AXPC Statement on Department of Interior Proposed Updates to Commingling Rules 

July 8, 2025

Washington, D.C. – Today, American Exploration & Production Council (AXPC) CEO Anne Bradbury issued the following statement after the Department of Interior announced forthcoming proposed updates to the Bureau of Land Management ‘s (BLM) commingling rules:  

“Enabling the broad use of commingling is one of the quickest, most effective ways for BLM to support domestic energy production and President Trump’s American energy dominance agenda.  

“AXPC applauds Secretary Bergum and the Department of Interior for moving at lightning speed to unlock production efficiencies that benefit taxpayers, enhance resource stewardship, and reduce operational impacts to the environment. 

“The planned rules updates represent a significant win-win, increasing efficiencies for domestic production on federal lands, while at the same time allowing for reduced environmental impacts, and we look forward to working with the Department of Interior to continue eliminating red tape that is holding American energy production back.” 

BACKGROUND 

What is Commingling? Surface commingling is the practice of producing oil or gas production from multiple federal leases or wells through a shared surface facility. By allowing operators to consolidate production infrastructure, surface commingling using modern allocation methods reduces capital costs, minimizes duplicative equipment, which helps reduce overall surface footprint and environmental impacts of facilities while still ensuring full proceeds from the development of these taxpayer owned resources. 

One, Big, Beautiful Bill Act: The OBBBA requires BLM to approve applications for the commingling of production if the applicant agrees to approved allocation methods to ensure accurate royalty accounting. 

Commingling Benefits: 

• Environmental Impacts: Commingling significantly reduces the environmental footprint of oil and gas operations by limiting the need for multiple well pads, access roads, and processing facilities, which in turn decreases land disturbance, truck traffic, and associated emissions. 

• Unlocking Federal Mineral Acreage: The broad use of commingling can potentially unlock federal mineral acreage that might otherwise be uneconomic or cost-prohibitive to develop compared to fee and state lands, which historically has led to stranded resources like marginal wells or leases that may not be viable on their own.  

• Economic Advantages: Approved more broadly by BLM, commingling could reduce by half the number of production facilities needed across an operator’s annual development program. At a savings of $6–8 million each, in some circumstances, this can equate to $100 million in capital or more that could then be invested in additional development instead of in the build out of redundant facilities.