IPAA and Western Energy Alliance Joint Comments to the Department of the Interior on the Bureau of Land Management’s Proposal to Rescind the 2015 Final Rule for Hydraulic Fracturing on Federal and Indian Lands

IPAA and Western Energy Alliance Joint Comments to the Department of the Interior on the Bureau of Land Management’s Proposal to Rescind the 2015 Final Rule for Hydraulic Fracturing on Federal and Indian Lands

Dear Ms. MacGregor and Mr. Nedd: On July 25, 2017, the Bureau of Land Management (BLM) published a proposed rule that would rescind a final rule BLM issued in March 2015. The “2015 Rule” was designed to regulate hydraulic fracturing on federal and Indian lands. This submission constitutes comments on the July 2017 proposal from the Independent Petroleum Association of America (IPAA) and the Western Energy Alliance (collectively, the Associations). The Associations collectively represent thousands of independent oil and natural gas explorers and producers, as well as the service and supply industries that support their efforts. It is the members of these groups that the proposed rescission will most significantly affect. Independent producers drill about ninety-five percent of American oil and natural gas wells, produce about fifty-four percent of American oil, and more than eighty-five percent of American natural gas. From the beginning, the Associations have actively engaged to assist BLM’s rulemaking efforts related to hydraulic fracturing.

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