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Letters & Comments

Letters and Comments, Methane, Regulations Jan 6, 2026

Re: Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems, Docket No. EPA-HQ-OAR-2023-0234

The Independent Petroleum Association of America (IPAA) submits this letter to address uncertainties caused by the underlying reconsideration of Subpart W in the Greenhouse Gas Reporting Program (GHGRP). IPAA is a national trade association that represents oil and natural gas producers and their support industries, including thousands of low production well producers.

Letters and Comments, Regulations Jan 5, 2026

Dear Environmental Protection Agency and Army Corps of Engineers:

This letter provides comments from the American Petroleum Institute (“API”), the Independent Petroleum Association of America (“IPAA”), the Petroleum Alliance of Oklahoma, the Petroleum Association of Wyoming (“PAW”), and the Western States’ Petroleum Association (“WSPA”) in response to the U.S. Environmental Protection Agency’s (“EPA’s”) and the Army Corps of Engineers’ (“Army Corps”) (collectively “the Agencies’”) proposed revisions (“Proposed Revisions”) to the definition of “Waters of the United States” (“WOTUS”).

We appreciate the Agencies’ commitment to fully incorporating the jurisdictional limits Congress imposed through the Clean Water Act (“CWA” or “the Act”) and the broad interpretive guideposts provided by the United States Supreme Court (“Supreme Court” or “the Court”). We believe that our additional clarifying changes further goals we share with the government — developing an interpretation of WOTUS that is clear, protective of the environment and human health, administrable, and legally sound. …

Letters and Comments, Regulations Jan 5, 2026

The Waters Advocacy Coalition (“WAC”) offers the following comments on the Environmental Protection Agency’s (“EPA”) and U.S. Army Corps of Engineers’ (“Corps”) (collectively, the “Agencies”) proposed revised definition of “waters of the United States” (“WOTUS”) under the Federal Water Pollution Control Act, as amended, also known as the Clean Water Act (“CWA” or “Act”),1 Updated Definition of “Waters of the United States,” 90 Fed. Reg. 52,498 (Nov. 20, 2025) (hereinafter, “Proposed Rule”). WAC appreciates the Agencies’ efforts to improve regulatory predictability and consistency by further clarifying the scope of WOTUS. When Congress enacted the CWA, it exercised its commerce power over navigation and specifically granted the Agencies the power to regulate “navigable waters,” which the CWA defines as “waters of the United States.”

Infrastructure, Letters and Comments Dec 16, 2025

Dear Members of the U.S. House of Representatives:

The undersigned organizations write to express strong support for the passage of H.R. 4776, the “Standardizing Permitting and Expediting Economic Development Act,” or the “SPEED Act.” By modernizing the permitting process, this legislation will help advance infrastructure, energy, natural resource, transportation, and other projects that improve quality of life, revitalize communities, and deliver the goods and services families rely on every day.

Unfortunately, today’s permitting system is burdened by delays, uncertainty, and duplicative reviews that stall investment and innovation, leaving critical projects in limbo for years. The SPEED Act offers common-sense reforms that address these challenges. It helps focus environmental reviews where they matter, promotes project certainty through requiring clear timelines, and improves coordination among federal agencies to reduce redundant reviews. These reforms and others in the bill will not only improve permitting efficiency but also help businesses to plan and invest with confidence, creating jobs, strengthening supply chains, and advancing U.S. leadership in energy, manufacturing, technology, and beyond. …

Infrastructure, Letters and Comments Dec 12, 2025

Dear Mr. President,

As leaders of America’s foremost energy trade associations, we write to express our strong support for the Standardizing Permitting and Expediting Economic Development (SPEED) Act and to respectfully urge the Administration to prioritize its advancement.

The undersigned associations represent the vast majority of U.S. oil and gas companies and the full supply chain that produces the energy Americans rely on every day, energy that powers homes, businesses, transportation, and national infrastructure. By supporting domestic energy development, we also lift communities, strengthen families, and sustain American industries, creating economic and societal benefits that lift every part of the country.

Modernizing federal permitting is essential to achieving the Administration’s stated goals of restoring American energy dominance, strengthening domestic industry, and accelerating major U.S. infrastructure and energy investment. …

Letters and Comments, Steel & Aluminum Tariffs Dec 10, 2025

Dear Members of the United States House and Senate,

We are writing to express urgent concern regarding the impact of tariffs on steel, aluminum, and other imported materials on the U.S. oilfield services (OFS) sector—a cornerstone of American energy leadership and industrial strength. …

To safeguard American energy leadership, jobs, and supply chain resilience, we urge Congress to:

  • Reinstate and expand the Section 232 tariff exclusion process for critical energy components.
  • Exempt OCTG, valves, and essential oilfield equipment from tariff lists.
  • Support policies that promote domestic production and workforce retention of the 650,000 jobs in the OFS sector.

Infrastructure, Letters and Comments, Regulations Dec 10, 2025

Dear Speaker Johnson and Leader Jeffries,

On behalf of the companies who produce, transport and deliver natural gas across the nation, the Natural Gas Council writes in support of H.R. 3898, the Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act and H.R. 3668, the Improving Interagency Coordination for Pipeline Reviews Act. These proposals would provide expedited permitting and improve regulatory certainty for gas pipeline infrastructure under the National Environmental Policy Act of 1969 (NEPA) and the Clean Water Act (CWA). …

Letters and Comments, Methane Dec 3, 2025

IPAA and a coalition of eight other energy trade organizations sent a letter urging House leadership to pass Representative Westerman’s H.R.4776 – Standardizing Permitting and Expediting Economic Development (SPEED) Act.


“Dear Speaker Johnson and Democratic Leader Jeffries,

“Across our country, American families and businesses need more affordable energy. It is more important than ever that Washington act soon to cut red tape and lower prices for consumers. On behalf of our combined industries—which supply a majority share of the energy infrastructure that powers America’s economy—we write to express strong support for H.R. 4776 the Standardizing Permitting and Expediting Economic Development (SPEED) Act. This bipartisan legislation takes critical steps to reforming a permitting system that too often chills investment, creates uncertainty, and increases costs and delays for essential energy infrastructure projects. … “

Infrastructure, Letters and Comments Nov 19, 2025

Dear Chairman Guthrie and Ranking Member Pallone,

On behalf of the companies that produce, transport, and deliver natural gas across the nation, the Natural Gas Council writes in strong support of legislation that protects Americans’ access to safe, affordable natural gas. Such access is essential to maintaining the affordability, reliability, and quality of life that Americans depend on, while supporting a sustainable energy future. For these reasons, we support H.R. 3699, the Energy Choice Act, and H.R. 4690, the Reliable Federal Infrastructure Act. …

Letters and Comments, Offshore, Regulations Nov 11, 2025

Dear Ambassador Greer:

The Independent Petroleum Association of America (IPAA) writes to recommend a clarification to the definition of “long-term charter agreement” in Annex I to ensure it is reflective of and consistent with customary business practices in the ship chartering industry. …

The proposed clarification to Section 301 Annex I Targeted Coverage is on page 30:

“and is in service and entered into a long-term charter agreement (that is, 20 years or more, inclusive of all extension rights that are at the sole discretion of the charterer) prior to December 31, 2027, will be considered owned and operated by the charterer.”

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.