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Letters & Comments

Letters and Comments, Offshore Jan 23, 2026

The American Petroleum Institute (“API”), National Ocean Industries Association (“NOIA”), Independent Petroleum Association of America (“IPAA”), U.S. Oil and Gas Association (“USOGA”), Louisiana Mid-Continent Oil and Gas Association (“LMOGA”), American Exploration & Production Council (“AXPC”), International Association of Drilling Contractors (“IADC”), EnerGeo Alliance (“EnerGeo”), Energy Workforce & Technology Council (“EWTC”), and the Offshore Operators Committee (“OOC”) (“the Associations”) offer the following comments on the Bureau of Ocean Energy Management’s (“BOEM”) request for comments on the 11th National Oil and Gas Leasing Draft Proposed Program (“DPP” or “Draft Proposed Program”) published in the Federal Register on November 24, 2025. The Associations’ members have significant interest in ensuring that there are future opportunities for offshore oil and natural gas exploration and development in the United States (“U.S.”) so that the nation can capitalize on industry expertise that has been garnered through years of successful and beneficial exploration, development and production of domestic outer continental shelf (“OCS”) oil and natural gas resources.

We fully support keeping the Draft Proposed Program acreage as is with no additional areas being removed from future leasing consideration. Considerable acreage has already been excluded in the development of the Draft Proposed Program, particularly in the Atlantic. The decisions made regarding what areas are available for leasing provide opportunities, particularly in the South-Central Gulf of America planning area, will have beneficial long-term implications for our nation’s energy security, national security, prospects for job creation, and government revenue generation.

Letters and Comments, Offshore Jan 23, 2026

As you prepare the 11th National Offshore Leasing Program, we commend the Department of the Interior (DOI) for proposing a robust lease sale schedule in planning areas throughout the Outer Continental Shelf. We appreciate that the proposal includes traditional production regions where production has some of the lowest carbon footprint in the world, areas close to existing infrastructure, and frontier areas. Expanding leasing, exploration and development of U.S. offshore oil and natural gas resources can drive economic growth and energy production, further strengthening American energy leadership.

Currently, offshore energy development accounts for approximately 14% of total U.S. crude oil production and 2% of natural gas production. Offshore exploration and production activities support high-paying jobs and help meet growing demand for affordable, reliable energy. In addition, U.S. offshore oil produces some of the lowest carbon intensity barrels in the world.1 A robust offshore leasing program can helpfully leverage the nation’s vast energy resources to provide affordable energy, fund critical government programs, and enhance stability around the world. In addition, unlocking the nation’s energy resources benefits all sectors of the economy, allowing businesses of all sizes to create jobs and build opportunities.

As development of the 11th National Offshore Leasing Program advances, we urge DOI to retain lease sales in frontier areas and to continue offering leasing opportunities in traditional production regions, ensuring the nation can fully realize the potential of U.S. offshore oil and natural gas exploration, development, and production. …

Letters and Comments, Methane, Regulations Jan 6, 2026

Re: Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems, Docket No. EPA-HQ-OAR-2023-0234

The Independent Petroleum Association of America (IPAA) submits this letter to address uncertainties caused by the underlying reconsideration of Subpart W in the Greenhouse Gas Reporting Program (GHGRP). IPAA is a national trade association that represents oil and natural gas producers and their support industries, including thousands of low production well producers.

Letters and Comments, Regulations Jan 5, 2026

Dear Environmental Protection Agency and Army Corps of Engineers:

This letter provides comments from the American Petroleum Institute (“API”), the Independent Petroleum Association of America (“IPAA”), the Petroleum Alliance of Oklahoma, the Petroleum Association of Wyoming (“PAW”), and the Western States’ Petroleum Association (“WSPA”) in response to the U.S. Environmental Protection Agency’s (“EPA’s”) and the Army Corps of Engineers’ (“Army Corps”) (collectively “the Agencies’”) proposed revisions (“Proposed Revisions”) to the definition of “Waters of the United States” (“WOTUS”).

