An update on the proposed BLM commingling Instructional Memoranda 2011-0184 (11/20/2012)

A small group of operators, both major and independent producers met with a group of BLM representatives from the Washington, DC office on November 8. Commingling in the State of New Mexico has been a common practice for the past 40 years and the new IM would have eliminated its use in many situations including down-hole commingling and surface commingling. Both the Farmington BLM Field Office and the Carlsbad BLM Field Office opposed implementing the order and encouraged the State office to set up a meeting with several producers to discuss the pertinent issues. A lot of facts were presented at the meeting and after a few days of reviewing the information, the DC office is going to hold back on issuing both the commingling and beneficial use IM’s. This is great news for operators across the state. However they may pursue these issues during the re-write of Onshore Oil and Gas orders currently being updated and expected to hit the Federal Register next spring.