American Oil and Gas Reporter - August 2020 - 75

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GPA 2261-13, GC verification records,
and GC component analysis.
Overall, Subparts 3173, 3174, and
3175 have a direct impact on measurement
SOPs for both producers and midstream
companies operating on BLM royalty
lands. While producers may not be the
royalty point in the value chain, they ultimately will be accountable for meeting
the requirements of both 3174 and 3175.
Those requirements include maintaining records of oil and gas production in
accordance with the BLM Records Retention Policy. Measurement SOPs should
be updated to ensure a company's processes generate accurate and reliable records
that will satisfy a BLM review.
Staying Proactive
Companies that operate on federal and
Indian land need to update measurement
SOPs to meet the industry standards and
best practices BLM references in the
final rule. Giving the field measurement
team clear and concise procedures and
recordkeeping for BLM royalty points is
essential. The measurement SOPs should
also satisfy SOX requirements.
By taking a proactive approach to examining how production measurement

fits within BLM requirements, oil and
gas producers can make wiser decisions
about investments in measurement equipment. Once those decisions are made,
the producer's team can communicate
the procedures that support procuring,
installing and maintaining the equipment
in alignment with the measurement SOPs.
This proactive approach also will help
prepare the company to adapt to future
changes to the BLM rule. As expressed
during the API Fall Meeting in October
2019, the BLM is reviewing challenges
that have arisen since the 2016 rule
became effective in 2017.
This includes the possibility of updating
or modifying references to industry standards to reflect industry changes since
the rule's implementation. As with any
federal rule-making process, there is no
guarantee what changes will occur, when
they will become effective, or even whether
they eventually will be implemented.
But for companies operating on federal
lands, the goal remains the same: to
ensure measurement SOPs conform to
BLM Onshore Order requirements. This
means adopting clear policies and procedures that are backed by industry standards
to support field measurement and intelli-

gently deploying new technology to optimize processes.
❒
Editor's Note:
Seeking to "remove or revise requirements . . . found to be unnecessarily burdensome, unclear, inconsistent or otherwise
problematic," BLM on July 29 proposed
changes to 81 FR 81365, 81 FR 81462
and 81 FR 81516 pertaining to onshore oil
and gas operations on federal and Indian
oil and gas leases, modifying certain provisions of 43 CFR Subparts 3170, 3173,
3174 and 3175. See story, page 82.
RUSSEL TREAT is the president
of Gas Certification Institute (GCI),
which provides measurement SOPs for
production, exploration, pipeline and
midstream companies. He also serves
as president and chief executive officer
of EnerSys Corp., which develops software for midstream companies, and
hosts the Pipeliners Podcast, where
he regularly discusses measurement
topics with industry experts. Treat
holds a B.S. in civil engineering from
Texas A&M and an M.B.A. from Boston
University.

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