IPAA and API Joint Comments to the U.S. Fish and Wildlife Service on its Advance Notice of Proposed Rulemaking on Non-Federal Oil and Gas Development Within the National Wildlife Refuge System

IPAA and API Joint Comments to the U.S. Fish and Wildlife Service on its Advance Notice of Proposed Rulemaking on Non-Federal Oil and Gas Development Within the National Wildlife Refuge System

These comments are filed on behalf of the Independent Petroleum Association of America (IPAA) and the American Petroleum Institute (API). Together these organizations represent the thousands of independent oil and natural gas explorers and producers, as well as the service and supply industries that support their efforts. Any additional regulations will most significantly affect the members of these organizations. API represents over 600 companies involved in all aspects of the oil and natural gas industry, including producers, suppliers, pipeline operators, marine transporters, and service and supply companies. The independent producers IPAA represents drill about ninety-five percent of American oil and natural gas wells, produce about fifty-six percent of American oil, and produce more than eighty-five percent of American natural gas. We appreciate the opportunity to comment on the advance notice of proposed rulemaking and notice of intent to prepare an environmental impact statement.

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