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Federal Lands, Letters and Comments Aug 31, 2026

IPAA and the Western Energy Alliance (the “Associations”) represent many members who are responsible for the filing of the Federal production and royalty reports to the Office of Natural Resources Revenue (“ONRR”).

The following tenets underly the Associations’ comments that follow:

1. The Associations support Secretary Burgum’s efforts to repeal regulations that are burdensome and unneeded. The Associations support the Secretary’s efforts to make regulations clearer, more consistent, and more certain in their application.

2. The Associations agree that free markets are the best way to create jobs, provide energy, and increase the nation’s wealth. To further those goals, the Associations continue to believe that the Department’s decision in 1988 to use the gross proceeds from arm’s length contracts as the best indication of market value is still the correct approach to follow in royalty valuation.

3. The Associations welcome this rulemaking as an opportunity to correct ill-considered trends in recent years in ONRR’s valuation and enforcement practices. More specifically, ONRR has altered its interpretation of the rules in recent years through ad hoc decisions that lead to costly, long drawn out disputes. …

Federal Lands, Letters and Comments, Regulations Aug 24, 2026

Western Energy Alliance (Alliance), the Independent Petroleum Association of America (IPAA), Colorado Oil and Gas Association, Independent Petroleum Association of New Mexico, Montana Petroleum Association, New Mexico Oil and Gas Association, North Dakota Petroleum Council, Petroleum Association of Wyoming, Utah Petroleum Association, and West Slope Colorado Oil and Gas Association, collectively the Trades, appreciate the opportunity to comment on the Bureau of Land Management’s (BLM) proposal to modify its existing regulations pertaining to royalties due on oil and natural gas lost on Federal and Indian leases.

The Trades represent member companies who are engaged in the environmentally responsible development of oil and natural gas on BLM lands across the West. Our members will be directly impacted by this rulemaking and have a substantial interest in ensuring it aligns with BLM’s 2 of statutory authority and achieves the appropriate balance between environmental protection and energy development on federal lands. The Trades support the proposed updates, with some edits suggested , and urge BLM to expeditiously finalize the rule.

Federal Lands, Letters and Comments, Regulations Aug 24, 2026

Western Energy Alliance, the Independent Petroleum Association of America, Colorado Oil and Gas Association, Montana Petroleum Association, New Mexico Oil and Gas Association, North Dakota Petroleum Council, Petroleum Association of Wyoming, Utah Petroleum Association, and West Slope Colorado Oil and Gas Association, collectively the Trades, appreciate the opportunity to comment on the Bureau of Land Management’s (BLM) draft rule on Oil and Gas Leasing. The Trades support the proposed updates, with minor comments and edits suggested, and urge BLM to expeditiously finalize the rule.

If finalized, the draft rule would create a more streamlined onshore oil and gas leasing and permitting program, while maintaining environmental protections on federal lands. The rule would also make oil and natural gas development on federal lands more competitive with production on state and private lands, ensuring the costs to operate and timelines for development of federal acreage more closely resemble those on non-federal lands. The proposed changes appropriately reflect FLPMA’s requirement that BLM manage these lands for multiple and sustained yield of resources such as oil and gas.

As BLM’s website notes, production of federal minerals “accounted for approximately 15 percent of domestically produced oil and 9 percent of domestically produced natural gas” in the most recent year for which data are available. Thus, BLM’s management of the onshore oil and gas program is undoubtedly critical to ensuring our country’s energy dominance and national security. Once again, the Trades appreciate that BLM’s draft rule would help achieve those goals.

Our comments highlight support for specific changes in the proposal, provide details on why those changes are necessary, and offer suggestions on ways in which the rule could be strengthened or clarified, including in response to questions posed by BLM within the draft. The comments proceed section-by-section through the proposed rule, although not all of the sections necessitate a response. In lieu of repeating previous discussion of deficiencies with the 2024 Rule, the Trades also provide our prior comment letters as attachments at the end of this submission. …

Letters and Comments, Offshore Aug 21, 2026

The Independent Petroleum Association of America (“IPAA”) appreciates the opportunity to submit comments regarding NOAA’s performance evaluation of the California Coastal Management Program (“CCMP”) under Section 312 of the Coastal Zone Management Act (“CZMA”), 16 U.S.C. § 1458.

