BLM Conservation Rule Rescission Comments

The Independent Petroleum Association of America writes in support of The BLM’s Proposed Rule to rescind the Conservation and Landscape Health Rule adopted on May 9, 2024, via 89 FR 40308, with an effective date of June 10, 2024. The Independent Petroleum Association of America (IPAA) is a national upstream trade association representing thousands of independent oil and natural gas producers and service companies across the United States. Independent producers operate 95 percent of the nation’s oil and natural gas wells and are responsible for 85 percent of US oil production and 90 percent of natural gas production onshore.

Attached, please see IPAA’s comment letter we submitted in 2023, detailing how the Rule creates a profound shift in how public lands are managed that is inconsistent with the intent of the Federal Lands Policy and Management Act of 1976 (FLPMA). IPAA is gravely concerned that the Rule fundamentally changes the way BLM carries out its multiple-use and sustained yield mandates by elevating conservation to a “use” under FLPMA.