American Oil and Gas Reporter - July 2016 - 86

ConventionSection: Independent Petroleum Association of New Mexico
Basin in northern New Mexico. She says
legal issues may delay any such moves.
A nongovernmental organization, Diné
against Ruining the Environment, is suing
BLM, arguing that projects near Chaco
Canyon, including 236 leases, are impacting the archaeological value.
"The NGOs have taken Chaco Canyon,
which is a UNESCO world heritage site,
and drawn a 20 mile radius around it,"
Foster says. "They don't want any development within those 20 miles. But they
also have taken what are considered archaeological migration pathways that go
through the northern San Juan Basin into
Colorado, and they want no development
in those pathways. One of those pathways
goes right through the heart of the San
Juan Basin."
Onshore Orders
New Mexico operators also are waiting
for BLM to issue revisions to Onshore
Orders No. 3, 4 and 5, Foster says. After
several rounds of commenting, the bureau
is expected to finalize the regulations by
the end of the year, she adds. Among its
provisions, Onshore Order No. 3 ensures
operators accurately report oil and gas
production from leases on federal and
Indian lands, and expands federal regulatory authority to state and fee tracts on
federally approved units or communitized
areas. Order No. 4 includes measurement
standards for crude oil, and No. 5 does
the same for natural gas production
(AOGR, February 2016, pg. 95).
"Based on stakeholder meetings and
several conversations with BLM, I think
those onshore orders will not be changing
very much, regardless of submitted comments," predicts Foster. "That is not good
news. Onshore Order No. 3, in particular,
is really going to hurt New Mexico
because of the commingling issue."
Commingling is a practice that has
developed over time that is unique to the
San Juan Basin, she points out. Foster
predicts BLM will move to impose additional requirements on all wells operating
on federal units, despite more than 80
years of contractual agreements.
"It is not only the federal wells over
which BLM thinks it has jurisdiction; it
is every private and state well impacting
all formations that happens to be in that
federal unit over which BLM now thinks
it has jurisdiction. The New Mexico State
Land Office is very opposed to Onshore
Order No. 3, because of the communitization and commingling issues," she says.
86 THE AMERICAN OIL & GAS REPORTER

In addition to a host of oil and gas industry associations opposing BLM's proposed revisions, Foster says New Mexico's
senators have expressed their opposition.
In an April letter to the bureau, Democratic
Senators Tom Udall and Martin Heinrich
urge BLM to consider grandfathering existing and previously approved commingling
agreements into any revisions to the order.
Annual Meeting
Krakauskas says declining meeting
attendance the past few years was a main
reason the association opted to move the
annual convention to the Hilton Santa Fe
Historic Plaza in Santa Fe this year.
"IPANM wants to change that by trying
to attract members who have not attended
in a few years. Sandia is such a remote
location for a meeting. I think moving
the meeting will be popular with members," he predicts.
Robert Bryce, author of Smaller, Faster,
Lighter, Denser, Cheaper: How Innovation
Keeps Proving the Catastrophists Wrong,
will be the meeting's keynote speaker,
Krakauskas says, adding Bryce's pres-

entation will examine the future of hydrocarbons and why the world is on the
brink of another American century.
To supplement the invited regulators
and industry experts, Foster mentions
plans to distribute her annual meeting
booklet laying out IPANM's achievements
and challenges over the past year. She
notes that this year's edition also will be
available in digital format, which will include the text's cited supporting documents.
"The booklet will have discussion
points on all the comments IPANM submitted this year," Foster says. "The amount
of comments the association had to respond to from the federal government
this year was more than any other year
that I have represented IPANM. What I
found in every single instance was the
federal government had rushed through
the process, and the supporting science
was very flimsy. There was a lot of fluff
in the regulations to make them look
thick. A look at what was included very
often revealed the government's arguments
did not have the scientific or factual support."
❒

BLM Changes To RMP Process
Spark Concerns In New Mexico
ALBUQUERQUE, N.M.-In addition
to the rule changes for air quality, increasing
penalties and changing royalty requirements, the Bureau of Land Management
continues to rewrite its guidance documents
on its administrative process, observes
Karin Foster, executive director of the Independent Petroleum Association of New
Mexico, pointing to revisions in the way
BLM develops resource management plans
under what it calls Planning 2.0.
"Although the Planning 2.0 name implies this is a second version of an existing
process, in actuality this is a wholesale
revision that sets up an entirely new way
of considering land that is impacted by
BLM's multiple-use mandates," says Foster. Of particular concern to association
members is the RMP being prepared for
southeast New Mexico.
"The next thing on the association's
horizon will be the Carlsbad RMP. I
expect the new document to be upward
of 1,000 pages, with several new provisions
that will impact whether IPANM members
will want to operate on federal lands and
how they will have to operate," she says.

"I think the timelines for development
will be expanded significantly. I am really
concerned about that. IPANM's comments
on Planning 2.0 speak to what we expect
to see in the RMP, which will be very
difficult to respond to."
BLM says it is reviewing the way it
develops and updates RMPs to improve
its public lands management. According
to the bureau, its goals include improving
the bureau's ability to respond to environmental, economic and social changes
in a timely manner, strengthen other federal, state and local government involvement in developing land-use plans, and
improve BLM's ability to address landscape-scale resource issues.
According to BLM, the proposed rule:
* Encourages early public involvement
in the planning process;
* Requires developing a planning assessment prior to work on a land-use
plan;
* Improves its ability to use best
available science and geospatial data in
plan development; and
* Relies on landscape-level planning

American Oil and Gas Reporter - July 2016

Table of Contents for the Digital Edition of American Oil and Gas Reporter - July 2016