Dec 14, 2015 IPAA and Western Energy Alliance Joint Supplemental Comments to the Department of the Interior on its Proposed Revisions to Onshore Order No. 3, Site Security
Dear Director Kornze: Western Energy Alliance and the Independent Petroleum Association of America (IPAA), appreciate that the Bureau of Land Management (BLM) has reopened the comment period for Onshore Order No. 3. Onshore Order No. 3 is highly complex, technical, and closely interrelated with Onshore Orders No. 4 and 5, and we appreciate this opportunity to reflect on No. 3 now that we have had some time to review 4 and 5. However, we are concerned that the timeframe to review these three proposed rules remains inadequate at just 21 days of overlap, given the fact that they run to a combined total of 591 pages in length.