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Letters and Comments Aug 6, 2025

This letter provides comments from the American Petroleum Institute (“API”), American Fuel & Petrochemical Manufacturers (“AFPM”), GPA Midstream, and the Independent Petroleum Association of America (“IPAA”) (collectively, “the Associations”) in response to the U.S. Environmental Protection Agency’s (“EPA’s” or “the Agency’s”) request for information on revising the regulations for Section 401 of the Clean Water Act (“CWA”).

The Associations appreciate and support EPA’s May 21, 2025 memorandum, “Clarification regarding Application of Clean Water Act Section 401 Certification,” which clarifies that the statutory intent of Section 401 water quality certifications is to protect water quality.[1]  As explained in more detail below, the Associations encourage EPA to pursue a rulemaking that restores the previous 2020 final rule on Section 401 of the CWA. The procedural guardrails, timelines, and specific interpretation found in that rule would provide the regulatory certainty and consistency needed for project developers to receive permits in a timely fashion.

Letters and Comments, Regulations Aug 6, 2025

Subject: Comments on Section 401 State Water Quality Certification Open Docket; Docket ID No. EPA-HQ-OW-2025-0272

Dear Ms. Browne,

The undersigned organizations write to express strong support for continued improvements to the Clean Water Act (CWA) Section 401 certification process— ensuring that the possible changes to the regulation provide clarity, certainty, and regulatory durability.

Permitting reform is essential to advancing national economic growth and modernizing critical infrastructure, while maintaining the environmental protections that are central to EPA’s mission. Efficient, transparent permitting processes help accelerate the deployment of energy, transportation, and water infrastructure— driving job creation and resilience in communities across our nation. Clean Water Act Section 401 state certifications play a foundational role in this framework, ensuring that states and tribes have a meaningful voice in reviewing that federally permitted projects comply with water quality standards. Strengthening coordination and certainty around Section 401 certifications can enhance both environmental outcomes and permitting efficiency, supporting EPA’s goals of protecting water resources, while enabling timely infrastructure investment.

Infrastructure, Letters and Comments, Regulations Jul 29, 2025

Dear Chairman Westerman:

As a coalition of oil and natural gas trade associations representing over 80 percent of domestic oil and natural gas production in the United States, we write in strong support of the “Standardized Permitting and Expediting Development Act” (SPEED Act) and thank you and all the sponsors for introducing this important legislation. The bipartisan nature of this legislation is both important in a divided and polarized political environment and essential to get this bill across the legislative “finish line.”

Reforming the nation’s outdated permitting system is key to the success of the American economy. The SPEED Act addresses many of the most critical issues surrounding the National Environmental Policy Act (NEPA) and makes commonsense reforms to the law. …

Infrastructure, Letters and Comments Jul 29, 2025

The Independent Petroleum Association of America (IPAA) submits the following comments regarding PHMSA’s advanced notice of proposed rulemaking (ANPRM) regarding Pipeline Safety Regulations. IPAA members are the primary producers of the nation’s natural gas and oil, accounting for 90 percent of America’s natural gas production and 83 percent of its oil output. Independent producers remain a driving force in our economy and support millions of jobs in the United States.

Although there are a variety of important issues facing independent producers regarding pipeline safety issues, IPAA wants to raise several specific issues outlined below…

Letters and Comments, Methane Jul 25, 2025

RE: RIN:2060-AW261: Extension of Deadlines in Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review.

Dear Administrator Zeldin and Deputy Administrator Fatouhi,

We are writing on behalf of the Domestic Energy Producers Alliance (DEPA) and the Independent Petroleum Association of America (IPAA). Our member companies urgently request that EPA promptly extend the compliance deadline for submitting the annual report under EPA’s Oil and Gas Methane Rule, which is currently due on August 5, 2025. The EPA can accomplish this by promptly issuing a Federal Register notice extending the current annual reporting deadline, or by issuing a direct final rule to extend the annual reporting deadline for one year under its general authorities.

This extension is not only necessary but also crucial to enable the EPA to align its plans for the Methane Rule with other related actions taken by the Agency and Administration regarding the growth of the energy sector and the return of power to the States. It would also be consistent with the stay of the litigation challenging the Methane Rules in the D.C. Circuit, Court of Appeals, obtained by EPA based on EPA’s announcement that it is reconsidering the Methane Rule.

The first annual report under the Methane Rule is due August 5. However, the process of collecting the data and preparing these reports is highly onerous and resource-intensive, imposing significant burdens on American energy producers. …

Infrastructure, Letters and Comments Jul 21, 2025

Dear Chairman Westerman:

…Reforming the nation’s outdated permitting system is critical to bolstering energy security, growing jobs, and building much-needed energy infrastructure to support the projected energy demands of our country in the coming years. According to Lawrence Berkeley National Laboratory, as of 2022 it took an average of five years for an energy infrastructure project to move from initial permitting to operation, more than double the time it took in 2000. Compounding these delays, Stanford University reports that nearly 30% of major energy and infrastructure projects requiring an environmental impact statement face predevelopment litigation, often based on meritless or duplicative claims under the National Environmental Policy Act (NEPA). These lawsuits have become a tool to delay or price projects out of existence. Delays discourage investment and threaten our energy security. Many projects take even longer or are ultimately cancelled as funding is lost, or companies decide to invest in regions with more stable and predictable permitting regimes.

