Appeal from the judgment of the United States District Court for the Western District of New York (Skretny, J.) confirming an arbitration award in favor of the defendant State of New York. The Seneca Nation of Indians (the “Nation”) argues that the arbitration panel majority manifestly disregarded the Indian Gaming Regulatory Act and the district court erred in confirming the award. Alternatively, the Nation argues that the district court erred in declining to refer the issues raised to the Department of the Interior pursuant to the primary jurisdiction doctrine. We agree with the district court that the dispute was a question of contractual interpretation reserved to the arbitral panel and referral was not necessary. Therefore, we AFFIRM the judgment of the district court. ROSEMARY POOLER, C.J. Plaintiff-Appellant Seneca Nation of Indians (the “Nation”) appeals from a judgment of the United States District Court for the Western District of New York (William M. Skretny, J.), entered on November 12, 2019, confirming an arbitral award for the State of New York. In the district court, the Nation argued that the arbitration panel majority manifestly disregarded the Indian Gaming Regulatory Act (“IGRA”), 25 U.S.C. §§2701-2721. The Nation argued that the panel usurped the authority of the Secretary of the Interior (the “Secretary”) by requiring the Nation to continue making payments to New York during the renewal period of a gambling compact between the parties. Alternatively, the Nation argued that the district court should refer the issues raised to the Department of the Interior (“DOI”) pursuant to the primary jurisdiction doctrine if it had any doubt as to whether the Secretary’s approval was required for those continued payments. The district court rejected these arguments, finding that the arbitral panel did not manifestly disregard the law in deciding on a disputed contractual term and imposing the payments. The district court also determined that referral to the DOI would undermine the parties’ agreement to submit disputes under the gambling compact to binding arbitration, and in any case was unnecessary to assess the propriety of the arbitration panel’s resolution of a contract dispute. Therefore, the district court confirmed the award. For the purposes of this appeal, the Nation concedes that it cannot relitigate the question, decided by the arbitral panel, of whether the contract requires payments during the renewal period. While the Nation focuses our attention on IGRA and the purposes underlying it, our review is narrower. We are simply asked to determine whether the arbitral panel manifestly disregarded IGRA in its decision. As such, we consider only (1) whether IGRA clearly imposes a requirement that the contract interpretation be subjected to the Secretary’s further approval, and (2) if so, whether the arbitration panel ignored or defied that governing law. It did not. The arbitral panel performed its assigned task of contract interpretation through standard methods. The district court also was not required to refer this question to the Department of the Interior, as contract interpretation is within the core competency of courts. We express no view about whether the Secretary’s position when the Compact was deemed approved was that it in fact required additional payments during the renewal term. We also express no view on whether a district court reviewing the Compact in the first instance could determine after reviewing post-agreement extrinsic evidence that the renewal term required continued payments, or whether IGRA would require secretarial approval of judicial interpretations that rely on extrinsic evidence. We hold only that the arbitral panel — which did in fact consider IGRA — reasonably concluded that its task here was a straightforward matter of contract interpretation not subject to the Secretary’s approval. Therefore, we AFFIRM the judgment of the district court confirming the arbitral award. BACKGROUND On August 18, 2002, the Nation and New York entered into a compact setting forth the terms and conditions under which the Nation could conduct certain casino-style gaming (Class III gaming, as defined by 25 U.S.C. §2701(d)) in New York (the “Compact”). On November 12, 2002, the Secretary completed review of the Compact and declined to approve or disapprove it. Pursuant to 25 U.S.C. §2710(d)(8)(c), the Compact was “considered to have been approved, ‘but only to the extent the compact is consistent with the provisions of [IGRA].’” App’x 163-64. The Compact became effective December 9, 2002. See Dep’t of the Interior, Indian Gaming, 67 Fed. Reg. 72968-01 (Dec. 9, 2002). The Compact provided for an initial term of 14 years and stated that absent objection by either party, “the term of this Compact shall be renewed automatically for an additional period of seven (7) years.” App’x 115. The essential bargain of the Compact was that the Nation received exclusive rights to maintain certain gaming machines in a large portion of Western New York (the “Exclusivity Zone”) in exchange for graduated revenue-sharing payments to New York from those machines (the “State Contribution”). For years 1-4, the State Contribution was 18 percent of the “net drop” of these machines (money dropped into machines, after payout, but before expenses). For years 5-7, it was 22 percent. For years 8-14, it was 25 percent. The Compact does not expressly address the terms of any State Contribution in the 7-year renewal period. New York received no other consideration in the Compact. The Nation’s obligation to pay the State Contribution began on December 31, 2002, when the Nation opened its first facility. During the initial 14-year period, the parties seemed largely satisfied with the agreement. The Nation notes that New York initially promised exclusivity for the Nation in both slot machines and video lottery gaming devices. However, New York began authorizing video lottery gaming devices within the Exclusivity Zone in 2004 and has, accordingly, collected payments only on the Nation’s slot machine revenue. Still, the parties agree that each received numerous benefits from the Compact. New York received more than $1.4 billion in payments through 2016. The Nation’s overall gaming revenue has been in the range of $6.5 billion during the term of the Compact. At the end of the 14-year term, neither party delivered written objections to renewal, resulting in automatic renewal of the Compact for an additional seven years on December 9, 2016. Therefore, the Compact remains in effect through December 9, 2023. Shortly before the initial term ended, the Nation contacted DOI regarding its understanding of the revenue-sharing provisions of the Compact during the renewal