By Ahuva Battams, Miguel Suazo, and Raj Lahoti Texas Operators Should Prepare Now for Mandatory Electronic Filing The Railroad Commission of Texas (RRC) has announced that, effective September 1, 2026, it will no longer accept hard-copy submissions for several...
By Ahuva Battams On May 18, 2026, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a new Statement of Policy on transporting hazardous liquids and carbon dioxide in non-steel pipelines, marking an important development for pipeline operators,...
Geothermal energy developers working on federal lands have a new tool in their permitting toolkit. Effective April 28, 2026, BLM established a new categorical exclusion (CE) that allows the agency to approve notices of intent for small-scale geothermal exploration...
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...
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...
By Miguel Suazo and Jacob Everhart The New Mexico Public Regulation Commission (“PRC”) recently initiated a formal rulemaking process to consider extensive amendments to the Community Solar Rule under 17.9.573 NMAC (the “Rule”). The proposed amendments are the result...
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...
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)...
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,…
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…