The petitioner, BP America Production Cohttp://en.wikipedia.org/wiki/BP ., holds gas leases for lands in New Mexico’s and Colorado's San Juan Basin. BP’s predecessor, Amoco Production Co., http://en.wikipedia.org/wiki/Amoco first entered into these leases nearly fifty years ago, and these leases require the payment of a royalty. For years, Amoco calculated the royalty as a percentage of the value of the gas as of the moment it was produced at the well. In 1996, MMS sent lessees a letter directing that royalties should be calculated based not on the value of the gas at the well, but on the value of the gas after it was treated to meet the quality requirements for introduction into the Nation’s mainline pipelines. Therefore, MMS in 1997 ordered payment of $32,264,570 in additional royalties (and interest) for the period from January 1989 through December 1996 to cover the difference.[2]