Although geothermal energy has been used commercially since at least 1818,¹ up until now it has received little public attention as an alternative energy source. The late energy panic has of course changed that situation, and major mineral development corporations are sending scores of field geologists scurrying into the West in search of steam. Just as prospecting techniques very from simply standing on mountaintops and looking for fumaroles to highly sophisticated passive seismology and aerial magnetic surveys, so do likely geothermal fields range from rugged glacial cirques to flat Idaho farmland.

A primary byproduct of any large scale resource development is always litigation, and the exploitation of geothermal energy will not likely prove an exception; already a small new body of geothermal law is growing.² The active wilderness advocate should brace himself for a storm, for it appears that there is at least prima facie ambiguity as to whether a resource development company may prospect for and develop geothermal resources in wilderness areas that are otherwise offered extensive federal protection.³