Extension of Applications of Permit to Drill (APDs)
Lease suspension
Applications for royalty relief
Notably, the March Memo specifically states that the above list is not exhaustive. And, to the extent approval is discretionary (i.e., extensions of APDs), we suspect an oil and gas lessee or operator will have difficultly receiving approval for those above-listed actions.
Although the March Memo is not addressed to the Bureau of Indian Affairs (BIA), the Bureau of Land Management (BLM) serves as a technical advisor to the BIA and is required to approve certain actions that impact Indian tribal and individual trust and restricted lands. The March Memo fails to make this distinction, thus raising the question whether the March Memo also excludes actions taken with respect to Indian tribal and individual trust and restricted lands.