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Surveyors urge board to review proposed NAC change that would remove well location plat requirement
Summary
A representative of the Nevada Association of Land Surveyors urged the State Board to review and consider commenting on proposed changes to NAC Chapter 522 (LCB File No. R052-25) that would eliminate the requirement for a licensed land surveyor-prepared location plat for oil and gas wells. Board members and staff discussed Form 2 and the possible need to retain surveyor involvement.
A representative of the Nevada Association of Land Surveyors (NALS) urged the State Board of Professional Engineers and Land Surveyors on April 9 to review proposed updates by the Nevada Division of Minerals to NAC Chapter 522 (LCB File No. R052-25) that would remove the requirement for a licensed land surveyor to prepare a "location plat" for oil and gas well permit applications.
Robert Carrington, speaking for NALS, said the association believes "oil and gas wells fall under 'fixed works' and, therefore, should be located in accordance with NRS 625.040 which is the practice of land surveying." Carrington urged the Board to review the Division of Minerals' proposed rule changes and consider making formal comment; he said he plans to attend the Division's next hearing to oppose the revisions.
Executive Director Mark Fakler summarized the proposal and said he had discussed it with Garrett Wake, Deputy Administrator for the Division of Minerals, who indicated the change was intended "to reduce barriers by eliminating items that are not reviewed in the application process" and that there was consideration of requiring a licensed surveyor to locate the well after it is installed. Fakler noted that the associated Form 2 in the meeting materials, as currently drafted, prescribes information that only a licensed land surveyor could provide and would need adjustment if the regulatory language were stricken as proposed.
Board members raised similar concerns. Vice-chair Matt Gingerich and Greg DeSart observed that, as drafted, Form 2 would still effectively require professional land surveying input unless it is rewritten. Members compared the proposal to existing practice for water wells and Water Rights Surveyors and said that if a Water Rights Surveyor or other professional lacked the necessary expertise, consultation with a licensed land surveyor should occur.
An email from board member Michael Kidd, read into the record, stated he would not support the proposed changes in their current form because the infrastructure involved is high-value, well locations should be tied to the Public Land Survey System section or quarter corners, and keeping locations within a 40-acre legal subdivision is not overly burdensome. Kidd noted he would support streamlining submittals electronically but opposed the substantive removal of surveying requirements as drafted.
Executive Director Fakler asked the board how it preferred to present a formal position; Vice-chair Gingerich offered to articulate a motion the Board could consider (motion 26-29). No public comment followed and the meeting adjourned. The transcript does not record a formal board vote or a finalized Board position on the NAC changes; the issue remains open for potential Board comment.
