IPANM & Mountains State Legal Foundation (Sept. 22, 2023) – The Independent Petroleum Association of New Mexico (IPANM) joins the Mountain States Legal Foundation (MSLF) in opposing a new proposed federal rule that sets out to do exactly the opposite of what the BLM’s Federal Leasing Program intended: Allow access to Oil & Gas extraction on federal lands.
The two associations submitted comments submitted today that read, “The Proposed Rule is an attempt to achieve through bureaucratic obfuscation what the BLM and Department of the Interior cannot do directly: prohibit new and even already-authorized oil and gas development on federal lands.”
Citing proposed language that attempts to unravel existing leasing regulations, the comments continue, “Among other things, the Proposed Rule improperly expands the scope of agency discretion and delegates that discretion to other entities in ways that contradict the letter and spirit of the statutes from which the BLM and the Interior derive any their alleged authority.”
Both IPANM and MSLF have worked closely on issues that are impacting producers in New Mexico, specifically with overly restrictive state and federal regulations that are obstructing the work of independent producers.
Today’s letter concludes, “Ultimately, the Proposed Rule is an attempt to achieve through bureaucratic obfuscation what the BLM and the Interior cannot do directly: prohibit oil and gas development on federal lands. The Proposed Rule both improperly expands the scope of agency discretion and delegates that discretion to new entities in ways that contradict the letter and spirit of the congressionally enacted statutes from which that authority derives. It also invites unreasonable and unreasonably explained administrative decision-making.”
IPANM thanks the MSLF for the collaborative effort with a bulk of the substantive comments authored by the legal team at Mountain States Legal Foundation.
A full copy of the comment letter can be below.
MSLF / IPANM Comment Letter on Proposed Federal Leasing Rule – September 22, 2023