We appreciate the Agencies’ commitment to fully incorporating the jurisdictional limits Congress imposed through the Clean Water Act (“CWA” or “the Act”) and the broad interpretive guideposts provided by the United States Supreme Court (“Supreme Court” or “the Court”). We believe that our additional clarifying changes further goals we share with the government — developing an interpretation of WOTUS that is clear, protective of the environment and human health, administrable, and legally sound. …

Letters and Comments, Regulations Jan 5, 2026

The Waters Advocacy Coalition (“WAC”) offers the following comments on the Environmental Protection Agency’s (“EPA”) and U.S. Army Corps of Engineers’ (“Corps”) (collectively, the “Agencies”) proposed revised definition of “waters of the United States” (“WOTUS”) under the Federal Water Pollution Control Act, as amended, also known as the Clean Water Act (“CWA” or “Act”),1 Updated Definition of “Waters of the United States,” 90 Fed. Reg. 52,498 (Nov. 20, 2025) (hereinafter, “Proposed Rule”). WAC appreciates the Agencies’ efforts to improve regulatory predictability and consistency by further clarifying the scope of WOTUS. When Congress enacted the CWA, it exercised its commerce power over navigation and specifically granted the Agencies the power to regulate “navigable waters,” which the CWA defines as “waters of the United States.”

Infrastructure, Letters and Comments Dec 16, 2025

Dear Members of the U.S. House of Representatives:

The undersigned organizations write to express strong support for the passage of H.R. 4776, the “Standardizing Permitting and Expediting Economic Development Act,” or the “SPEED Act.” By modernizing the permitting process, this legislation will help advance infrastructure, energy, natural resource, transportation, and other projects that improve quality of life, revitalize communities, and deliver the goods and services families rely on every day.

Unfortunately, today’s permitting system is burdened by delays, uncertainty, and duplicative reviews that stall investment and innovation, leaving critical projects in limbo for years. The SPEED Act offers common-sense reforms that address these challenges. It helps focus environmental reviews where they matter, promotes project certainty through requiring clear timelines, and improves coordination among federal agencies to reduce redundant reviews. These reforms and others in the bill will not only improve permitting efficiency but also help businesses to plan and invest with confidence, creating jobs, strengthening supply chains, and advancing U.S. leadership in energy, manufacturing, technology, and beyond. …

Infrastructure, Letters and Comments Dec 12, 2025

Dear Mr. President,

As leaders of America’s foremost energy trade associations, we write to express our strong support for the Standardizing Permitting and Expediting Economic Development (SPEED) Act and to respectfully urge the Administration to prioritize its advancement.

The undersigned associations represent the vast majority of U.S. oil and gas companies and the full supply chain that produces the energy Americans rely on every day, energy that powers homes, businesses, transportation, and national infrastructure. By supporting domestic energy development, we also lift communities, strengthen families, and sustain American industries, creating economic and societal benefits that lift every part of the country.

Modernizing federal permitting is essential to achieving the Administration’s stated goals of restoring American energy dominance, strengthening domestic industry, and accelerating major U.S. infrastructure and energy investment. …

Letters and Comments, Steel & Aluminum Tariffs Dec 10, 2025

Dear Members of the United States House and Senate,

We are writing to express urgent concern regarding the impact of tariffs on steel, aluminum, and other imported materials on the U.S. oilfield services (OFS) sector—a cornerstone of American energy leadership and industrial strength. …

To safeguard American energy leadership, jobs, and supply chain resilience, we urge Congress to:

  • Reinstate and expand the Section 232 tariff exclusion process for critical energy components.
  • Exempt OCTG, valves, and essential oilfield equipment from tariff lists.
  • Support policies that promote domestic production and workforce retention of the 650,000 jobs in the OFS sector.

Infrastructure, Letters and Comments, Regulations Dec 10, 2025

Dear Speaker Johnson and Leader Jeffries,

On behalf of the companies who produce, transport and deliver natural gas across the nation, the Natural Gas Council writes in support of H.R. 3898, the Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act and H.R. 3668, the Improving Interagency Coordination for Pipeline Reviews Act. These proposals would provide expedited permitting and improve regulatory certainty for gas pipeline infrastructure under the National Environmental Policy Act of 1969 (NEPA) and the Clean Water Act (CWA). …

Letters and Comments, Methane Dec 3, 2025

IPAA and a coalition of eight other energy trade organizations sent a letter urging House leadership to pass Representative Westerman’s H.R.4776 – Standardizing Permitting and Expediting Economic Development (SPEED) Act.


“Dear Speaker Johnson and Democratic Leader Jeffries,

“Across our country, American families and businesses need more affordable energy. It is more important than ever that Washington act soon to cut red tape and lower prices for consumers. On behalf of our combined industries—which supply a majority share of the energy infrastructure that powers America’s economy—we write to express strong support for H.R. 4776 the Standardizing Permitting and Expediting Economic Development (SPEED) Act. This bipartisan legislation takes critical steps to reforming a permitting system that too often chills investment, creates uncertainty, and increases costs and delays for essential energy infrastructure projects. … “

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.