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Comments to ONRR on Its New Proposal to Rescind Trump-Era Valuation Rule Repeal

In June 2021, the Department of the Interior’s Office of Natural Resource Revenue's (ONRR) proposed a rule rescinding a Trump-era repeal of the Valuation Rule. This rule sought to ensure that states and the federal government receive the full value of royalties due under the law for oil, gas, and coal extracted from public land. We submitted comments supporting ONRR’s proposal to fully rescind the 2020 Rule and encourage ONRR to further elaborate upon its reasons for fully withdrawing the 2020 Rule, in contrast to other alternatives. We lay out several key provisions in the 2020 Rule where ONRR can expand upon its justification for rescinding.

This comment letter follows a long line of advocacy that we've made opposing the Trump-era rule and supporting the valuation processes that it rescinded.