Stop BLM from cutting royalties on wasted oil and gas

What the public could have raised, from the agency’s own document

• I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
• The proposed rule keeps operator negligence as a basis for finding an emergency-related gas loss 'avoidably lost' under section 3179.41(e), but it simultaneously eliminates the Sundry Notice requirement that previously required operators to describe the emergency event and measures taken to control it within 45 days, the very information BLM used to determine whether a loss was due to negligence. The agency should explain how it will identify negligent emergency losses without the reporting mechanism it is eliminating, or retain a reporting requirement sufficient to support negligence determinations.
• The agency repeatedly states that NTL-4A proved unsuited to modern horizontal drilling and hydraulic fracturing operations, yet the proposed rule conforms several of its new time and volume limits, such as those for well completion and recompletion flaring, directly back to the limits established in NTL-4A. The agency should explain why standards it says are outdated and ill-suited for current production techniques are nonetheless being reinstated as the operative limits in the new rule.
• The proposed rule changes the stated purpose of the subpart from including protection of worker safety and conservation of surface resources, as in the 2024 Rule, to a purpose focused only on compensation, efficient development, burden reduction, and streamlining, with no explanation of why worker safety and surface resource conservation are being dropped as regulatory objectives. The agency should explain why worker safety and surface resource conservation are no longer part of the rule's purpose or restore them.
• The agency proposes to eliminate the requirement that operators use appropriately sized production equipment, stating only that there is no way to practically enforce it, without describing any effort to develop an enforceable version of the standard or evaluating what volume of gas loss results from undersized equipment. The agency should either develop an enforceable equipment-sizing standard or provide data showing that undersized equipment does not contribute meaningfully to gas losses before eliminating the requirement.