Rosario Hecht Domínguez (Doriott)

Office of Natural Resources Revenue (ONRR)

• Advises federal and Indian lessees on royalty reporting, valuation, allowances, self-audits, and ONRR compliance.
• Routinely resolves data mining reviews, compliance reviews, audits, and enforcement inquiries concerning federal and Indian oil and gas sales, volumes, valuation, and allowances.
• Obtained rare closure, without civil penalties, of ONRR enforcement cases alleging offshore operator knowingly or willfully submitted inaccurate royalty reports or maintained inaccurate records.
• Obtained rare ONRR withdrawal of an Order to Report and Pay alleging improper transportation and processing allowances.
• Secured an uncommon settlement of an appeal from an ONRR Order to Perform Restructured Accounting and Pay, requiring no additional reporting or submissions and releasing all open federal and Indian royalty claims and obligations for a dissolving operator.
• Counseled operators on federal royalty valuation and allowances in data-center and Bitcoin-mining arrangements.

Office of Inspector General (OIG) & Department of Justice (DOJ)

• Successfully resolved and settled various False Claims Act investigations conducted by DOJ, including matters alleging underpaid federal royalties and overclaimed allowances.
• Successfully resolved and settled various investigations conducted by the Department of the Interior's OIG, including matters alleging unreported sales and transportation.
• Counseled New Mexico operator in connection with an asset acquisition on potential liability arising from unresolved federal royalty audits, civil penalty matters, and a False Claims Act investigation conducted by DOJ.

Interior Board of Land Appeals (IBLA)

• Obtained rare IBLA full vacatur, without remand, of ONRR Order to Perform Restructured Accounting and Pay demanding more than $20 million in federal offshore royalties and challenging transportation allowances. 200 IBLA 66 (2025).
• Obtained several IBLA opinions finding evidence ONRR may have acted in bad faith in its decision-making and record compilation when denying royalty refund claims. IBLA-2020-398, IBLA-2021-176, IBLA-2022-69 (2023).
• Obtained an IBLA opinion prompting codification of the rule that filing an appeal divests the issuing bureau or office of jurisdiction to modify, rescind, or supersede its decision. 90 Fed. Reg. 2332, 2364 (Jan. 10, 2025) (citing 196 IBLA 250, 253 (2021)).

Federal Courts

• Successfully appealed and vacated an ONRR Director Decision denying offshore transportation allowances. Obtained a district court decision vacating modified royalty demands as arbitrary and capricious and remanding for further consideration of ONRR's non-compliance with Generally Accepted Government Auditing Standards.
• In a case of first impression, successfully appealed and vacated an ONRR Director Decision denying transportation allowances. Obtained a district court decision vacating the unlawful expansion and modification of claims asserted in an Order to Report and Pay. 421 F. Supp. 3d 1213 (D. Wyo. 2019).
• Successfully appealed and set aside an ONRR Director Decision valuing unprocessed gas using higher residue gas pricing. Obtained a district court decision holding the valuation of unprocessed gas sold at the wellhead under percentage-of-proceed contracts as processed gas was arbitrary, capricious, plainly erroneous, and inconsistent with the governing regulation. 410 F. Supp. 3d 30 (D.D.C. 2019).
• In a case of first impression, successfully appealed a district court decision dismissing a federal royalty suit as time-barred. Obtained reversal clarifying the application of the 180-day and 33-month periods for judicial review under 30 U.S.C. § 1724. 846 F.3d 1232 (D.C. Cir. 2017).

Bureau of Indian Affairs (BIA) & Tribal Authorities

• Advises Indian lessees on lease administration, bonding and surety requirements, letters of credit, assignments, royalty payment, and related compliance matters.
• Successfully resolved and settled numerous obligations involving Indian leases and Kiowa Tribe severance taxes in a corporate dissolution context.
• Successfully resolved Navajo Nation severance-tax audit with no penalties assessed.

Marine Minerals Administration (MMA)

• Advises Outer Continental Shelf operators on lease administration and assignments, decommissioning obligations, financial assurance, and escrow and other credit-support arrangements in matters involving BOEM and BSEE.
• Obtained rare Treasury waiver and referral of federal royalty debt back to ONRR, resulting in immediate savings of more than $635,000, and secured BOEM approval of related offshore lease assignments.

Bureau of Land Management (BLM)

• Advises federal lessees on communitization and unit obligations, lease administration, production and revenue allocation, and related regulatory requirements.
• Successfully appealed multiple Incidents of Noncompliance issued by a BLM inspector concerning metering requirements and resolved the appeals without penalties.
• Secured BLM acceptance of a corrected federal royalty allocation factor for the light-oil participating area of a Wyoming unit, effective as of the client's approval as successor operator.
• Counseled a North Dakota operator on revenue obligations under a federal communitization agreement involving unleased federal land.
• Counseled Wyoming operator on allocation methodologies under a unit operating agreement involving a consolidated and expanded participating area and consent and non-consent interests.
• Advised operator on ownership, cost-allocation, and liability issues involving a pre-existing saltwater disposal facility under governing facility and joint operating agreements.

State Agencies, Class Actions, & Private Royalty Matters

• Successfully resolved various audits conducted by the Colorado Department of Revenue, New Mexico Taxation and Revenue Department, and Wyoming Department of Audit, including obtaining rare final audit reports identifying no issues after review of clients' federal gas royalties and unbundling of arm's-length costs.
• Successfully prevented discovery of a non-party natural gas processor's confidential information in multiple class actions.
• Successfully resolved an audit of a national energy producer's private royalty payments and deductions on Denver Basin production.

Department of Commerce / National Oceanic and Atmospheric Administration (NOAA) & California Coastal Commission

• Advised Outer Continental Shelf energy company in federal consistency proceedings before the California Coastal Commission and in appeal to the Secretary of Commerce, administered by NOAA's Office of General Counsel, from Commission objections to consistency certifications under the Coastal Zone Management Act.

Rulemaking & Policy

• Advises clients on proposed federal rulemakings, new regulations, and agency policies affecting onshore, offshore, and Tribal energy development, and helps clients develop comments, administrative records, and implementation strategies.
• Drafted H.R. 10005, "Expedited Appeals Review Act" (Rep. Hageman, 2024), to create a process for expedited review of certain Department of the Interior appeals.

Pro Bono

• In 2013, obtained the nation's first ruling holding transgender students must be allowed to use restrooms matching their gender identities. Successfully appealed a Colorado school district decision to the Colorado Civil Rights Division under the Colorado Anti-Discrimination Act, working with the Transgender Legal Defense & Education Fund.