AXPC Provides Recommendations to BLM Waste Prevention Proposed Rule to Improve Feasibility and Safety of Rules

WASHINGTON – AXPC submitted comments and recommendations to the Bureau of Land Management’s (BLM) Proposed Rulemaking on Waste Prevention, Production Subject to Royalties, and Resource Conservation. 

“Our members are committed to minimizing waste and methane emissions and being good stewards of the environment. Proper development of BLM’s Proposed Rule is important to us and will have a significant impact on member operations; therefore, we want to work with BLM to resolve technical issues we have identified and help the agency craft a more defensible rule,” said AXPC CEO Anne Bradbury.

AXPC’s comments identify several overarching concerns that should be addressed by the agency to conform to their statutory authority and make the rule more tenable, effective, and efficient for both BLM and American’s independent producers of oil and natural gas. 

AXPC urges BLM to return to its practice of evaluating economics and costs as a required, fundamental element of the Mineral Leasing Act and other associated statues, as has been implemented by BLM for decades and upheld by the courts.  AXPC also explains that in some areas the Proposed Rule conflicts with other existing BLM regulations, State programs, and with the duties of the Bureau to manage the economic development of these oil and natural gas resources for the benefit of both the lessor and the lessee. There are also several proposed provisions where AXPC understands the intent and goals of BLM, but identifies operative and technical issues that would result in these goals not being achievable.

AXPC provided detailed recommendations for needed clarifications and alternatives to improve the rule’s technical feasibility and avoid unintended consequences, including some crucial safety concerns. 

AXPC’s technical, legal, and safety concerns can be found in the full comments here along with recommended solutions.  AXPC will continue to work collaboratively with BLM on this rulemaking and to continue supporting efforts to improve performance on these important matters. 

AXPC also adopts and incorporates by reference the comments submitted by the American Petroleum Institute (API).

About the American Exploration and Production Council:
AXPC is a national trade association representing the leading independent oil and natural gas exploration and production companies in the United States. We lead the world in the cleanest and safest onshore production of oil and gas, while supporting millions of Americans in high-paying jobs and investing a wealth of resources in our communities. Learn more at


← Back to News