Support Common-Sense BLM Rule Changes | NSWA

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Support Common-Sense BLM Rule Changes

Two proposed Bureau of Land Management rules would improve federal oil and gas policy for small, independent, and marginal-well operators. Use the templates below, personalize your comments, and submit them directly to BLM.

Comment deadline: August 24, 2026

Comment on Leasing & Bonding Comment on Waste Prevention & Royalties

Why your comment matters

BLM considers the public record when finalizing federal regulations. A short, specific, personalized comment from an operator, employee, service company, royalty owner, or rural community member can help explain how these rules affect real businesses and producing wells.

Please submit a separate comment for each docket. The templates are starting points—not legal advice—and should be edited to reflect your own experience.

Three easy steps

Choose a rule below.
Personalize the highlighted bracketed sections.
Copy the comment and submit it on Regulations.gov.

BLM-2025-0037-0001

Oil and Gas Leasing & Bonding

Support attainable bonding requirements and risk-based oversight for responsible operators.

Why NSWA supports the proposal

Restores more reasonable minimum lease and statewide bond levels.
Recognizes that very high bond requirements can be unattainable for small operators.
Preserves BLM authority to require higher bonds where actual risk warrants it.
Keeps working capital available for maintenance, compliance, mechanical integrity, and plugging.
Helps preserve marginal production, federal royalties, state revenue, and rural jobs.

Submit Comment to BLM

Choose your comment

This version requires no edits. Copy it as written and submit it directly to BLM.

Re: Docket No. BLM-2025-0037 — Oil and Gas Leasing

I support the Bureau of Land Management’s proposed revisions to the federal oil and gas leasing regulations, particularly the restoration of more reasonable minimum bonding requirements and the continued use of risk-based bond adequacy reviews.

The 2024 bonding increases created a serious and unnecessary burden for small and marginal-well operators. The practical cost of a bond is not limited to the annual premium. Sureties may require substantial collateral, letters of credit, personal guarantees, or other financial commitments that reduce the capital available for maintenance, environmental compliance, mechanical integrity, and the plugging of wells that have reached the end of their productive lives.

A one-size-fits-all minimum does not distinguish responsible, low-risk operators from operators with significant inactive-well inventories, poor compliance histories, or greater reclamation exposure. BLM should focus additional financial assurance on actual risk while recognizing successful plugging performance, responsible operation, and compliance history.

Producing marginal wells continue to provide federal royalties, state and local revenue, employment, and domestic energy from existing wells and existing surface footprints. Unnecessarily high minimum bonds can force otherwise viable wells out of production prematurely and accelerate plugging obligations without providing a corresponding public benefit.

I respectfully urge BLM to finalize the restoration of reasonable individual lease and statewide minimum bond amounts, reinstate a workable nationwide bond option, retain risk-based bond adequacy reviews, apply bond review standards consistently, and recognize responsible operating and plugging history when evaluating bond adequacy.

Thank you for considering my comments.

Open Regulations.gov

Complete the fields below. Your finished comment updates automatically.

Your role

State

Your company, work, or connection to marginal production

How higher bonding requirements affect you

Open Regulations.gov

BLM-2025-0235-0001

Waste Prevention, Flaring, LDAR & Lost-Gas Royalties

Support a practical royalty framework that avoids duplicative environmental regulation.

Why NSWA supports the proposal

Removes duplicative BLM administrative LDAR requirements.
Creates more workable venting and flaring provisions.
Reduces unnecessary measurement, reporting, and compliance costs.
Better respects the separate roles of BLM, EPA, and state regulators.
Allows BLM to focus on federal mineral management and royalty determinations.

Submit Comment to BLM

Choose your comment

This version requires no edits. Copy it as written and submit it directly to BLM.

Re: Docket No. BLM-2025-0235 — Royalty for Oil and Gas Lost From Onshore Federal and Indian Leases

I support the Bureau of Land Management’s proposed revisions to the rules governing venting, flaring, leak detection and repair, and royalty determinations for lost oil and natural gas.

BLM’s primary responsibility in this area is to manage federal minerals, prevent avoidable waste, and determine when royalties are due. The 2024 rule expanded BLM requirements into areas already regulated by the Environmental Protection Agency, state oil and gas agencies, and state air-quality regulators. This creates duplicative inspections, plans, recordkeeping, and administrative costs without necessarily producing an equivalent public benefit.

The proposed rule would provide a more practical framework by removing duplicative administrative LDAR requirements and revising flaring and lost-gas provisions. These changes are especially important for marginal wells, where fixed compliance costs are spread across very small volumes of production.

Operators already have strong economic incentives to capture and sell natural gas whenever it is technically and economically feasible. Gas that is sold generates revenue. However, mature wells, temporary operating conditions, pipeline limitations, safety events, and low-volume production can make capture impractical in particular circumstances. Federal regulations should distinguish avoidable waste from reasonable and necessary operational losses.

I respectfully urge BLM to finalize the removal of duplicative administrative LDAR requirements, adopt workable venting and flaring provisions that account for actual field conditions, avoid duplicating environmental programs administered by EPA and state regulators, limit royalty determinations to oil and gas that is avoidably lost under a clear and practical standard, and consider the disproportionate effect of fixed compliance costs on marginal and low-volume wells.

The proposed revisions would reduce unnecessary administrative burdens while preserving appropriate oversight, responsible operations, and a fair return to the public.

Thank you for considering my comments.

Open Regulations.gov

Complete the fields below. Your finished comment updates automatically.

Your role

State

Your company, work, or connection to marginal production

A real LDAR, flaring, reporting, or pipeline example

Open Regulations.gov

This resource is provided for general informational and advocacy purposes. Commenters are responsible for reviewing and personalizing their own submissions. NSWA does not guarantee that Regulations.gov links or agency deadlines will remain unchanged.

Why your comment matters

Oil and Gas Leasing & Bonding

Why NSWA supports the proposal

Choose your comment

Waste Prevention, Flaring, LDAR & Lost-Gas Royalties

Why NSWA supports the proposal

Choose your comment

Help strengthen the public record