period. DOI responded with a technical assistance letter. The letter stated that DOI understood that the Compact contained 14 years of revenue sharing in exchange for 21 years of exclusivity and suggested that New York would need to make additional economic concessions benefiting the Nation to justify extending the revenue sharing provision to cover the renewal period. On March 31, 2017, Seneca Nation President Todd Gates notified New York Governor Andrew Cuomo that the State Contribution for the last quarter of 2016 would be the final payment under the Compact. The Nation stated that the Compact required only 14 years of the State Contribution. New York responded that the payments should continue at the 25 percent rate for the seven-year renewal period, and when the parties were unable to reach agreement, New York issued a demand for arbitration on September 7, 2017, in accordance with the Compact’s dispute resolution procedures. On December 15, 2017, DOI withdrew the technical assistance letter as it “did not provide the certainty available to the parties in arbitration proceedings.” App’x 212. Section 14 of the Compact provides for binding arbitration to resolve disputes. The Compact states that in the event of a dispute, the parties should engage in good faith negotiations. If the negotiations fail, “either [p]arty may submit the dispute, claim, question, or disagreement to binding arbitration” to be conducted in accordance with the rules of the American Arbitration Association (“AAA”). App’x 143-44. The parties then appoint an arbitral panel of three, with each party selecting one arbitrator, and the two arbitrators picking the third. The Compact specifies that the arbitral award would be “final, binding and non-appealable.” App’x 145. The Compact gave the United States District Court for the Western District of New York exclusive jurisdiction to enforce the arbitral award. The parties submitted their dispute to a panel of three arbitrators. The Nation selected Kevin Washburn, Dean of The University of Iowa College of Law and former Assistant Secretary of Indian Affairs in DOI. New York selected Henry Gutman, of Counsel at Simpson Thacher & Bartlett LLP. Those two arbitrators jointly selected William G. Bassler, a retired United States District Judge for the District of New Jersey, as the arbitral panel chair. With the parties’ agreement, the panel bifurcated its consideration of liability and remedy after conducting full arbitration hearings on December 12 and 13, 2018, resulting in a January 7, 2019 partial final award on liability with dissent; and an April 12, 2019 final award addressing remedies. The panel heard live testimony, including direct and cross examination, from Robert Williams, Deputy Secretary in the Office of Governor Cuomo. The panel also received two witness statements from Williams, a witness statement from Gates, and a statement from David Sheridan, Chief Financial Officer of the Seneca Gaming Corporation. It also received other documentary evidence. The panel majority — comprised of Bassler and Gutman — found that the renewal provision was ambiguous as to the Nation’s obligation to pay the State Contribution during the renewal period. Accordingly, the majority examined extrinsic evidence to resolve the ambiguity. The panel concluded that “read as a whole and in light of the extrinsic evidence” indicating “silence in the [renewal term's] negotiating history” and the “central premise” of an exchange of exclusivity for revenue sharing, the Compact should be read to require the Nation to make revenue sharing payments in the renewal period. App’x 29, 59, 63, 67, 77. The panel examined the parties’ pre-execution negotiations, post-execution communications, submissions from both parties to DOI, and determined “[t]he essential bargain of the Parties’ agreement is a commercial agreement wherein exclusivity payments are made in consideration for exclusivity.” App’x 67. The panel concluded that it would also be commercially unreasonable and against common sense to find that the word “renew” would extend the Nation’s exclusivity without obligating the Nation to provide any continuing consideration to New York. The Nation argued that the panel could not approve additional payments because the Secretary did not approve revenue sharing upon renewal of the Compact, as required by IGRA. 25 U.S.C. §2710(d)(8). The panel majority acknowledged that it had no “legal authority to usurp the Secretary’s” approval authority, but found that it could determine whether the terms of the Compact “already provide[d] for revenue-sharing payments upon renewal.” App’x 65. The majority found that the Nation’s argument depended on finding that the Secretary shared its interpretation, to wit, that the renewal term the Secretary deemed approved did not include additional payments — but there was “no evidence in the record” to support that contention. Id. Furthermore, the majority found that if the Nation’s argument were correct, DOI never approved the renewal term, and “that arguably would mean that renewal of the Compact was not properly authorized and the Nation’s gaming activities are unlawful.” Id. The majority was also unpersuaded that adopting New York’s position would be “approving” an additional seven years of payments; rather “it would simply be finding that the terms of renewal in the Compact deemed approved by the Secretary included revenue sharing payment obligations.” App’x 66. Washburn dissented. He viewed the terms of the Compact as unambiguously providing for only 14 years of State Contribution, with no State Contribution due in the 7-year renewal period. Washburn found the extrinsic evidence, the context of the negotiations, and the intent of the parties failed to support New York’s position that the Compact provided for State Contribution payments during the renewal period. With regards to IGRA, Washburn found the majority’s holding inconsistent with federal law and policy. First, he cited County of Oneida v. Oneida Indian Nation of New York State, 470 U.S. 226, 247 (1985), for the principle that if the Compact were indeed ambiguous, it should be interpreted liberally in the Nation’s favor and to its benefit. Second, he viewed the majority’s construction of the Compact as directly counter to the purpose of IGRA. Finally, Washburn wrote that if the Compact were ambiguous, the Secretary “cannot be said to have considered and reviewed or approved this key [renewal] provision,” and enforcement of the majority opinion had “the effect of enforcing an agreement that goes beyond what was approved by DOI, thus potentially undermining DOI’s important regulatory role.” App’x 102. The majority’s final award on remedy found that “the Nation is obliged under
