Limits on federal land

March 10, 2003
After waiting 5 years for the Bureau of Indian Affairs (BIA) to approve a Bureau of Land Management (BLM) request that a parcel be made available for leasing and after being unable to have land in the Farmington district of the BLM put up for leasing for the past 21/2 years, I was surprised by the title of your article (OGJ, Jan. 27, 2003, p. 30)

Limits on federal land

After waiting 5 years for the Bureau of Indian Affairs (BIA) to approve a Bureau of Land Management (BLM) request that a parcel be made available for leasing and after being unable to have land in the Farmington district of the BLM put up for leasing for the past 21/2 years, I was surprised by the title of your article (OGJ, Jan. 27, 2003, p. 30) "Producers face few limits on some federal lands." The reason for my surprise is that certainly is not the case in the San Juan basin, where operators face a myriad of impediments.

You, the BLM, and the Congress need to know that the USGS's recent estimate of undiscovered resources in the San Juan basin are grossly underestimated. As a result, those estimates cannot be relied upon, or used to plan for development of resources in the Four Corners area.

For example, the US Geological Survey's new estimate of the undiscovered oil in the Mancos-Menefee Total Petroleum System is only 16.8 million bbl of oil. At the same time that unbelievably low USGS estimate came out, Oil & Gas Journal was publishing an article, coauthored by a senior project manager for the Department of Energy, which stated that 189 million bbl remains to be discovered and produced from the play (OGJ, Dec. 2, 2002, p. 42).

My company has focused on the San Juan basin for the past 25 years, and I have worked in the San Juan basin, as a petroleum engineer, for over 35 years. As a result, it is obvious to me that such a reduction cannot be reconciled. It's simply wrong, and that reduction together with other errors and omissions can have very serious consequences.

Such an unrealistically low estimate raises the question of whether any further leasing may be justified, when in reality additional leasing is unquestionably justified. In addition, issuance of such a low estimate makes it difficult for the Department of Interior to employ adequate personnel in the BLM and the BIA to process expressions of interest (EIOs), to clear land for leasing, to conduct environmental impact studies (EISs) needed to open frontier areas, like Catron county, New Mexico, to make land available for leasing, and to process applications for permits to drill (APDs).

From the 5 years that it recently took to lease land that contains proved, undeveloped oil reserves, it is obvious that there are limitations on federal lands—at least in the San Juan basin. Those limitations have come from assumptions made by the BLM in staffing its leasing and permit processing sections. Those stated assumptions were:

1. That there will be no increase in production from the San Juan basin, even though the state of New Mexico had approved closer spacing and the New Mexico Bureau of Mines estimated that 15,000 additional wells will be needed to recover the additional gas reserves from infill developments.

2. That there is no more oil to be discovered in the San Juan basin, not 16.8 million bbl, or 189 million bbl, but no oil to be discovered and produced.

As a result, the staffs for the Farmington and Albuquerque district of the BLM have shrunk through attrition and one person in the BIA handles EOIs and clearance of parcels for leasing. Consequently, there is a bottleneck impeding development of oil and gas resources on federal land in New Mexico, and probably elsewhere.

John B. Somers II, President
High Plains Petroleum
Boulder, Colo.