Oct 9, 2015 IPAA and Western Energy Alliance Joint Comments to the Department of the Interior on its Proposed Revisions to Onshore Order No. 3, Site Security
Dear Director Kornze: Western Energy Alliance and the Independent Petroleum Association of America (IPAA), appreciate the opportunity to comment on the proposed changes to Bureau of Land Management (BLM) Onshore Order No. 3, which would be codified in the Code of Federal Regulations through modifications to 43 C.F.R. Part 3160 and the addition of new Part 3170. While recognizing the need to keep regulations current with modern technology and industry standards, the Associations are concerned that the proposed rule change would result in substantial changes to the way domestic onshore oil and gas operations are conducted, leading to an unwarranted increase in costs and burdens to domestic oil and natural gas producers. These costs would be incurred largely without a concomitant benefit to the federal government or the public at large and create further disincentives for oil and natural gas producers to invest in development on federal public and tribal lands. Moreover, some of these revisions would require physical changes with impacts to the environment and socio-economic impacts that have not been adequately analyzed in the Environmental Assessment for the proposed rule.