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Letters & Comments

Letters and Comments, Offshore Jun 16, 2025

The Independent Petroleum Association of America (IPAA), American Petroleum Institute (API), National Ocean Industries Association (NOIA), Offshore Operators Committee (OOC), U.S. Oil and Gas Association (USOGA), American Exploration & Production Council (AXPC), International Association of Drilling Contractors (IADC), EnerGeo Alliance, Energy Workforce and Technology Council, and the Louisiana Mid-Continent Oil and Gas Association (LMOGA) (collectively, the Associations), offer the following comments on the Bureau of Ocean Energy Management’s (BOEM) request for information and comments on the preparation of the 11th National Outer Continental Shelf (OCS) Oil and Gas Leasing Program (National Program) published in the Federal Register on April 30, 2025.

Letters and Comments, Regulations Jun 16, 2025

Although there are a variety of important issues facing independent producers on offshore and onshore federal lands, IPAA wants to raise three specific issues the Trump Administration is working on that are of vital importance to our members. These issues are outlined below:

1. Revising the Risk Management and Financial Assurance Rule for OCS Lease and Grant Obligations

2. Rescission of the Conservation and Landscape Health Rule

3. Permitting Reform

Letters and Comments, Offshore Jun 16, 2025

IPAA joined the American Petroleum Institute and more than 100 other energy trade groups and organizations in urging the Department of the Interior to develop a new five-year offshore leasing program that fully leverages the U.S. Outer Continental Shelf as a secure source of affordable, reliable energy.

“Revising the 5-year offshore leasing program to take full advantage of our rich offshore resources through expanded access and development in the Gulf of America, Alaska, Pacific, and Atlantic will help sustain America’s growing energy advantage for decades to come,” the groups wrote in comments to Interior’s Bureau of Ocean Energy Management (BOEM).

Infrastructure, Letters and Comments May 12, 2025

Dear Representative Fedorchak:

The undersigned organizations are pleased to provide our views in response to your AI and Energy Working Group’s recently circulated Request for Information. We represent companies and workers who build and provide equipment, materials, supplies and services to energy infrastructure development, including facilities essential to natural gas production, transportation and consumption. We comprise the vast industrial and labor supply chain that underpins American energy abundance, reliability and affordability.

We applaud and stand ready to support your critical work to develop legislative and policy recommendations to ensure that abundant power is available to support data centers critical to American AI dominance.

Long-term policy durability enshrined in law is critically essential to encourage large, long- term, multi-year investments by developers of energy infrastructure. Our comments below primarily address Pillar One of your Request for Information: American Energy Dominance and AI Energy Demands.

Letters and Comments, Taxes May 12, 2025

Dear Speaker Johnson, Majority Leader Thune, Leader Jeffries, and Leader Schumer:

We, the undersigned organizations, representing thousands of businesses who collectively employ millions of Americans in all sectors of the U.S. economy, urge Congress to immediately enact three specific pro-growth tax relief proposals in the upcoming reconciliation bill authorized by H.Con.Res.14, the fiscal year 2025 budget resolution. …

We strongly urge Congress to bolster our economy and support American workers and families. Congress should restore immediate R&D expensing, a pro-growth interest deductibility standard, and full expensing for capital investments.

Letters and Comments May 2, 2025

We write to you today as a coalition of oil and natural gas trade associations representing over 80% of domestic production in the United States to express our strong support for the budget reconciliation provisions currently under consideration by the House Natural Resources Committee. We stand ready to offer our full assistance in fulfilling President Donald J. Trump’s goals to unleash American energy and strengthen the economic future of the United States.

We strongly agree with the President that the success of the American economy and the prosperity of its citizens depend on the ability of our members to prudently access and develop the abundant energy resources with which our nation has been so generously blessed.

The budget reconciliation provisions under consideration are critical to advancing this shared goal. Our coalition advocated tirelessly during the Biden Administration for a return to regularly held federal lease sales, common-sense permitting reform, and unleashing American resources. These provisions, included in the House Natural Resources bill text will increase domestic energy production allowing for affordable and reliable energy to all Americans. …

Letters and Comments, Taxes Apr 22, 2025

Dear Speaker Johnson and Majority Leader Thune:

On behalf of America’s independent oil and natural gas producers, the Independent Petroleum Association of America (IPAA) urges you to help preserve the current tax treatment of carried interest to protect energy investment, support job creation, and ensure the continued growth of a resilient, domestically powered energy economy. …

The carried interest structure is a well-established mechanism that rewards long-term investment and risk-taking. It is particularly critical in the oil and natural gas industry, where smaller, independent companies often partner with private equity investors to raise the capital needed to explore, drill, and produce America’s energy resources. Nowhere is this model more embedded-or more vital-than in the Gulf Coast states, where these partnerships drive innovation, economic growth, and energy resilience. …

Letters and Comments, Methane, Taxes Apr 4, 2025

Dear Speaker Johnson and Majority Leader Thune:

We, the undersigned, congratulate you on the recent passage of H.J. Res 35, expressing Congress’s disapproval of the Environmental Protection Agency’s (EPA) rulemaking on the Waste Emissions Charge (WEC).

Passage of this Congressional Review Act (CRA) resolution, signed by President Trump, is an important step toward rectifying a disastrous approach to regulating methane emissions stemming from oil and natural gas production by eliminating the administrative means to collect the tax.

However, that was just step one. It is critically important to repeal the WEC, which was established in the 2022 Inflation Reduction Act (IRA) and remains federal law.

While the CRA removed the ability of EPA to charge for methane emissions, and collect the tax for now, the legal authority for doing so in the future remains, and it is imperative that Congress address this matter as soon as possible. …

IPAA is the industry's strongest presence in the nation's capital and these are important times. The entire oil and gas industry remains under fire from anti-development groups; but with these challenges arise unique opportunities that IPAA is seizing for our members.