NOAA’s review provides an important opportunity to assess not merely whether California has adopted coastal policies, but whether it is effectively implementing the federally approved CCMP in accordance with the CZMA, including its federal consistency provisions. IPAA recognizes the value of protecting the nation’s coastal resources and supports the balanced approach embodied in the CZMA. Congress established a collaborative federal-state structure intended to reconcile coastal conservation with legitimate national and economic interests.

IPAA’s primary concern in this evaluation is whether California has materially altered the substance of its federally approved coastal-management program through subsequent legislative amendments and administrative implementation without obtaining the approval required by the CZMA. …

Infrastructure, Letters and Comments, Regulations Jul 28, 2026

The Natural Gas Council (NGC), on behalf of the companies that produce, transport, and deliver natural gas across the nation, urges Congress to enact durable permitting reforms that provide the predictability needed to develop America’s critical energy infrastructure.

In a recent letter to Senate leaders Chairwoman Capito, Chairman Lee and Ranking Members Whitehouse and Heinrich, the NGC leaders wrote:

“Reliable energy infrastructure is foundational to America’s economic strength, energy security, and global competitiveness. Natural gas infrastructure supports affordable energy, strengthens domestic manufacturing, enables U.S. energy exports, enhances electric reliability, and provides the dependable foundation needed to accommodate rising energy demand.

“Increased electricity consumption, the expansion of artificial intelligence and data centers, the resurgence of domestic manufacturing, and population growth are reshaping the U.S. energy landscape. Notably, the Energy Information Administration’s 2026 Annual Energy Outlook projects that total U.S. electricity generation will increase by 25 to 50 percent by 2050. It also projects natural gas use in the electric power sector will grow more than in any other end-use sector, rising from 35.2 Bcf/d in 2025 to as much as 50.4 Bcf/d by 2050. Meeting this growth will require continued investment in natural gas production, transportation, and delivery infrastructure that reliably and affordably serves homes, businesses, manufacturers, and electric generators…”

Letters and Comments, Regulations Jul 27, 2026

IPAA and a coalition of nearly 40 trade associations led by the U.S. Chamber of Commerce submitted comments to the U.S. Environmental Protection Agency (EPA) supporting the administration’s comprehensive effort to modernize the permitting process:

“The proposed updates of EPA’s existing NEPA procedures along with other administration actions represent important steps forward in addressing long-standing challenges that have hindered infrastructure development and responsible use of natural resources, delivering tangible benefits to communities and local economies.

“Modernizing outdated agency NEPA procedures while maintaining environmental protections of underlying action statutes and implementing reforms will reduce delays and uncertainties. With this action, the administration is paving the way for timely agency project approvals that support local job creation, economic revitalization, and community growth…”

Federal Lands, Letters and Comments Jul 13, 2026

IPAA, API and a coalition of groups representing energy producers wrote to BLM highlighting how “We appreciate and support the Administration’s intention “to modernize the BLM’s grazing program,” however, we note with concern that this rule, titled “Revisions of Regulations for Grazing Administration – Exclusive of Alaska,” could actually impact a far broader set of stakeholders than the grazing-specific title would suggest, unless BLM provides clarification in the final rule. The proposed changes include relocating the existing Subpart 4180 framework specific to the grazing program to an entirely new 43 CFR Part 1700 (“Part 1700”), which – as presently drafted – applies LHS to all BLM programs.

“The Associations urge BLM to specifically clarify in the final rule that the sections expanding on the use of land health standards have no application beyond range lands used for grazing at this time. Specifically, any final rule should make clear that BLM is making no changes to its management of oil and gas development (or any other multiple use aside from grazing) on federal lands, and that oil and gas leaseholders possess valid existing rights that are in no way impacted by this specific rule on grazing policies. …”

Federal Lands, Letters and Comments May 21, 2026

To Whom It May Concern:

The American Petroleum Institute (“API”), Independent Petroleum Association of America (“IPAA”), Western Energy Alliance, Colorado Oil & Gas Association (“COGA”), Western Slope Colorado Oil & Gas Association (“WSCOGA”), Montana Petroleum Association (“MPA”), New Mexico Oil & Gas Association (“NMOGA”), the Petroleum Alliance of Oklahoma; and Utah Petroleum Association (“UPA”) (collectively “the Associations”) respectfully support’s the Bureau of Land Management’s (“BLM”) decision to make non-discretionary revisions to existing regulations at 43 CFR 3103.31(a)(1) – (5) to effectuate the changes required by the One Big Beautiful Bill Act (“OBBBA”) enacted on July 4, 2025.

