Obtaining approval for a Saltwater Disposal (SWD) or Pressure Maintenance (PM) Well permit from the New Mexico Oil and Gas Conservation Division (OCD) is growing increasingly more challenging with each passing day. With persistent low staffing levels at OCD, large numbers of permit applications in process, and the rapidly changing induced seismicity guidance, your permit application can easily be set aside indefinitely because of one error or omission in your application. When checking on the status of your permit, if you are getting a persistent “In Administrative Review” response and your permit approval decision is taking longer than expected, you may be one of those unlucky permit applications that have been set aside. Often, no notice or further information is given to the applicant when this occurs.
Based on the volume of SWD and PM permits that ALL has successfully obtained approval from OCD, combined with ongoing and regular contact with key staff discussing ongoing SWD projects, ALL has become keenly aware of the errors and oversights that can be the culprit of your permit approval to stall in administrative review. ALL has reviewed many submitted permit applications that have been set aside and, when deficiencies are identified, has made the necessary adjustments and corrections that were the culprit for your application being set aside. Once this is completed, ALL can push to obtain permit approval where it is not uncommon to obtain approval or a meaningful status update toward approval within a couple of months.