For our upstream members, work with the DOGM continues on rules regarding Forced Pooling. The Board has received several written comments, including from UPA, as part of the informal rulemaking. Expect to see a formal notice of draft rulemaking to come out very soon. UPA will continue to engage in the formal rulemaking and provide formal public comments on the draft rule, but we would encourage every operator to also provide their feedback.
Immediately following Forced Pooling, DOGM will initiate a rulemaking process on Operatorship. This will allow the board to designate an operator for the drilling, pooling, and oil and gas operations of a well not within a drilling unit or of the lands and the pool within a drilling unit. Similar to the efforts on Forced Pooling, UPA’s upstream committee will start the process to discuss if we can come to a common industry position on some of the elements. We anticipate providing comments to DOGM, first through an informal rulemaking basis and then through comments on the draft rule during the formal rulemaking process. Respecting that members are likely to have differing views on the best mechanisms to deal with these issues, we strongly encourage you to also engage directly with DOGM through both Forced Pooling and Operatorship rulemaking process.
In their March board meeting, The SITLA Board of Trustees approved proceeding with formal rulemaking on a change of SITLA’s oil and gas rules. UPA provided the proposed draft rules to the upstream committee for review during an informal comment period. We expect the formal rulemaking process to start in April and will send out notice once the draft rules are available for formal public comment. SITLA anticipates the final rule to be in place by June.
And finally, the Record of Decision for the BLM Sage Grouse Resource Management Plan Amendment was released on March 14th. A Draft EIS and Plan Amendments for BLM-managed public lands in Utah was published on May 4, 2018, initiating a 90-day public comment period that ended on August 2, 2018. On December 7, 2018 the BLM Utah released the Proposed Resource Management Plan Amendment and Final Environmental Impact Statement (Proposed RMPA/Final EIS) for a 30-day protest period and a 60-day Governor’s Consistency Review. The BLM received 8 protest letters. The Management Alignment Alternative in the Draft EIS was proposed to enhance cooperation and improve alignment between BLM plans for conserving Greater Sage-Grouse habitat and the State of Utah’s updated 2019 plan for managing the Greater Sage-Grouse species.