IPANM (August 8, 2025) – IPANM filed all of its witness testimony to the Oil Conservation Commission regarding Western Environmental Law Center (WELC)’s Rulemaking Petition to raise financial assurance levels on state lands. These IPANM filings represent a year’s worth of policy discussion, data collection, and witness testimony in opposition of WELC’s overly prescriptive and overly costly rule.
Make no mistake, this rulemaking is being driven by environmental groups that want to end the secondary lifecycles of marginal wells. The New Mexico Oil Conservation Division has done no favors for us either through their near blanket-support of these proposals, as their testimony reflects.
IPANM is treating this rulemaking with the highest priority, and our testimony reflects our most vigorous opposition to this proposed rule. (For context, the proposed rule is being pushed administratively after the enviros and the OCD failed to get legislation passed in previous sessions.)
All testimony is now public record, and below are links to IPANM’s witness testimony. IPANM would like to thank these members who are standing up to represent the collective interests of independents.
Witness Topic: Effects on Operators
Testimony of David Mitchell
Testimony of George Sharpe
Testimony of Jerome McHugh, Jr.
Testimony of Vern Andrews
Witness Topic: Effects on Deals & Acquisitions
Testimony of Jeff Harvard
Testimony of Kyle Armstrong
Witness Topic: Conservation Tax
Testimony of Mark Murphy
Witness Topic: Legalities of Rule
Testimony of T. Calder Ezzell
Witness Topic: Bonding Markets
Testimony of Trevor Gilstrap
Witness Topic: Study Findings
Testimony of Robert Arscott
Witness Topic: Rule Impacts in Colorado
Testimony of Sam Bradley
Witness Topic: General Context/Member Issues
Testimony of Jim Winchester
IPANM’s Legal Team on the WELC Rulemaking has been led by Drew Cloutier and Ann Tripp of Hinkle Shanor LLP in Roswell. On behalf of the membership, I’d like to thank our legal team for months of fulltime work to prepare our filings, Hinkle Shanor LLP.
IPANM’s Complete Financial Assurance Testimony Filed
NMOCD’s Full Filings
State Land Office’s Full Filings
