Nov 6, 2017 Western Energy Alliance, IPAA Joint Comments to the Bureau of Land Management on the Proposed Stay of its 2016 Waste Prevention (Venting and Flaring) Rule
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.