Letters & Comments

Letters and Comments Jan 31, 2018

Pursuant to Rules 207(a)(4) and (a)(5) of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. §§ 385.207(a)(4) and (a)(5) (2017), the undersigned Petitioners, representing a broad-based coalition of the natural gas industry that are dependent upon services provided by interstate natural gas pipeline and storage companies, hereby petition the Commission to take immediate action under Sections 5(a), 10(a), and 14(a) and (c) of the Natural Gas Act (NGA) to initiate show cause proceedings against all interstate natural gas pipeline and storage companies, excluding (1) Section 311 pipelines (which are otherwise required to file updated rate justifications on an ongoing basis); and (2) natural gas pipeline and storage companies that are obligated to file a Section 4 rate case in 2018. Petitioners request the Commission to require all other regulated interstate natural gas pipeline and storage entities (unless barred by a settlement moratorium) to demonstrate that their existing jurisdictional rates continue to be just and reasonable following the passage of the Tax Cuts and Jobs Act of 2017 (“Tax Act”).

Letters and Comments Jan 22, 2018

Dear Mr. Sheehan: With this letter, API, IPAA, AXPC, and IAGC (together “the Associations”) are pleased to submit these comments in response to the U.S. Fish and Wildlife Service’s (FWS, or “the Service”) Candidate Conservation Agreements with Assurances (CCAAs) Policy, which the Services announced that they were intending to review and possibly to revise in a notice pub-lished at 82 Fed. Reg. 55,625 (November 22, 2017). The Services finalized a revision of the CCAA policy on December 27, 2016 (81 FR 95164). The Associations request the FWS revise the existing policy as described below.

Letters and Comments Jan 22, 2018

Dear Mr. Sheehan: With this letter, API, IPAA, AXPC, and IAGC (together “the Associations”) are pleased to submit these comments in response to the U.S. Fish and Wildlife Service’s (FWS, or “the Service”) Candidate Conservation Agreements with Assurances (CCAAs) Regulations found at 50 C.F.R. 17.22(d) and 17.32(d), which the Service announced that it was intending to review and possibly to revise in a notice published at 82 Fed. Reg. 55,550 (November 22, 2017). We request the FWS revise the existing rule as described below.

Letters and Comments Jan 5, 2018

Dear Mr. Sheehan: With this letter, API, IPAA, AXPC, IAGC, and Western Energy Alliance (together “the Associations”) are pleased to submit these comments in response to the captioned public notice, published in the Federal Register November 6, 2017, in which the U.S. Fish and Wildlife Service (FWS or the Service) requests public comment to the use of the terms “net conservation gain” and “no net loss” to describe planning goals for the Service’s Endangered Species Act (“ESA”) Compensatory Mitigation Policy. We appreciate the FWS seeking public comments on this policy. However, we have significant concerns with many as-pects of the policy as discussed below. As such, we request the FWS withdraw and revise this policy.

Letters and Comments Jan 5, 2018

Dear Mr. Sheehan: With this letter, API, IPAA, AXPC, IAGC, and Western Energy Alliance (together “the Associations”) are pleased to submit these comments in response to the captioned public notice, published in the Federal Register November 6, 2017, in which the U.S. Fish and Wildlife Service (FWS or the Service) requests public comment to portions of the Service’s Mitigation Policy. We appreciate the FWS seeking public comments on this policy. However, we have significant concerns, as discussed below. We request the FWS withdraw and revise this policy.

Letters and Comments Dec 8, 2017

Dear Administrator Pruitt: The following comments are submitted on the above-referenced proposed rule and notice of data availability (NODA) on behalf of the following national and state trade associations: the Independent Petroleum Association of America (IPAA), American Exploration & Production Council (AXPC), Domestic Energy Producers Alliance (DEPA), Eastern Kansas Oil & Gas Association (EKOGA), Illinois Oil & Gas Association (IOGA), Independent Oil and Gas Association of West Virginia, Inc. (IOGA-WV), Indiana Oil and Gas Association (INOGA), International Association of Drilling Contractors (IADC), Kansas Independent Oil & Gas Association (KIOGA), Kentucky Oil & Gas Association (KOGA), Michigan Oil and Gas Association (MOGA), National Stripper Well Association (NSWA), North Dakota Petroleum Council (NDPC), Ohio Oil and Gas Association (OOGA), Oklahoma Independent Petroleum Association (OIPA), Pennsylvania Independent Oil & Gas Association (PIOGA), Texas Alliance of Energy Producers (Texas Alliance), Texas Independent Products & Royalty Owners Association (TIPRO), and West Virginia Oil and Natural Gas Association (WVONGA) (collectively, “Independent Producers”). We respectively ask that you consider these comments.  We are here to respond to any questions or comments you may have.

Letters and Comments Dec 1, 2017

In accordance with the Federal Register notice, issued on October 2, 2017 and revised on November 3, 2017, the Independent Petroleum Association of America (IPAA) and its members, along with the Kentucky Oil & Gas Association, the Ohio Oil and Gas Association, and the Pennsylvania Independent Oil & Gas Association (collectively, Independent Producers), submit the following comments on existing rules and other agency actions that are good candidates for repeal, replacement, suspension, or modification. The Independent Producers represent the companies that drill 90 percent of the nation’s oil and natural gas wells. These companies produce 82 percent of American natural gas and 68 percent of American oil. The Independent Producers’ members represent the full range of producers, from small family‐owned businesses, to the large independent companies that are some of the largest American natural gas producers. The Independent Producers’ recommendations focus on three issues under the auspices of the Pipeline and Hazardous Materials Safety Administration (PHMSA): Sampling and testing for unrefined petroleum‐based products; Regulatory treatment of farm taps off production lines; and Proposed regulations affecting gathering lines and production facilities.

Letters and Comments Dec 1, 2017

Dear Mr. Nedd: With this letter, API and IPAA are pleased to submit its comments in response to the captioned public notice, published in the Federal Register October 11, 2017, describing the intention of the Bureau of Land Management (BLM) to consider amendments to “some, all or none of the BLM land use plans that were amended or revised in 2014 and 2015 regarding Greater Sage-Grouse (GRSG) conservation in the States of California, Colorado, Idaho, Nevada, Oregon, Wyoming, North Dakota, South Dakota, Utah and Mon-tana” (2015 GRSG Plans).

Letters and Comments Nov 28, 2017

Dear Ms. Christensen and Ms. Jensen: The Waters Advocacy Coalition (WAC) submits the attached comments in response to the U.S. Environmental Protection Agency’s and U.S. Army Corps of Engineers’ request for written recommendations regarding the definition of “Waters of the United States” under the Clean Water Act. WAC appreciates the opportunity to comment on this important issue.

Letters and Comments Nov 16, 2017

Dear Mr. Beaman: The American Exploration & Production Council (AXPC) and the Independent Petroleum Association of America (IPAA) are pleased to submit comment to the Environmental Protection Agency (EPA) on its voluntary information collection request (ICR) proposal, “Survey on Clean Water Act Hazardous Substances and Spill Impacts” published in the federal register on September 21, 2017 (Document No. 2017-20170). AXPC and IPAA member companies are currently subject to the existing spill prevention, control, and countermeasure (SPCC) regulations in addition to the many similar, supplementary state specific requirements. As such, AXPC and IPAA believe that the current regulatory environment is sufficient as it provides for adequate protection against any unplanned release of hazardous substances and submits the following response.

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.