Member Login
 

Letters & Comments

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.”

Federal Lands, Letters and Comments, Regulations Nov 10, 2025

The Independent Petroleum Association of America writes in support of The BLM’s Proposed Rule to rescind the Conservation and Landscape Health Rule adopted on May 9, 2024, via 89 FR 40308, with an effective date of June 10, 2024. The Independent Petroleum Association of America (IPAA) is a national upstream trade association representing thousands of independent oil and natural gas producers and service companies across the United States. Independent producers operate 95 percent of the nation’s oil and natural gas wells and are responsible for 85 percent of US oil production and 90 percent of natural gas production onshore.

Attached, please see IPAA’s comment letter we submitted in 2023, detailing how the Rule creates a profound shift in how public lands are managed that is inconsistent with the intent of the Federal Lands Policy and Management Act of 1976 (FLPMA). IPAA is gravely concerned that the Rule fundamentally changes the way BLM carries out its multiple-use and sustained yield mandates by elevating conservation to a “use” under FLPMA.

Letters and Comments, Methane Oct 4, 2025

Dear Administrator Zeldin:

The Independent Petroleum Association of America (IPAA) hereby submit these comments on the Environmental Protection Agency (EPA) Interim Final Rule: 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.

IPAA represents thousands of American independent oil and natural gas producers across the nation that are most affected by the standards (Subpart OOOOb) and guidelines (Subpart 0000c) promulgated by the EPA, and therefore by the actions addressed in this rule.

Overview

IPAA supports this action by EPA to extend a selection of deadlines regarding regulations under Subparts 0000b and 0000c. This action recognizes that these deadlines are impractical because the agency has accepted that reconsideration of the underlying regulations is essential.

EPA has correctly identified that several specific source requirements – control devices, equipment leaks, storage vessels, process controllers, covers/closed vent systems, and continuous monitoring of the “vent gas net heating value” of flares and enclosed combustion control devices – must be modified. Similarly, state planning requirements and the Super Emitter program need revision. Deadlines associated with these requirements must be adjusted.

Additionally, IPAA believes that the Annual Reporting Deadline requirements that were the subject of specific extensions in early August should be suspended until the final regulatory structure of Subpart 0000b is settled.

While EPA’s regulations represent a reasonable extension of time, when the final regulatory structures of Subparts 0000b and 0000c are completed, EPA should revisit these timelines to confirm they are still adequate. …

Letters and Comments, Methane Sep 24, 2025

IPAA and the Producers Association submitted a letter to EPA this week addressing issues related to the regulation of methane emissions for low production wells.

The letter outlines the inefficiencies of methane regulation under the Biden EPA and lays out a framework to manage emissions for low producing wells. IPAA and the associations listed believe that if EPA must regulate methane emissions from low producing wells, a more bespoke approach which recognizes the difference between low producing wells would effectively manage emissions without costly and unreasonable burdens that have created confusion and inefficient emissions management.

To that end, the letter lays out the authorities under EPA’s control to create tranches with different emissions management protocols that recognizes the fundamental differences, emissions profiles, and solutions available to various types low producing wells. Under the proposal, EPA would create three low production categories for wells producing less than 6 boe/day, 6-15 boe/day, and greater than 15 boe/day.

Infrastructure, Letters and Comments, Regulations Sep 4, 2025

Dear Speaker Johnson, Minority Leader Jeffries, Majority Leader Thune, and Minority Leader Schumer,

America’s economic competitiveness depends on our ability to build critical infrastructure quickly. With electricity demand surging from AI, manufacturing, and industrial growth, we need unprecedented levels of new energy production, transmission, and pipeline infrastructure—and we need it now.

Unfortunately, today’s permitting system was designed for a different era. While laws like the National Environmental Policy Act of 1969 (NEPA) were written with good intentions, they have evolved into procedural gauntlets. In the 1970s, the NEPA process for highway projects took a mean of 2.2 years to complete. The average time to complete an Environmental Impact Statement and obtain a Record of Decision now takes an average of almost 4 years. The full process is often further slowed because energy projects of all types run into a “litigation doom loop”, years of lawsuits and delay that create uncertainty and chill investment. These delays don’t improve environmental outcomes, but they do prevent America from building the infrastructure we need. …

Infrastructure, Letters and Comments Sep 3, 2025

Dear Chairman Lee and Ranking Member Heinrich,

On behalf of the organizations representing industries, companies, and individuals who depend on legally durable and timely regulatory decisions relating to energy infrastructure and markets, we write to urge the Senate Committee on Energy and Natural Resources to swiftly approve the Federal Energy Regulatory Commission (FERC or Commission) nominees to fill current vacancies.

The Commission plays a critical role in making certain that energy – from electricity, natural gas, and oil – is secure, reliable, and affordable. To fulfill this role, FERC must advance projects that modernize and expand America’s energy infrastructure, spur economic growth, and ensure reliability and affordability. …

Infrastructure, Letters and Comments Sep 3, 2025

Dear Chairmen Westerman and Graves and Ranking Members Huffman and Larsen,

On behalf of the companies who produce, transport, and deliver natural gas across the nation, the Natural Gas Council writes to urge you to work collaboratively to advance policies that would expedite permitting for critical energy infrastructure under key statutes. Importantly, Congress can reform processes that would establish timelines, clarify the scope of agency review, and reduce the uncertainty associated with judicial review without compromising the United States’ environmental protections.

More than 189 million Americans and nearly six million businesses use natural gas because it is safe, affordable, reliable and essential to improving our environment. Our nation’s natural gas industry is the fundamental underpinning of a growing U.S. economy, adding an additional customer every minute daily, and approximately 60 businesses begin new natural gas service every day. Moreover, U.S. electricity demand is projected to rise due to increased demand from various sectors and because of the re-shoring of manufacturing, and an expansion of AI and data centers. …

Infrastructure, Letters and Comments Sep 3, 2025

Dear Chairwoman Capito, Chairman Lee and Ranking Members Whitehouse and Heinrich,

On behalf of the companies who produce, transport and deliver natural gas across the nation, the Natural Gas Council writes to urge you to advance policies that would restore predictability to the permitting of essential natural gas infrastructure projects.

Permitting reforms for our energy infrastructure networks are crucial to meeting our reliability, affordability, and climate goals. More than 189 million Americans and nearly six million businesses use natural gas because it is safe, affordable, reliable and essential to improving our environment. Our nation’s natural gas industry is the fundamental underpinning of a growing U.S. economy, adding an additional customer every minute daily, and approximately 60 businesses begin new natural gas service every day. Moreover, U.S. electricity demand is projected to rise due to increased demand from various sectors and because of the re-shoring of manufacturing, and an expansion of AI and data centers. …

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.