Feb 9, 2016 IPAA and API Joint Comments to the U.S. Fish and Wildlife Service on its Proposed Rule on Management of Non-Federal Oil and Gas Rights on National Wildlife Refuges
This letter provides the comments of the American Petroleum Institute (API) and the Independent Petroleum Association of America (IPAA) (the “Associations”) in response to the U.S. Fish and Wildlife Service’s proposed rule and associated draft environmental impact statement (DEIS) addressing the management of non-federal oil and gas rights on National Wildlife Refuge System (NWRS) lands and waters. See 80 Fed. Reg. 77,200 (Dec. 11, 2015). The Associations appreciate the Service’s consideration of these comments.