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Letters & Comments

Letters and Comments, Offshore Jul 11, 2025

Dear Chair Graves and Ranking Member Larsen:

President Trump’s directive that the U.S. government “unleash American energy” (Executive Order 14154) has helped set the country on a course of global energy dominance. Congress plays a significant role in advancing this important agenda, and the U.S. Outer Continental Shelf (OCS) is a critical component in this energy dominance strategy. Approximately 1 of every 6 barrels produced domestically comes from the OCS, along with more than 300,000 jobs for American workers, and billions of dollars in state and federal taxes and royalty revenues. Offshore energy development is an irreplaceable strategic asset for America’s national security, which is why it is so important that U.S. policy supports growing access to, and production of, oil and natural gas in the Gulf of America.

As the Committee prepares to consider the HR 4275, the Coast Guard Authorization Act of 2025, we want to caution against the inclusion of language that could hinder the goal of energy dominance, specifically in the Gulf of America. In the last several Coast Guard reauthorization bills, the House of Representatives has included language from a bill introduced in past Congresses called The American Offshore Worker Fairness Act, which would place stifling and unreasonable restrictions on the limited number of highly specialized vessels needed for exploration, to construct new and expanding Gulf of America oil and natural gas projects and to effectively maintain existing production. The language would effectively eliminate the ability to use these vessels and the well-trained and highly experienced crew that accompany them because they are foreign-owned and foreign-flagged. …

Letters and Comments Jul 10, 2025

Dear Leader Thune, Leader Schumer, Chairman Lee, and Ranking Member Heinrich:

We write to express our gratitude for the Senate’s confirmation of President Donald Trump’s picks to lead the Department of the Interior (DOI) – Secretary Doug Burgum and Deputy Secretary Katharine MacGregor – and to express our strong support for the expeditious consideration of all remaining DOI nominees who are currently awaiting Senate floor action. …

Endangered Species, Letters and Comments Jul 9, 2025

The American Petroleum Institute (“API”), the American Exploration and Production Council (“AXPC”), the Independent Petroleum Association of America (“IPAA”), GPA Midstream Association, Marcellus Shale Coalition, the North Dakota Petroleum Council (“NDPC”), the Petroleum Alliance of Oklahoma, the Texas Oil and Gas Association (“TXOGA”), and Utah Petroleum Alliance (“UPA”) (collectively, the “Associations”) appreciates the opportunity to provide comments in response to the Fish and Wildlife Service’s (“FWS” or “the Service”) request for information (“RFI”) issued on June 9, 2025. This RFI sought feedback on improvements to the development and implementation of survival permits associated with Conservation Benefit Agreements (CBAs) and Incidental Take Permits (ITPs) associated with Habitat Conservation Plans (HCPs) under Section 10(a) of the Endangered Species Act (ESA). We appreciate the Trump Administration’s desire to achieve a meaningful reduction in regulatory burdens while continuing to meet statutory obligations, advance American energy independence, and ensure the responsible stewardship of the nation’s public lands and resources. …

Voluntary conservation agreements such as HCPs and CBAs are helpful mechanisms to minimize impacts to species and habitat and contribute to overall species conservation goals, while avoiding unwarranted access restrictions that could obstruct national energy security objectives. A significant value of these plans lies in their ability to streamline or even proactively preempt the often-lengthy Incidental Take Permit process, a benefit that works both in favor of industry and the Service. Though not applicable in all situations and for all species, the Associations’ members already successfully leverage various CBAs and HCPs for species such as the Dunes Sagebrush Lizard, the Lesser Prairie Chicken, the Texas Hornshell Mussel, and the Monarch Butterfly. Critical learnings from these initiatives can be applied to future conservation plans, as per the suggestions delivered below. …

 

Infrastructure, Letters and Comments Jul 7, 2025

Chairman and Commissioners:

On behalf of the thousands of companies who produce, transport, and deliver natural gas to the 189 million Americans and 5.8 million businesses that use it, the Natural Gas Council writes the following in reference to Docket No. AD25-7-000, “Meeting the Challenge of Resource Adequacy in Regional Transmission Organization and Independent System Operator Regions,” and in response to the Commissioner-led technical conference that occurred on June 4-5, 2025.

It was apparent during the conference discussion that ensuring reliable natural gas supply is a critical component underpinning resource adequacy. …

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.

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.