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Infrastructure, Letters and Comments, Regulations Sep 4, 2025

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

America’s economic competitiveness depends on our ability to build critical infrastructure quickly. With electricity demand surging from AI, manufacturing, and industrial growth, we need unprecedented levels of new energy production, transmission, and pipeline infrastructure—and we need it now.

Unfortunately, today’s permitting system was designed for a different era. While laws like the National Environmental Policy Act of 1969 (NEPA) were written with good intentions, they have evolved into procedural gauntlets. In the 1970s, the NEPA process for highway projects took a mean of 2.2 years to complete. The average time to complete an Environmental Impact Statement and obtain a Record of Decision now takes an average of almost 4 years. The full process is often further slowed because energy projects of all types run into a “litigation doom loop”, years of lawsuits and delay that create uncertainty and chill investment. These delays don’t improve environmental outcomes, but they do prevent America from building the infrastructure we need. …

Infrastructure, Letters and Comments Sep 3, 2025

Dear Chairman Lee and Ranking Member Heinrich,

On behalf of the organizations representing industries, companies, and individuals who depend on legally durable and timely regulatory decisions relating to energy infrastructure and markets, we write to urge the Senate Committee on Energy and Natural Resources to swiftly approve the Federal Energy Regulatory Commission (FERC or Commission) nominees to fill current vacancies.

The Commission plays a critical role in making certain that energy – from electricity, natural gas, and oil – is secure, reliable, and affordable. To fulfill this role, FERC must advance projects that modernize and expand America’s energy infrastructure, spur economic growth, and ensure reliability and affordability. …

Infrastructure, Letters and Comments Sep 3, 2025

Dear Chairmen Westerman and Graves and Ranking Members Huffman and Larsen,

On behalf of the companies who produce, transport, and deliver natural gas across the nation, the Natural Gas Council writes to urge you to work collaboratively to advance policies that would expedite permitting for critical energy infrastructure under key statutes. Importantly, Congress can reform processes that would establish timelines, clarify the scope of agency review, and reduce the uncertainty associated with judicial review without compromising the United States’ environmental protections.

More than 189 million Americans and nearly six million businesses use natural gas because it is safe, affordable, reliable and essential to improving our environment. Our nation’s natural gas industry is the fundamental underpinning of a growing U.S. economy, adding an additional customer every minute daily, and approximately 60 businesses begin new natural gas service every day. Moreover, U.S. electricity demand is projected to rise due to increased demand from various sectors and because of the re-shoring of manufacturing, and an expansion of AI and data centers. …

Infrastructure, Letters and Comments Sep 3, 2025

Dear Chairwoman Capito, Chairman Lee and Ranking Members Whitehouse and Heinrich,

On behalf of the companies who produce, transport and deliver natural gas across the nation, the Natural Gas Council writes to urge you to advance policies that would restore predictability to the permitting of essential natural gas infrastructure projects.

Permitting reforms for our energy infrastructure networks are crucial to meeting our reliability, affordability, and climate goals. More than 189 million Americans and nearly six million businesses use natural gas because it is safe, affordable, reliable and essential to improving our environment. Our nation’s natural gas industry is the fundamental underpinning of a growing U.S. economy, adding an additional customer every minute daily, and approximately 60 businesses begin new natural gas service every day. Moreover, U.S. electricity demand is projected to rise due to increased demand from various sectors and because of the re-shoring of manufacturing, and an expansion of AI and data centers. …

Infrastructure, Letters and Comments Sep 2, 2025

To the Members of the United States Congress:

We write to urge you to take meaningful and bipartisan action to pass comprehensive permitting reform. The time has come to modernize our nation’s permitting systems so that our communities can build the infrastructure necessary to grow our economy, create good-paying jobs, and meet the challenges of today and tomorrow.

Across the country, communities and businesses are ready to invest in projects that will strengthen our economy and improve quality of life—from expanding broadband access and upgrading transportation networks, to building innovative energy facilities that will provide new sources of power to meet growing demand, and modernizing drinking water systems. But too often, outdated and inefficient permitting processes stand in the way, delaying these investments and driving up costs.  …

Letters and Comments Aug 6, 2025

This letter provides comments from the American Petroleum Institute (“API”), American Fuel & Petrochemical Manufacturers (“AFPM”), GPA Midstream, and the Independent Petroleum Association of America (“IPAA”) (collectively, “the Associations”) in response to the U.S. Environmental Protection Agency’s (“EPA’s” or “the Agency’s”) request for information on revising the regulations for Section 401 of the Clean Water Act (“CWA”).

