AXPC Submits Comments on Federal Oil and Gas Program

WASHINGTON – The American Exploration and Production Council submitted formal comments to the U.S. Department of the Interior (DOI) following AXPC’s participation in the DOI forum on the federal oil and gas program.

“We take our responsibility to steward public lands seriously and we are committed to safe, environmentally protective oil and natural production that provides a fair return to the American people,” said AXPC CEO Anne Bradbury. “AXPC members are committed to working with local, state, tribal, and federal governments to responsibly produce the Nation’s natural resources, and care deeply about protecting cultural resources and the environment.  Our companies are also highly conscientious about working with, and listening to, the communities and the people in the places where we operate.”

AXPC’s comments focused on how the U.S. oil and natural gas industry continues to develop and deploy myriad technological advancements to reduce surface disturbance, emissions, water usage, and broader environmental impacts across all areas of operations, including on federal lands.  AXPC expressed its commitment and willingness to work with DOI as the Agency undergoes its review of the oil and gas program and considers new policy to support the nations’ energy, environmental, and economic goals.

AXPC’s comments demonstrate some of the ways our members are committed to working with local, state, tribal, and federal governments to responsibly produce the Nation’s natural resources:

    • Industry has not spent years stockpiling onshore leases: Data from the U.S. Department of the Interior Bureau of Land Management Oil & Gas Statistics show that companies have not been stockpiling leases and are diligently working to bring any leases held to production using technological advances that yield more production with less impact.
    • Americans receive substantial economic benefits from onshore oil and gas leases: According to the Office of Natural Resource Revenue (ONRR), in fiscal year 2019 alone, revenues from federal onshore oil and natural gas leases totaled around $4.2 billion, including: $2.931 billion in royalties and $1.181 billion in bonuses (when a lease sale occurs).
    • The issuance of onshore leases does not prohibit other public land uses of the surface estate: Under the Federal Land Policy and Management Act (FLPMA) and pursuant to federal land use plans, much of onshore leased federal acreage remains open to “multiple uses.” This compatibility helps maximize revenue to taxpayers and local governments from oil and gas leases and other nearby federal lands activities, such as grazing.
    • More time and effort is required to develop federal oil and gas leases: More time and capital investment is needed to drill on federal land, compared to fee land, given the multiple layers of National Environmental Policy Act (NEPA) analysis throughout the development process and the complexity of layered federal and state regulation and permitting. Any potential changes to the federal oil and gas program or royalty rates should recognize the increased regulatory burden for companies who develop on federal lands versus nonfederal lands, as well as the significant differences between these systems.
    • The evaluation and development process takes time and is often susceptible to delays beyond the lessee’s control:  Before federal acreage is leased and companies can actively explore for or develop oil and natural gas on federal lands, the federal government undergoes complex, multi-step processes to ensure environmental protections are in place, the public is consulted, and appropriate leasing stipulations are applied.  The Bureau of Land Management (BLM) cannot approve an Application to Drill (APD) until the operator meets the requirements of certain laws and regulations, including NEPA, the National Historic Preservation Act (NHPA), and the Endangered Species Act (ESA), which are each separate processes that can involve lengthy reviews.
    • Federal lands development can continue to help the U.S. lead on climate solutions: According to 2018 study by the U.S. Geological Survey (USGS), the extraction of oil and natural gas from federal lands accounts for just 0.6 percent of total U.S. greenhouse gases (GHGs), while providing the American taxpayer, states, and local communities with billions in annual revenue.  The same study showed that emissions of CO2 and methane from federal fossil fuel development have declined 6.1 percent and 10.5 percent respectively since 2005.
    • State regulations expertise should be consulted and considered: State rules and regulations are oftentimes structured to address the specific hydrology, geology, production volumes, and unique features of the state. For example, addressing the challenge of orphan wells, states, through organizations like the Interstate Oil and Gas Compact Commission (IOGCC), have gathered decades of expertise about addressing the challenge and the sensitivities that should be considered.  In particular, these states have expressed concerns to federal regulators to caution against situations where regulations themselves are driving companies out of business and exacerbating the problem.

AXPC’s full comments and analysis can be found here.

About the American Exploration and Production Council:
AXPC is a national trade association representing the largest independent oil and natural gas exploration and production companies in the United States. We lead the world in the cleanest and safest onshore production of oil and gas, while supporting millions of Americans in high-paying jobs and investing a wealth of resources in our communities. Learn more at


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