IPAA and AXPC Joint Comments to the U.S. Army Corps of Engineers on its Proposal to Reissue and Modify Nationwide Permits

IPAA and AXPC Joint Comments to the U.S. Army Corps of Engineers on its Proposal to Reissue and Modify Nationwide Permits

The American Exploration & Production Council (AXPC) and the Independent Petroleum Association of America (IPAA) are pleased to submit comment to the U.S. Army Corps of Engineers (USACE) on its Proposal to Reissue and Modify Nationwide Permits published in the federal register on June 1, 2016 (Volume 81, Number 105). While AXPC and IPAA jointly requested a comment extension deadline of 60-days, in a June 13, 2016 letter to USACE, AXPC understands USACE’s refusal to grant such a request in an effort to ensure adequate time for publishing the 2017 Nationwide Permits (NWP) prior to the expiration of the 2012 NWPs. Thus, having only a 60-day comment deadline has caused AXPC and IPAA to focus only on some of the principal topics that USACE is specifically seeking for comment and submits the following response.