Today, September 23rd, the Office of Natural Resources Revenue Asset Valuation Unbundling Team (AVUT) updated the Unbundling Cost Allocations for the San Juan Conventional Transportation System and the Ignacio Processing plant. These new numbers are for royalties reporting for these named plants for 2006-2010. The AVUT also calculated new Transportation UCA’s for the Otero, Lybrook and Buena Suerte Transportation systems. New Processing USA’s were published for the Huerfano Gas Plant for royalties reported from 2007 to July 2013. In order to assist operators, the AVUT has placed 4 additional documents relating to unbundling Transportation Systems and Processing Plants on the ONRR Website at onrr.gov/unbundling/methodology. I have attached the four documents to this email and they will also be on our website at ipanm.org.
Please note the following language from the ONRR website. This is their disclaimer:
“ONRR provides the UCAs on this website based on the best information available to ONRR at the time of publication. If ONRR receives more accurate information, then ONRR will update and modify the UCAs. You may use these UCAs as estimates for later time periods until such time as ONRR provides updated information. When ONRR updates or modifies information you may be subject to additional royalty obligations, or a credit, and associated interest under the provisions at 30 CFR §§ 1206.156(d) (for transportation allowances) and 1206.158(e) (for processing allowances). When ONRR updates the UCAs for a specific year you should adjust previously submitted royalty lines only for that specific year. Do not change previously reported data until ONRR publishes actual values. You should use the most recent UCAs as estimates for future reporting months.”
I have added emphasis to certain words here because this statement is unclear and yet the agency continues to believe operators will be able to comply with their unbundling enforcement efforts. IPANM is working closely with Senator Udall’s office to try to remedy the situation. Please consider contacting Jonathan Black at the Senator’s office via email or a letter to describe to him how difficult it is to comply with the ONRR unbundling theory. Jonathan’s email address is : Jonathan_Black@tomudall.senate.gov.
UCA-Calculations: accounting-and-contract-data-needs.pdf (79 kb)
UCA-Calucations: engineering-data-needs.pdf (75 kb)
How to Calculate a Processing – UCA.pdf (439 kb)
How to Calculate a Transportation UCA.pdf (402kb)
Disclaimer ONRR website 092313.pdf
