Letters and Comments

Independent Producers’ Comments Re: Environmental Protection Agency’s Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Reconsideration at 83 Federal Register 52,056 (October 15, 2018)

Letters and Comments Dec 17, 2018

The Independent Producers have participated individually or through the Independent Producers in most, if not all, of the rulemakings and associated litigation since the Environmental Protection Agency (“EPA” or “Agency”) proposed to revise the New Source Performance Standard...

December 17, 2018

Joint Comments to PHMSA on the Safety of Gas Transmission and Gathering Pipelines

Letters and Comments Dec 5, 2018

The Pipeline and Hazardous Materials Safety Administration (PHMSA) in 2016 proposed several changes to the existing regulations applicable to gathering lines in rural areas as part of its larger natural gas pipeline rulemaking. Those proposed changes have elicited fairly consistent comments from the...

December 5, 2018

IPAA PAW Comments on ESA Regulatory Reforms

Re: Revision of the Regulations for Prohibitions to Threatened Wildlife and Plants, 83 Fed. Reg. 35174 (July 25, 2018); Revision of the Regulations for Interagency Cooperation, 83 Fed. Reg. 35178 (July 25, 2018); Revision of the Regulations for Listing Species and Designating Critical Habitat, 83......

September 24, 2018

Comments Regarding the Council on Environmental Quality’s Request to Update Implementing Regulations of the National Environmental Policy Act (NEPA).

Letters and Comments Aug 21, 2018

Since its enactment, requirements involving NEPA have grown considerably and place a heavy burden on independent oil and gas producers operating on federal lands. As more than forty years of experience with implementing NEPA have demonstrated, overly broad NEPA reviews add unreasonable costs and d...

August 21, 2018

Additional Joint Industry Comments on Definition of “Waters of the United States” (WOTUS)

Letters and Comments Aug 14, 2018

The organizations filing these comments support the Environmental Protection Agency’s and the Army Corps of Engineers’ proposal to repeal the 2015 Rule Defining Waters of the United States (“2015 Rule”), and many have submitted individual comment letters detailing reasons for supporting the ...

August 14, 2018

Comments to the Federal Energy Regulatory Commission Regarding its Notice of Inquiry on Certification of New Interstate Natural Gas Facilities

Letters and Comments Jul 25, 2018

Pursuant to the April 19, 2018, Notice of Inquiry, issued by the Federal Energy Regulatory Commission (“Commission”) in the above-referenced docket, the Independent Petroleum Association of America (“IPAA”) hereby respectfully submits the following comments on Certification of New Interst...

July 25, 2018

Natural Gas Council Comments to the Federal Energy Regulatory Commission Regarding its Notice of Inquiry on Certification of New Interstate Natural Gas Facilities

Letters and Comments Jul 25, 2018

Dear Chairman McIntyre: We are writing you on behalf of the Natural Gas Council (NGC) to express our views in connection with the referenced Notice of Inquiry (NOI) issued by the Federal Energy Regulatory Commission (Commission), in Docket No. PL18-1-000. Formed in 1992, the NGC......

July 25, 2018

IPAA Letter to Secretary of the Interior Ryan Zinke Supporting Plans to Reorganize and Streamline the U.S. Department of the Interior

Letters and Comments Jul 19, 2018

Dear Secretary Zinke: The Independent Petroleum Association of America (IPAA) is dedicated to supporting and promoting the safe and responsible development of our nation’s abundant energy resources. One of the keys to increasing American oil and natural gas production is to have a reasonabl...

July 19, 2018

President and CEO Barry Russell Letter to Congressional Western Caucus Chairman Paul Gosar Supporting the Endangered Species Act Modernization Package

Letters and Comments Jul 10, 2018

Dear Chairman Gosar: The Independent Petroleum Association of America writes to express its support for the nine bills included in the Congressional Western Caucus Endangered Species Act Modernization Package. IPAA believes both exploration and development of America’s oil and natural gas resourc...

July 10, 2018

Comments to the U.S. Environmental Protection Agency on its Draft Audit Policy Agreement for New Owners of Oil and Natural Gas Exploration and Production Facilities

Letters and Comments Jul 2, 2018

Dear Deputy Director Chapman: This document provides comments from the IPAA in response to the U.S. Environmental Protection Agency’s (“EPA’s” or “the Agency’s”) request for comments on its proposed changes to EPA’s 2000 policy titled “Incentives for Self-Policing: Discovery, Discl...

July 2, 2018