Letters & Comments

Letters and Comments Nov 7, 2017

A diverse group of a dozen energy industry associations representing oil, natural gas, wind, solar, efficiency, and other energy technologies submitted reply comments to the Federal Energy Regulatory Commission (FERC) continuing their opposition to the Department of Energy’s (DOE) proposed rulemaking on grid resiliency pricing, in the next step in this FERC proceeding.

Letters and Comments Nov 6, 2017

To Whom It May Concern: Western Energy Alliance and the Independent Petroleum Association of America (IPAA) appreciate the opportunity to provide comment on the Bureau of Land Management’s (BLM) proposed stay of effectiveness of certain provisions of the Methane and Waste Prevention rule, or 2016 rule. We believe that the original rule as promulgated exceeded BLM’s authority under the Mineral Leasing Act (MLA) and that the decision to postpone compliance dates while BLM re-evaluates the rule is prudent. Given the lengthy rulemaking process that will be needed to revise the final rule, we believe BLM should stay compliance dates for two years, rather than the proposed one year. Notably, the 2016 rule took more than two years to develop and finalize.

Letters and Comments Nov 6, 2017

Chairman Bishop and Ranking Member Grijalva, As trade associations representing companies who produce the energy needed to fuel our cars and heat our homes, we support H.R. 4239, the SECURE American Energy Act, which seeks to achieve and maintain our domestic energy dominance by harnessing more onshore and offshore energy production here in the U.S.

Letters and Comments Oct 23, 2017

A broad coalition of 12 energy industry associations representing oil, natural gas, wind, solar, efficiency, and other energy technologies submitted joint comments to the Federal Energy Regulatory Commission (FERC) in response to the Department of Energy’s (DOE) proposed rulemaking on grid reliability and resiliency pricing. In the joint comments, the coalition urged FERC not to adopt DOE’s proposed rule to provide out-of-market financial support to uneconomic coal and nuclear power plants in the wholesale electricity markets overseen by FERC.

Letters and Comments Oct 23, 2017

Pursuant to the October 2, 2017, Notice Inviting Comment, issued by the Federal Energy Regulatory Commission (FERC or “the Commission”) in the above-referenced docket, the Independent Petroleum Association of America and the following organizations (collectively, “Independent Producers”) hereby respectfully submit the following comments on the Notice of Proposed Rulemaking in this docket. The Independent Producers urge the Commission to reject the recommendations as set forth by the Secretary of Energy in its September 28, 2017, proposal of a rule for final action by the Commission.

Letters and Comments Oct 5, 2017

Pursuant to Rule 212 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission, 18 C.F.R. § 385.212 (2016), and section 403(b) of the Department of Energy Organization Act, 42 U.S.C. § 7173, the Independent Petroleum Association of America and the signed independent producers hereby respectfully submit this motion for extension of time for filing comments on the Notice of Proposed Rulemaking in this docket. The Independent Producers request at a minimum the 90-day initial comment period and 45-day reply comment period suggested by the Energy Industry Associations.

Letters and Comments Oct 2, 2017

Petitioners Western Energy Alliance and the Independent Petroleum Association of America respectfully request that the Court invalidate and remand the Bureau of Land Management’s rule related to the reduction of venting and flaring from oil and gas production on federal and Indian leases, Waste Prevention, Production Subject to Royalties, and Resource Conservation, 81 Fed. Reg. 83,008 (Nov. 18, 2016). The Rule exceeds BLM’s statutory authority, is inconsistent with such statutory authority, and is arbitrary, capricious, and an abuse of discretion.

Letters and Comments Sep 28, 2017

To the Members of the United States Congress: We urge Congress to expeditiously pass a budget resolution with reconciliation instructions so that the promise of tax reform can be made a reality. It has been 31 years since Congress last reformed the tax code. Since then, the code has become an anchor weighing down the economy, job creation, and wage growth for American families.

Letters and Comments Sep 27, 2017

Dear Secretary Zinke: The Independent Petroleum Association of America (IPAA) and the American Exploration and Production Council (AXPC) appreciate the opportunity to submit comments regarding ways the Department of the Interior can improve management of federal lands and reform the regulatory process utilized by the agency. The comments contained in this document specifically address regulatory reform at the Bureau of Land Management (BLM). We welcome the Trump Administration’s efforts to make American energy dominance a cornerstone of Administration policy. However, the current regulatory process at the BLM hampers that important goal.

Letters and Comments Sep 25, 2017

Dear Ms. MacGregor and Mr. Nedd: On July 25, 2017, the Bureau of Land Management (BLM) published a proposed rule that would rescind a final rule BLM issued in March 2015. The “2015 Rule” was designed to regulate hydraulic fracturing on federal and Indian lands. This submission constitutes comments on the July 2017 proposal from the Independent Petroleum Association of America (IPAA) and the Western Energy Alliance (collectively, the Associations). The Associations collectively represent thousands of independent oil and natural gas explorers and producers, as well as the service and supply industries that support their efforts. It is the members of these groups that the proposed rescission will most significantly affect. Independent producers drill about ninety-five percent of American oil and natural gas wells, produce about fifty-four percent of American oil, and more than eighty-five percent of American natural gas. From the beginning, the Associations have actively engaged to assist BLM’s rulemaking efforts related to hydraulic fracturing.

IPAA is the industry's strongest presence in the nation's capital and these are important times. The entire oil and gas industry remains under fire from anti-development groups; but with these challenges arise unique opportunities that IPAA is seizing for our members.