Commission pauses final action on NAC 5.22 after land surveyor raises accuracy and safety concerns
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Summary
After public comment from the Nevada Association of Land Surveyors warning that removing a licensed-surveyor plat requirement could jeopardize accurate well location and water-right mapping, the commission directed staff to work with the proponent and return with revised language and a scope/milestones before further action.
Commissioners held a public hearing Feb. 19 on proposed changes to NAC chapter 5.22 (LCB file R052-25) that would update references to API standards, allow GPS coordinates in lieu of a plat prepared by a Nevada-licensed land surveyor for some well-location submissions, extend cuttings-submittal deadlines to 90 days, and permit electronic filing. The package was part of the Division of Minerals’ review of regulations under Executive Order 2023-003 to remove outdated requirements.
At the hearing, Robert Carrington, a licensed professional land surveyor representing the Nevada Association of Land Surveyors, urged the commission to retain requirements for licensed surveyors to prepare plat maps. Carrington said Nevada’s land survey history, the Public Land Survey System and water-rights mapping frequently require specialized survey expertise and that removing the licensed-surveyor plat requirement risks inaccuracies that could affect water-rights applications and public safety.
Division staff told commissioners they would work with Carrington and other stakeholders to develop a certification or verification approach for GPS-submitted coordinate data that would preserve the intent to streamline regulations while assuring accuracy. The office of the Attorney General (Alexa Ravencroft) confirmed the process for making revisions and whether another hearing would be needed depends on how substantive any changes are.
Commissioners agreed not to adopt the proposed changes at this meeting and asked staff to return with revised language and a scope of work addressing certification and accuracy, and to consider another public hearing if changes are significant. The decision was unanimous.

