Industry Trade Associations Joint Comments to the Office of Management and Budget on the Bureau of Land Management’s Proposed Rule on Waste Prevention, Production Subject to Royalties, and Resource Conservation

Industry Trade Associations Joint Comments to the Office of Management and Budget on the Bureau of Land Management’s Proposed Rule on Waste Prevention, Production Subject to Royalties, and Resource Conservation

The Independent Petroleum Association of America (IPAA), the Western Energy Alliance (Alliance), and the American Exploration and Production Council (AXPC) (collectively “the Associations”) appreciate the opportunity to comment to the Office of Management and Budget (OMB) in relation to the information collection requirements that would be imposed by the Bureau of Land Management’s (BLM) proposed Waste Prevention, Production Subject to Royalties, and Resource Conservation Rule. The proposed information collection requirements would result, contrary to the requirements of the Paperwork Reduction Act (44 USC §§ 3501-3521), in unnecessary new costs and burdens, without compensating benefits, to domestic oil and natural gas producers, the vast majority of which are small, independent businesses.

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