As your committee begins the heavy lift of holding oversight hearings and developing legislation, we recommend the principles that form the foundation of strong energy development be prioritized. Permitting reform should:

  • Define clear agency permitting approval processes
  • Streamline interagency coordination of reviews
  • Ensure cost certainties and reliable timetables
  • Place reasonable limits on environmental reviews
  • Prohibit project approvals from being slowed for political purposes
  • Prevent obstructionist protests intended to indefinitely halt projects
  • Set clear guidelines for judicial reviews and corrective actions. …

Letters and Comments, Offshore Jul 11, 2025

Dear Chair Graves and Ranking Member Larsen:

President Trump’s directive that the U.S. government “unleash American energy” (Executive Order 14154) has helped set the country on a course of global energy dominance. Congress plays a significant role in advancing this important agenda, and the U.S. Outer Continental Shelf (OCS) is a critical component in this energy dominance strategy. Approximately 1 of every 6 barrels produced domestically comes from the OCS, along with more than 300,000 jobs for American workers, and billions of dollars in state and federal taxes and royalty revenues. Offshore energy development is an irreplaceable strategic asset for America’s national security, which is why it is so important that U.S. policy supports growing access to, and production of, oil and natural gas in the Gulf of America.

As the Committee prepares to consider the HR 4275, the Coast Guard Authorization Act of 2025, we want to caution against the inclusion of language that could hinder the goal of energy dominance, specifically in the Gulf of America. In the last several Coast Guard reauthorization bills, the House of Representatives has included language from a bill introduced in past Congresses called The American Offshore Worker Fairness Act, which would place stifling and unreasonable restrictions on the limited number of highly specialized vessels needed for exploration, to construct new and expanding Gulf of America oil and natural gas projects and to effectively maintain existing production. The language would effectively eliminate the ability to use these vessels and the well-trained and highly experienced crew that accompany them because they are foreign-owned and foreign-flagged. …

Letters and Comments Jul 10, 2025

Dear Leader Thune, Leader Schumer, Chairman Lee, and Ranking Member Heinrich:

We write to express our gratitude for the Senate’s confirmation of President Donald Trump’s picks to lead the Department of the Interior (DOI) – Secretary Doug Burgum and Deputy Secretary Katharine MacGregor – and to express our strong support for the expeditious consideration of all remaining DOI nominees who are currently awaiting Senate floor action. …

Endangered Species, Letters and Comments Jul 9, 2025

The American Petroleum Institute (“API”), the American Exploration and Production Council (“AXPC”), the Independent Petroleum Association of America (“IPAA”), GPA Midstream Association, Marcellus Shale Coalition, the North Dakota Petroleum Council (“NDPC”), the Petroleum Alliance of Oklahoma, the Texas Oil and Gas Association (“TXOGA”), and Utah Petroleum Alliance (“UPA”) (collectively, the “Associations”) appreciates the opportunity to provide comments in response to the Fish and Wildlife Service’s (“FWS” or “the Service”) request for information (“RFI”) issued on June 9, 2025. This RFI sought feedback on improvements to the development and implementation of survival permits associated with Conservation Benefit Agreements (CBAs) and Incidental Take Permits (ITPs) associated with Habitat Conservation Plans (HCPs) under Section 10(a) of the Endangered Species Act (ESA). We appreciate the Trump Administration’s desire to achieve a meaningful reduction in regulatory burdens while continuing to meet statutory obligations, advance American energy independence, and ensure the responsible stewardship of the nation’s public lands and resources. …

Voluntary conservation agreements such as HCPs and CBAs are helpful mechanisms to minimize impacts to species and habitat and contribute to overall species conservation goals, while avoiding unwarranted access restrictions that could obstruct national energy security objectives. A significant value of these plans lies in their ability to streamline or even proactively preempt the often-lengthy Incidental Take Permit process, a benefit that works both in favor of industry and the Service. Though not applicable in all situations and for all species, the Associations’ members already successfully leverage various CBAs and HCPs for species such as the Dunes Sagebrush Lizard, the Lesser Prairie Chicken, the Texas Hornshell Mussel, and the Monarch Butterfly. Critical learnings from these initiatives can be applied to future conservation plans, as per the suggestions delivered below. …

 

Infrastructure, Letters and Comments Jul 7, 2025

Chairman and Commissioners:

On behalf of the thousands of companies who produce, transport, and deliver natural gas to the 189 million Americans and 5.8 million businesses that use it, the Natural Gas Council writes the following in reference to Docket No. AD25-7-000, “Meeting the Challenge of Resource Adequacy in Regional Transmission Organization and Independent System Operator Regions,” and in response to the Commissioner-led technical conference that occurred on June 4-5, 2025.

It was apparent during the conference discussion that ensuring reliable natural gas supply is a critical component underpinning resource adequacy. …

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.