Comments On Regulations

Federal rulemaking is based on the comments it receives on its proposed regulations. IPAA regularly submits comments on significant regulations to assure that its position is included in the analysis of the proposed regulation. This section provides recent comments on rules and regulations.

Economic Issues

pdf 2008-07 IPAALetterOnHR6604 (pdf) 64.41 kB
pdf 2008-02-19-OilandGasReservesDisclosureRequirements (pdf) 56.62 kB
doc 2006-10 Dear Secretary Bodman (doc) 127.5 kB
pdf 2006-01 Comments Natural Gas Supply (pdf) 240.03 kB

 

Federal Resources

pdf IPAATaxpayersGuidetoDeepwaterRoyaltyRelief (pdf) 2.4 MB
doc ActionAlertLetter5YearPlan (doc) 28.5 kB
pdf 2005-10 Final Scoping Notice (pdf) 227.48 kB

 

FERC and Pipeline Safety

pdf 2007_IPAA_Comments_RM07-9 (pdf) 95.13 kB
doc 2006-11 Pipeline Safety (doc) 46.5 kB
pdf 2006-01 Gas Gathering Pipeline Safety (pdf) 173.88 kB
pdf 2005-11 PL05-10 comments (pdf) 104.06 kB

 

SPCC

pdf 2006-02-10-IPAA-SPCC-PlanComments (pdf) 153.93 kB

 

Stormwater Construction Management

pdf 2006-02 Attachment4 (pdf) 9.21 MB
pdf 2006-02 Attachment3 (pdf) 222.25 kB
pdf 2006-02 Attachment2 (pdf) 277.63 kB
pdf 2006-02 Attachment1 (pdf) 55.2 kB
pdf 2005-05 IPAA Comments at EPA Stormwater Management Mtg (pdf) 119.76 kB
pdf 2005-05 Appendix3-DOEAnalysis (pdf) 110.18 kB
pdf 2005-05 Appendix3 DOE Analysis-Attachment1 (pdf) 37.41 kB
pdf 2005-05 Appendix2-RAPPS (pdf) 3.54 MB
pdf 2005-05 Appendix1-CommonPlanIssues (pdf) 114.4 kB
pdf 2005-05 Appendix1 Attachment1-A (pdf) 119.76 kB
pdf 2004-04 RAPPS (pdf) 3.54 MB

 

IPAA Comments on House Anti-Speculation Bill IPAA weighs in on U.S. House of Representatives anti-speculation bill, H.R. 6604.
SEC Reserves Disclosure Comments IPAA’s comments on the Security and Exchange Commission concept release regarding possible changes to oil and natural gas reserves disclosure requirements.
IPAA Comments on Pinedale Anticline Oil and Gas Exploration and Development Project IPAA submitted comments to the Bureau of Land Management (BLM) supporting year-round drilling and completion operations in the Pinedale Anticline Project Area.
IPAA Files Comments on EPA Stormwater Construction Regulatory Proposal These materials were submitted to the Environmental Protection Agency public meeting on stormwater management during oil and gas construction activities. They were submitted by IPAA on its behalf and for a number of national, regional, and state associations. They discuss the IPAA position on EPA’s approach to regulating stormwater during oil and gas construction activities, the current management practices, and the consequences of applying EPA’s Construction General Permit.
SPCC Plan Comments IPAA comments on potential future actions by EPA on Spill Prevention, Control and Countermeasure (SPCC) regulations.
IPAA Submits Comments to EPA Public Meeting on Stormwater These materials were submitted to the Environmental Protection Agency public meeting on stormwater management during oil and gas construction activities. They were submitted by IPAA on its behalf and for a number of national, regional, and state associations. They discuss the IPAA position on EPA’s approach to regulating stormwater during oil and gas construction activities, the current management practices, and the consequences of applying EPA’s Construction General Permit.
Stormwater Construction Permit Requirements These comments were submitted to the Environmental Protection Agency (EPA) supporting its proposal to delay the effectiveness of new stormwater related construction permit requirements for until March 2005 for Phase II (one to five acre sized) oil and gas exploration and production facilities. The comments also address suspending these permit requirements on larger facilities and other problems with the new proposed permit. The comments were filed by IPAA on its behalf and numerous federal, regional, and state trade associations.
Spill Prevention, Control, and Countermeasure (SPCC) Plan Comments These comments were submitted to the Environmental Protection Agency (EPA) supporting its proposal to extend the compliance dates for new Spill Prevention, Control, and Countermeasure (SPCC) Plan regulations. Additionally, they identify a number of specific issues that need to be addressed during the extension period. The comments were filed by IPAA on its behalf and numerous federal, regional, and state trade associations.
Suspension of Operations for Exploration Under Salt Sheets Written comments submitted by Chuck Davidson, Chairman, IPAA’s Offshore Committee
IPAA & National Stripper Well Hydraulic Fracturing Testimony Written comments submitted for draft EPA design on the environmental risks of hydraulic fracturing.