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Letters & Comments

Letters and Comments, Methane Mar 26, 2024

The Independent Petroleum Association of America (IPAA) submits these comments regarding the Environmental Protection Agency (EPA) proposal to implement a Waste Emissions Charge for Petroleum and Natural Gas Systems (WEC) under the Inflation Reduction Act Methane Emissions Reduction Program (Methane Tax).

In addition to the comments filed here, unless there are specific comments presented herein, IPAA endorses the comments filed by the American Petroleum Institute (API).

The Methane Tax process includes multiple features. However, a key factor in conjunction with this WEC proposal is the application of information from Subpart W. IPAA previously filed comments on the EPA proposal to modify Subpart W (EPA-HQ-OAR-2023-0234-0265). These comments are included in this submission as Appendix A.

Because the emissions calculations under Subpart W are the building blocks for calculation of the WEC, these comments will reiterate and expand on those prior comments. Then, it will address key issues in the WEC proposal.

 

 

Letters and Comments, Methane Mar 26, 2024

IPAA joined with the American Petroleum Institute (API) and 18 other associations representing all segments of the U.S. oil and natural gas industry operating across the country in calling on the U.S. Environmental Protection Agency (EPA) to revise its misguided methane fee on American energy. In comments submitted to the agency on the “waste emissions charge” proposed rulemaking, the associations argued that EPA’s proposed rule creates an incoherent regulatory regime, fails to meet the statutory requirements outlined by the Inflation Reduction Act and disincentivizes emissions reduction efforts by the industry.

In their comment letter, the associations raised significant concerns about the proposed rule’s nexus to other methane regulations underway, highlighting the Biden administration’s disharmonized approach to methane regulations. The associations urged the administration to coordinate this proposed rule with other regulations, including Subpart W and EPA’s final Methane Rule. Additionally, the associations called for more flexibility on netting requirements to incentivize greater emissions reductions, clarification to the rule’s exemptions as intended by Congress, and commonsense compliance and reporting timelines.

Letters and Comments Feb 14, 2024

“On behalf of undersigned energy associations, we urge a yes vote on H.R. 7176 Unlocking Our Domestic LNG Potential Act. …

“The Biden Administration’s recent announcement to pause new non-FT A permits for LNG export facilities could not have come at a worse time. This action threatens to stifle the progress made by the unprecedented ramp up of our domestic industry and the fundamental shift in dependence made by Europe. …

“U.S. LNG exports have received bipartisan support in the past that continues to this day. Given the national security implications of this misguided decision for both the United States and our European allies, we urge you to quickly advance legislation to remove the Department of Energy from the non-FT A permitting process to allow critical LNG infrastructure to move forward.

“Our associations strongly support the passage of H.R. 7176 Unlocking Our Domestic LNG Potential Act by Rep. August Pfluger (TX-11) which will counter this misguided decision by the Administration and put the Federal Energy Regulatory Commission in charge of all LNG export permitting in the United States…”

 

Letters and Comments, Methane Feb 9, 2024

“Dear Mr. Speaker, Leader Jeffries, Leader Schumer, and Leader McConnell:

This letter is submitted on behalf of the 26 organizations listed below. These organizations want to express serious concerns regarding the impact of the Environmental Protection Agency’s (EPA) new methane emissions regulations (Subparts OOOOb and OOOOc) and the Methane Emissions Reduction Program (Methane Tax) on oil and natural gas marginal well owners. Both actions threaten marginal wells continued operations by creating unfair, unworkable, and uneconomic regulations. These small business energy producers need assistance to find a regulatory or legislative solution to mitigate these threats. …”

The letter provides definitions and information on the impact to producers in the following areas –

  • Regulatory Applicability to Marginal Wells
  • Subparts OOOOb and OOOOc
  • The Methane Tax

“Collectively, the Subpart OOOOc regulations and the Methane Tax pose serious and direct threats to hundreds of thousands of marginal wells. These threats have not been remotely addressed in the current regulatory actions completed or pending at EPA. Congress needs to step up and step in to prevent irresponsible agency actions that would savage the nation’s marginal oil and natural gas wells.”

 

Letters and Comments, Taxes Feb 2, 2024

Dear Majority Leader Schumer and Leader McConnell,

The Natural Gas Council, on behalf of the individuals and companies who produce, transport, and deliver natural gas across the nation, urges Congress to enact H.R. 7024, the Tax Relief for American Families and Workers Act, which would extend the benefits of 100-percent bonus depreciation, enhanced interest deductibility, and immediate expensing of domestic research and development (R&D) expenses.

As a capital-intensive industry with extended project lead times, the natural gas sector benefits from provisions that allow immediate expensing or bonus depreciation. The ability to completely deduct the cost of making acquisitions of all new and used equipment reduces the average cost of capital across all business investments. By substantially lowering the cost of capital for depreciable investments for equipment to maintain, operate, and deploy our critical infrastructure systems, immediate expensing further spurs activities that might otherwise be delayed to later years. …

Infrastructure, Letters and Comments Feb 2, 2024

The Natural Gas Council, on behalf of the individuals and companies who produce, transport, and deliver natural gas across the nation, writes in support of H.R. 7023, Creating Confidence in Clean Water Permitting Act. This proposal would ensure the continued availability of the Nationwide Permit (NWP) program for the construction of new natural gas infrastructure projects and the maintenance of existing infrastructure to ensure safety and reliability. …

Letters and Comments, Uncategorized Feb 1, 2024

This Coalition letter was sent to the Members of the U.S. House of Representatives’ Committees on Small Business and of the Judiciary, supporting reform in implementation of the Regulatory Flexibility Act.

