The Associations’ Comments – 2026 Federal Oil and Gas Valuation

The Associations’ Comments – 2026 Federal Oil and Gas Valuation

IPAA and the Western Energy Alliance (the “Associations”) represent many members who are responsible for the filing of the Federal production and royalty reports to the Office of Natural Resources Revenue (“ONRR”).

The following tenets underly the Associations’ comments that follow:

1. The Associations support Secretary Burgum’s efforts to repeal regulations that are burdensome and unneeded. The Associations support the Secretary’s efforts to make regulations clearer, more consistent, and more certain in their application.

2. The Associations agree that free markets are the best way to create jobs, provide energy, and increase the nation’s wealth. To further those goals, the Associations continue to believe that the Department’s decision in 1988 to use the gross proceeds from arm’s length contracts as the best indication of market value is still the correct approach to follow in royalty valuation.

3. The Associations welcome this rulemaking as an opportunity to correct ill-considered trends in recent years in ONRR’s valuation and enforcement practices. More specifically, ONRR has altered its interpretation of the rules in recent years through ad hoc decisions that lead to costly, long drawn out disputes. …