Letters and Comments
Comments of AFPM, AXPC, API, DEPA and IPAA on the EPA’s Proposed Rule Updating Regulations for Water Quality Certifications under Section 401 of the Clean Water Act
Letters and Comments Oct 21, 2019Dear Sir/Madam: This letter provides comments from the American Fuel & Petrochemical Manufacturers (“AFPM”), the American Exploration and Production Council (“AXPC”), the American Petroleum Institute (“API”), the Domestic Energy Producers Alliance (“DEPA”), and the Independent Pe...
October 21, 2019
Natural Gas Council letter Re: Updating Regulations on Water Quality Certification
Letters and Comments Oct 21, 2019“Dear Administrator Wheeler: The Natural Gas Council submits this letter in response to the proposed rule published by the Environmental Protection Agency (“EPA”) on August 22, 2019, that proposes to update and clarify the substantive and procedural requirements for water quality certifica...
October 21, 2019
Energy Infrastructure Stakeholders Urge Adoption of New CWA Section 401 Rules
Letters and Comments Oct 8, 2019On Tuesday, October 8, IPAA joined a broad coalition of energy infrastructure stakeholders in writing to EPA Administrator Andrew Wheeler urging adoption of the new Clean Water Act Section 401 rules. Organized by the Energy Equipment & Infrastructure Alliance, letter signers included eight labor...
October 8, 2019
IPAA comments on Railroad Commission (RRC) informal draft of revised pipeline safety regulations for oil and natural gas pipelines
Infrastructure, Letters and Comments Aug 12, 2019The Independent Petroleum Association of America (IPAA) submits the following comments in response to the Railroad Commission (RRC) informal draft of revised pipeline safety regulations for oil and natural gas pipelines. IPAA is a national upstream trade association representing thousands of indepen...
August 12, 2019
IPAA Amicus Curiae Brief in Support of Petitioners’ Joint Motion for Preliminary Injunction
Letters and Comments, Regulations, Taxes Aug 2, 2019One of IPAA’s primary purposes is to advocate for its members’ interests in continued and responsible oil and gas development before Congress and federal agencies and in the judicial system. (Id.) This purpose includes advocating for rational and fair policies on the valuation of royalties......
August 2, 2019
IPAA Comments on Proposed Rule to Reclassify American Burying Beetle from Endangered to Threatened
Letters and Comments Jul 1, 2019Re: Comments on Proposed Rule to Reclassify the American Burying Beetle (Nicrophorus americanus) from Endangered to Threatened on the Federal List and Proposed Endangered Species Act Section 4(d) Rule FWS-R2-ES-2018-0029 … IPAA supports the proposed rules to downlist and reclassify the America...
July 1, 2019
API, AXPC, IPAA and DEPA Comments on EPA Development of a Draft Water Reuse Action Plan
Letters and Comments Jun 27, 2019Summary In considering viable options and opportunities for water reuse, we encourage EPA to consider ways to provide maximum flexibility, certainty, and clarity to the existing regulatory and permitting frameworks applicable to the management of water from all industries (including the oil and natu...
June 27, 2019
Supplemental Comments Re: EPA’s Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Reconsideration
Letters and Comments, Methane Jun 17, 2019Dear Administrator Wheeler: The following Supplemental Comments are submitted on the above-referenced proposed Reconsideration Rulemaking (“Reconsideration Rulemaking”) on behalf of the following national and state trade associations: the Independent Petroleum Association of America (“...
June 17, 2019
Re: Comments of the American Petroleum Institute, the American Exploration & Production Council, the Association of Oil Pipe Lines, the Independent Petroleum Association of America, the Domestic Energy Producers Alliance, and the Marcellus Shale Coalition in Response to the Environmental Protect...
June 7, 2019