Apr 2, 2026 Coalition Comments on BLM proposed Requirements for Site Security and Production Handling; Applying for Commingling and Allocation Approval
To Whom It May Concern:
The American Petroleum Institute (“API”), Independent Petroleum Association of America (“IPAA”), Alaska Oil and Gas Association (“AOGA”), Colorado Oil and Gas Association (“COGA”), Montana Petroleum Association (“MPA”), New Mexico Oil and Gas Association (“NMOGA”), North Dakota Petroleum Council (“NDPC”), the Petroleum Alliance of Oklahoma, the Petroleum Association of Wyoming, and the Western States Petroleum Association (“WSPA”)— collectively “The Associations” — respectfully submit the following coalition comments on the Bureau of Land Management’s (“BLM”) proposed Requirements for Site Security and Production Handling; Applying for Commingling and Allocation Approval (“Proposed Rule”) that was published in the Federal Register on January 30, 2026. This letter contains both our substantive comments and a suggested redline of regulatory text (Attachment 1). On March 2, 2026, the API and ten industry partners submitted comments to the BLM in response to the Office of Management and Budget’s Information Collection Request (“ICR”) pertaining to the revised information collection requirements in the Proposed Rule. …
