Comments to the Office of Natural Resources Revenue on its Advance Notice of Proposed Rulemaking for Federal Oil and Gas & Federal and Indian Coal Valuation

Comments to the Office of Natural Resources Revenue on its Advance Notice of Proposed Rulemaking for Federal Oil and Gas & Federal and Indian Coal Valuation

Dear Mr. Aguilar: I write on behalf of the membership of the Independent Petroleum Association of America (IPAA) in response to the Advance Notice of Proposed Rulemaking, published at 82 Federal Register 16,325 (April 4, 2017), concerning royalty valuation for federal oil and gas, as well as federal and Indian coal. We appreciate the willingness of the Office of Natural Resource Revenues (ONRR) to re-examine royalty valuation.

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