The direct final rule is an appropriate vehicle because, at the present time, these non-discretionary changes are necessary for compliance. Section 40101(a)(1) of the OBBBA repealed Section 5026(a) of the Inflation Reduction Act (“IRA”). It also stated that any provision amended or repealed by that subsection is restored or revived as if that subsection had not been enacted into law. Therefore, the BLM correctly determined that the following changes must be made:

• 43 CFR 3103.31(a) must be revised to reflect the correct royalty rate applicable to production from Federal oil and gas leases, restoring the royalty rate to not less than 12.5 percent.

• 43 CFR 3103.31(a)(2) and (a)(3) must be removed in their entirety, as they include royalty rates that are no longer applicable.

• The current 43 CFR 3103.31(a)(4) will be redesignated to (a)(2), with all references to the IRA’s 16.67 percent royalty rate removed and adjusted to the 12.5 percent designated in OBBBA.

• A new 43 CFR 3103.31(a)(3) must be added to address the royalty rate for non-competitive leases, as reinstituted by the OBBBA.

• The current 3103.31(a)(5) will be redesignated to (a)(4) and also must be revised to address the OBBBA-designated royalty rate for reinstated leases. …

Letters and Comments, Offshore May 15, 2026

Dear Ms. Thundiyil:

The Gulf Energy Alliance (GEA), the Independent Petroleum Association of America (IPAA) the U.S. Oil and Gas Association (USOGA), the Southeast Oil and Gas Association (SOGA), the Mississippi Energy Institute (MEI), the Louisiana Oil and Gas Association (LOGA), and the American Energy Institute (AEI) (hereinafter “the Associations”) respectfully submit the following comments in response to the Bureau of Ocean Energy Management’s proposed rule entitled Risk Management and Financial Assurance for OCS Lease and Grant Obligations, 91 Fed.
Reg. 11212 (March 9, 2026) (to be codified at 30 C.F.R. pts. 550, 556, and 590) (“the Proposed Rule”). …

It is vitally important that the Proposed Rule, with minor modifications, promptly become a final rule. Regulatory uncertainty regarding this specific issue has hindered investment in the GOA for ten years. At such a tenuous time for the offshore oil and gas industry, finalizing the Proposed Rule will provide necessary regulatory certainty, respect market participants’ previous bargains, and allow this critical sector of the American economy to flourish—all to the benefit of taxpayers, state and local governments, and the United States itself.

 

Federal Lands, Letters and Comments, Regulations Apr 2, 2026

To Whom It May Concern:

The American Petroleum Institute (“API”), Independent Petroleum Association of America (“IPAA”), Alaska Oil and Gas Association (“AOGA”), Colorado Oil and Gas Association (“COGA”), Montana Petroleum Association (“MPA”), New Mexico Oil and Gas Association (“NMOGA”), North Dakota Petroleum Council (“NDPC”), the Petroleum Alliance of Oklahoma, the Petroleum Association of Wyoming, and the Western States Petroleum Association (“WSPA”)— collectively “The Associations” — respectfully submit the following coalition comments on the Bureau of Land Management’s (“BLM”) proposed Requirements for Site Security and Production Handling; Applying for Commingling and Allocation Approval (“Proposed Rule”) that was published in the Federal Register on January 30, 2026. This letter contains both our substantive comments and a suggested redline of regulatory text (Attachment 1). On March 2, 2026, the API and ten industry partners submitted comments to the BLM in response to the Office of Management and Budget’s Information Collection Request (“ICR”) pertaining to the revised information collection requirements in the Proposed Rule. …

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.