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I appreciate the opportunity to provide comments on the proposed rule, Waste Prevention, Production Subject to Royalties, and Resource Conservation Rule published on February 8, 2016 by the Bureau of Land Management (BLM). As a proud resident of New Mexico, I know firsthand the value of the oil & gas industry. The rule, as proposed, greatly concerns me for the following reasons:
- The oil and gas industry has a long history of being a significant funding source for the New Mexico general revenue fund, severance tax bonding, and permanent funds. In 2014, 35% of the state general fund revenues came from activities of the oil and gas industry, and this industry is vital to the long-term economic success of New Mexico. The vital services funded by oil and gas revenues include teachers’ salaries, building schools, and providing healthcare for our poorest citizens.
- Approximately 63% of New Mexico’s natural gas production and 54% of oil production originates from mineral leases on federal land. Production on these leases generates significant tax revenue that our local communities and citizens in southeast New Mexico depend on for our livelihoods.
- This rule, as proposed, will have substantial unintended consequences on oil and gas operators, local communities, and funding necessary for critical state services. The costly compliance impacts associated with this rule will force operators to prematurely shut-in wells which will result in fewer jobs for hard working New Mexicans and less tax money for state funded programs.
- Current state regulations and voluntary initiatives by companies utilizing new technologies have DECREASED methane emissions from both oil and gas production while production has INCREASED. According to the EPA, methane emissions have been reduced 38% related to natural gas production and 21% related to oil production from 1990 – 2013, and producers have made additional progress in recent years.
- As drafted, this rule will not achieve the BLM’s intended goal to obtain lower methane emissions and cleaner air. In fact, the environmental improvements of this rule are negligible while negative economic impacts on the industry are drastic. Methane emissions are decreasing under existing regulations and voluntary industry action that does not put oil and gas production, reserves, the communities and state at risk.
- As written, the rule will cause unnecessary and severe economic harm to our state, our communities, and real lives.
I respectfully ask you conduct a more thorough evaluation of this rule that considers a more balanced review of the statewide direct and indirect economic impacts compared to anticipated benefits. At a minimum, the BLM should consider limiting the application of the proposed regulation to only new wells and grandfather existing facilities to minimize significant unintended consequences.
Links to Submit Your Comments:
Link to comments on Proposed Venting and Flaring Rule: https://www.regulations.gov/#!documentDetail;D=BLM-2016-0001-0001
Link to send a copy of your comments to Senator Udall: https://www.tomudall.senate.gov/?p=contact
Link to send a copy of your comments to Senator Heinrich: https://www.heinrich.senate.gov/contact/write-martin
Link to send a copy of your comments to Representative Pearce: https://pearce.house.gov/contact-me/email-me
Link to send a copy of your comments to Representative Lujan: https://lujan.house.gov/issue-subscribe
Link to send a copy of your comments to Representative Lujan-Grisham: https://lujangrisham.house.gov/contact