“Dear Chairmen Williams and Jordan and Ranking Members Velazquez and Nadler:

On behalf of millions of small businesses across the country, we urge legislative action to strengthen the meaningful input of small businesses in federal regulatory processes and ensure the intent of the Regulatory Flexibility Act is fulfilled. …

Unfortunately, loopholes in the RFA allow federal regulators to bypass the law’s requirements and misrepresent the costs of new mandates on small businesses because (a) transparency requirements only apply to businesses directly regulated and (b) judges may not punish agencies for ignoring small business concerns. …

At a time when we are counting on small business growth to enrich communities and bolster America’s economy, we cannot afford to bury free enterprise under red tape emanating from Washington.

We urge the Committee to prioritize legislation that strengthens and closes loopholes in the Regulatory Flexibility Act. …”

Letters and Comments, Methane, Taxes Jan 30, 2024

Dear Mr. Ragnauth,

The Independent Petroleum Association of America (IPAA) respectfully requests a 30-day extension of the public comment period for the Environmental Protection Agency’s (EPA) Proposed Rule, “Waste Emissions Charge for Petroleum and Natural Gas Systems (“WEC Rule”) [89 FR 5318]. …

EPA has failed to adequately recognize and address the myriad crosscutting issues among the WEC Rule, EPA’s proposed Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas System (“Subpart W Rule”) [88 FR 50282], and EPA’s proposed New Source Performance Standards and Emission Guidelines for Crude Oil and Natural Gas Facilities: Climate Review (“Methane Rule”) [87 FR 74702]. EPA has also failed to recognize the risks to the workability and durability of these rules posed by an inadequately coordinated rulemaking process.

IPAA believes a 30-day extension of the WEC Rule comment period is both necessary and reasonable in order for IPAA staff and its members to fully analyze the proposed WEC Rule and its connections to the Subpart W Rule and Methane Rule, develop comments, and inform EPA’s final rule. Thank you for your prompt consideration of this request.

Infrastructure, Letters and Comments Jan 30, 2024

Dear Chairmen Graves and Rouzer and Ranking Members Larsen and Napolitano:

We, the undersigned organizations, urge the House Committee on Transportation and Infrastructure to favorably report the Nationwide Permitting Improvement Act.

Building smart, modern, resilient infrastructure through innovation and responsible development is a top priority for the business community. Linear infrastructure from pipelines and transmission lines to other critical infrastructure plays an essential role in reducing greenhouse gas emissions and providing energy security for the United States and our allies. Thousands of miles of hydrogen and CO2 pipelines will be needed to meet ambitious climate goals. This legislation will also help expedite the delivery of clean water for communities and broadband needed to support small business innovation. Ensuring a strong, stable, and predictable nationwide permitting program is critical for the United States to sustainably grow and prosper.

We support NWP-12 and the Nationwide Permitting Improvement Act for the following reasons:

  • Contributing to our national and energy security.
  • Ensuring electricity reliability.
  • Providing the foundation for decarbonization infrastructure.
  • Serving customers with affordable energy.
  • Providing predictability and regulatory certainty for NWP-12.

Letters and Comments Jan 30, 2024

“Dear Speaker Johnson, Senator Schumer, Representative Jeffries and Senator McConnell,

“On March 25th, 2022, President Biden stood with European Commission President Ursula von der Leyen and pledged to work together to lay the framework for a significant increase in U.S. LNG exports to the European Union. American supply allowed the European Union’s economies and population to survive as Russian natural gas was turned off following the brutal Russian invasion of Ukraine.

“At home, the men and women at the heart of U.S. energy production ramped up production at an unprecedented pace to meet domestic demand as well as the new demand from our allies abroad. Today, production has never been higher and energy prices and supply have remained stable in America even with the increased U.S. exports. In fact, U.S. LNG exports reached record highs in 2023 while domestic prices declined 62%.

“The Biden Administration’s recent announcement to pause new non-FTA permits for LNG export facilities could not have come at a worse time. This action threatens to stifle the progress made by the unprecedented ramp up of our domestic industry and the fundamental shift in dependence made by Europe. …

“We strongly support the re-introduction of Unlocking Our Domestic LNG Potential Act by Rep. August Pfluger (TX-11) which will counter this misguided decision by the Administration and put the Federal Energy Regulatory Commission in charge of all LNG export permitting in the United States. Removing DOE from the process will help to ensure that political maneuvers will not interfere with energy supplies. It is vital that Congress send an immediate message to our allies, and enemies, abroad that U.S LNG will continue to flow uninterrupted for many years to come.

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.