Practical Implications for Projects in Ozone Nonattainment Areas By Bret Sumner, and Raj Lahoti A recent Interior Board of Land Appeals (IBLA) decision vacating Bureau of Land Management’s (BLM) approval of a large scale federal natural gas development project in Wyoming addresses how Clean Air Act (CAA) general conformity analyses must account for emissions from […]

New Mexico Moves Closer to Streamlining Carbon Capture Projects with Proposed State-Led Class VI Well Rules
Carbon capture developers facing multi-year federal permitting delays may soon have a faster path forward. New Mexico is proposing state-specific rules that could slash Class VI underground injection well approval times from years to approximately six to eight months—a potential game changer for project economics, investment decisions, and the state’s competitiveness in the growing carbon […]
PUCT Signals Major Changes Ahead for Large Load Interconnection in Texas
By Miguel Suazo and Raj Lahoti Last week, the Public Utility Commission of Texas (PUCT) convened a full-day stakeholder workshop in Project No. 58481 to gather input on implementing new large-load interconnection standards under PURA §37.0561. The workshop included extensive participation from electric utilities, ERCOT, large-load customers (including data center and industrial developers), and trade […]
New Mexico PRC Issues Notice of Proposed Rulemaking on Community Solar Program
BLM Proposes to Extend Compliance Deadlines for Bonding, Measurement and Sampling Requirements for High Pressure Flares, Submission of LDAR Reporting
By Theresa Sauer and Jacob Everhart This week, the Bureau of Land Management (“BLM”) published two direct final rules (“DFR”) to amend its regulations pertaining to minimum statewide bonding requirements, high pressure flare measurement and sampling requirements, and leak detection and repair (“LDAR”) reporting. Bonding On December 18, 2025, BLM published a DFR to amend […]
New NM OCD Rules Aim to Streamline Pooling and Hearings—But Add New Filing Hurdles
The New Mexico Oil Conservation Division (“OCD”) recently provided advance notice to industry and operators regarding the staggered implementation of new policy requirements. In total, three Notices propose to change OCD requirements for the following processes: (1) Changes to the Hearing Submission Process, (2) Procedure for Deviation from Orders, and (3) Evidentiary Requirements for Compulsory […]
Beatty & Wozniak Welcomes Veteran General Counsel Francis Barron as General Counsel in Residence
DENVER (September 8, 2025) — Beatty & Wozniak, P.C., a nationally recognized oil and gas, energy, and natural resources law firm, is proud to announce that Francis Barron has joined the firm as its first General Counsel in Residence. With more than 35 years of experience, Barron is a respected corporate and securities attorney who […]
Congress Legislates Commingling Reform for Federal Oil and Gas Production; BLM to Initiate Rulemaking Process for Implementing Regulations
By Bret Sumner & Jacob Everhart The Big Beautiful Bill or the Reconciliation Act of 2025 (the Act) (House Resolution 1), contains an important provision for upstream oil and natural gas operators on federal lands. This provision directs the Bureau of Land Management (BLM) to draft a rule authorizing commingling of production from diverse mineral ownership (federal and fee, federal,…
Successor in Interest or Successor in Liability? New Mexico Court Expands SLO’s Reach in Marathon Decision
The recent Richard v. Marathon Petroleum Corp. decision compels oil and gas operators to adopt rigorous due diligence standards prior to lease acquisitions. The New Mexico Court of Appeals (NMCA) ruled that New Mexico State Land Office (SLO) approved lease assignments do not absolve assignors or their successors in interest from liability for tortious or statutory harms caused before the…
Supreme Court Issues a Course Correction to Bring Sanity Back to NEPA Reviews
Today, in a unanimous decision, the Supreme Court of the United States issued a “course correction. . .to bring judicial review under NEPA back in line with the statutory text and common sense.”[1] In Seven County, the Court held that the D.C. Circuit Court of Appeals erred in finding deficiencies in the agency’s NEPA analysis for approval of a railroad…









