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BLM proposes new gas measurement requirements

September 07, 2007
The U.S. Bureau of Land Management (BLM) proposed new requirements for electronic flow computers (EFC) used on differential type flow meters for gas measurement on all federal and Indian leases located in Oklahoma, Texas, Kansas, and New Mexico.

The proposed requirements would apply to all EFCs (existing and new) under the BLM’s jurisdiction. The purpose of BLM’s proposed requirements is to allow BLM personnel to verify gas volumes in the field without additional equipment, information or the aid of company officials. The BLM proposed similar requirements in 2005. The BLM’s proposed 2007 requirements eliminates some onerous reporting and record keeping requirements, and provides a more reasonable implementation schedule. However, the proposed requirements are still problematic for industry.

The proposed requirements arbitrarily selects, waives or is more stringent than current industry standards developed by organizations such as the American Petroleum Institute, the American Gas Association, and the Gas Processors Association. It is not clear how the current rules and industry standards has failed to provide accurate gas volume data or has prevented BLM from meeting its legally mandated requirements to verify gas volumes from wells under its jurisdiction. In addition, it is not clear how the proposed requirements will improve the accuracy of the gas volume data collected by the BLM.

In comments submitted to BLM, OIPA noted that changes will have to be made to company’s operating procedures and processes, updates will have to be made to existing EFC software, and in some cases, new EFC equipment may be needed to comply with the proposed requirements – all of which will unnecessarily increase the cost of doing business on federal and Indian leases. OIPA urged the BLM to carefully weigh the costs and benefits, and consider whether the proposed changes are warranted as it will change technically sound procedures that have been shown to be effective in providing accurate gas volume data.

It is not known when the BLM will finalize the proposed EFC requirements. However, OIPA encouraged the BLM to continue to work on the proposed requirements in coordination with industry to jointly develop reasonable requirements regarding EFC that would provide uniformity and avoid inconsistent and confusing regulatory requirements with well established industry standards.
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