The Associations appreciate and support EPA’s May 21, 2025 memorandum, “Clarification regarding Application of Clean Water Act Section 401 Certification,” which clarifies that the statutory intent of Section 401 water quality certifications is to protect water quality.[1]  As explained in more detail below, the Associations encourage EPA to pursue a rulemaking that restores the previous 2020 final rule on Section 401 of the CWA. The procedural guardrails, timelines, and specific interpretation found in that rule would provide the regulatory certainty and consistency needed for project developers to receive permits in a timely fashion.

Letters and Comments, Regulations Aug 6, 2025

Subject: Comments on Section 401 State Water Quality Certification Open Docket; Docket ID No. EPA-HQ-OW-2025-0272

Dear Ms. Browne,

The undersigned organizations write to express strong support for continued improvements to the Clean Water Act (CWA) Section 401 certification process— ensuring that the possible changes to the regulation provide clarity, certainty, and regulatory durability.

Permitting reform is essential to advancing national economic growth and modernizing critical infrastructure, while maintaining the environmental protections that are central to EPA’s mission. Efficient, transparent permitting processes help accelerate the deployment of energy, transportation, and water infrastructure— driving job creation and resilience in communities across our nation. Clean Water Act Section 401 state certifications play a foundational role in this framework, ensuring that states and tribes have a meaningful voice in reviewing that federally permitted projects comply with water quality standards. Strengthening coordination and certainty around Section 401 certifications can enhance both environmental outcomes and permitting efficiency, supporting EPA’s goals of protecting water resources, while enabling timely infrastructure investment.

Infrastructure, Letters and Comments, Regulations Jul 29, 2025

Dear Chairman Westerman:

As a coalition of oil and natural gas trade associations representing over 80 percent of domestic oil and natural gas production in the United States, we write in strong support of the “Standardized Permitting and Expediting Development Act” (SPEED Act) and thank you and all the sponsors for introducing this important legislation. The bipartisan nature of this legislation is both important in a divided and polarized political environment and essential to get this bill across the legislative “finish line.”

Reforming the nation’s outdated permitting system is key to the success of the American economy. The SPEED Act addresses many of the most critical issues surrounding the National Environmental Policy Act (NEPA) and makes commonsense reforms to the law. …

Infrastructure, Letters and Comments Jul 29, 2025

The Independent Petroleum Association of America (IPAA) submits the following comments regarding PHMSA’s advanced notice of proposed rulemaking (ANPRM) regarding Pipeline Safety Regulations. IPAA members are the primary producers of the nation’s natural gas and oil, accounting for 90 percent of America’s natural gas production and 83 percent of its oil output. Independent producers remain a driving force in our economy and support millions of jobs in the United States.

Although there are a variety of important issues facing independent producers regarding pipeline safety issues, IPAA wants to raise several specific issues outlined below…

Letters and Comments, Methane Jul 25, 2025

RE: RIN:2060-AW261: Extension of Deadlines in Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review.

Dear Administrator Zeldin and Deputy Administrator Fatouhi,

We are writing on behalf of the Domestic Energy Producers Alliance (DEPA) and the Independent Petroleum Association of America (IPAA). Our member companies urgently request that EPA promptly extend the compliance deadline for submitting the annual report under EPA’s Oil and Gas Methane Rule, which is currently due on August 5, 2025. The EPA can accomplish this by promptly issuing a Federal Register notice extending the current annual reporting deadline, or by issuing a direct final rule to extend the annual reporting deadline for one year under its general authorities.

This extension is not only necessary but also crucial to enable the EPA to align its plans for the Methane Rule with other related actions taken by the Agency and Administration regarding the growth of the energy sector and the return of power to the States. It would also be consistent with the stay of the litigation challenging the Methane Rules in the D.C. Circuit, Court of Appeals, obtained by EPA based on EPA’s announcement that it is reconsidering the Methane Rule.

The first annual report under the Methane Rule is due August 5. However, the process of collecting the data and preparing these reports is highly onerous and resource-intensive, imposing significant burdens on American energy producers. …

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.