Letters & Comments

Infrastructure, Letters and Comments Nov 6, 2026

IPAA, the U.S. Chamber of Commerce and more than 500 additional organizations sent a coalition letter to members of the U.S. House and Senate supporting the Bipartisan American Affordability and Jobs Act of 2026. The letter demonstrates the broad, nationwide consensus behind comprehensive permitting reform.

“To the Members of the United States Congress:

On behalf of the undersigned organizations, we urge Congress to pass the Bipartisan American Affordability and Jobs Act of 2026, historic comprehensive permitting reform legislation, and send it to the President’s desk as soon as possible. At a time when affordability remains a top concern for American families, there is no greater opportunity to lower costs and improve everyday life than by ensuring needed projects, investments, and other activities can move forward in a timely, predictable, and transparent manner.

Communities across the country are waiting to invest in improvements that will make everyday life better and more affordable. From critical infrastructure and communications networks to natural resource management, water, and all kinds of energy projects, these investments will lower costs, strengthen the economy, create jobs, and improve quality of life in communities across the country. Yet far too often, these improvements are delayed for years by a broken permitting process that has become overly complex, unpredictable, and inefficient. …”

Infrastructure, Letters and Comments Oct 26, 2026

Dear Chairmen Capito and Lee, and Ranking Members Whitehouse and Heinrich:

On behalf of the companies that produce, transport, and deliver natural gas across the nation, the Natural Gas Council strongly supports S. 5653, the Bipartisan American Affordability and Jobs Act of 2026. We commend you for reaching a bipartisan agreement that represents meaningful progress toward a more efficient, predictable, and durable federal permitting process.

The Natural Gas Council commends your bipartisan leadership in advancing meaningful permitting reform. The Bipartisan American Affordability and Jobs Act represents an important opportunity to provide the certainty necessary to develop and modernize critical energy infrastructure while maintaining appropriate environmental safeguards.

Our nation’s energy needs continue to grow, and now is the time for the Senate to act. We urge the Senate to advance this legislation and stand ready to work with you and your colleagues to secure its enactment this Congress.

Infrastructure, Letters and Comments Oct 22, 2026

The Independent Petroleum Association of America (IPAA) joined with the American Petroleum Institute (API) and 136 organizations representing energy, labor, manufacturing, housing, transportation, infrastructure and businesses across the country in urging congressional leaders to bring the Bipartisan American Affordability and Jobs Act of 2026 (S. 5653) to the floor and pass comprehensive permitting reform before the end of the year.

In a letter to House and Senate leaders, the groups warned that lengthy permitting delays are driving up costs, holding back investment and slowing the infrastructure Americans need. The organizations called on Congress to seize a rare bipartisan opportunity to modernize the nation’s permitting system and strengthen economic competitiveness.

“With Americans focused on rising costs, permitting reform presents Congress with one of its most consequential opportunities to address affordability this Congress,” the groups wrote. “Modernizing the nation’s permitting system can help improve energy affordability, strengthen economic competitiveness, unlock investment, and restore confidence in the nation’s ability to build critical infrastructure.”

Infrastructure, Letters and Comments, Regulations Oct 13, 2026

IPAA joined the National Association of Manufacturers and other leading manufacturing and business organizations in sending a coalition letter urging Congress to swiftly pass the Bipartisan American Affordability and Jobs Act. Representing businesses across the country and industries throughout the manufacturing economy, the coalition called on lawmakers to advance the bipartisan permitting deal to reduce costly delays, provide greater certainty for investment and make it easier to build and expand manufacturing operations in America.

Infrastructure, Letters and Comments, Regulations Oct 9, 2026

IPAA as part of the Waters Advocacy Coalition (“WAC”) submits the following comments on the Environmental Protection Agency’s (“EPA”) and U.S. Army Corps of Engineers’ (“Corps”) (collectively, the “Agencies”) Supplemental Notice of Proposed Rulemaking (“SNPRM”) regarding the definition of “waters of the United States” (“WOTUS”) under the Clean Water Act (“CWA” or the “Act”), Updated Definition of “Waters of the United States.”1 The SNPRM supplements the Agencies’ November 20, 2025, Notice of Proposed Rulemaking, Updated Definition of “Waters of the United States,”2 (hereinafter “NPRM”) by proposing additional options for defining “continuous surface connection” and “relatively permanent.”

WAC represents a diverse cross-section of the nation’s business community, including construction, transportation, real estate, mining, manufacturing, forestry, agriculture, energy, recreational, wildlife conservation, and public health and safety sectors—all of which are vital to a thriving national economy and provide much-needed American jobs.4 WAC members are committed to both building modern, resilient infrastructure and protecting and restoring America’s wetlands and waters.

WAC appreciates the Agencies’ efforts to improve regulatory predictability and consistency by providing an additional option for clarifying the scope of WOTUS. As WAC noted in its comments on the NPRM, 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.”

Exports, Letters and Comments Sep 23, 2026

IPAA joined more than 50 U.S. business, energy and manufacturing groups from around the country in issuing a letter to President Trump urging him to reject calls to institute any kind of fuel export ban or limit.

The letter notes:

  • “Export bans would lead to less fuel production, tighter supplies, and rising costs for American families, farmers, and truckers.” 
  • “An export ban would require refineries to throttle utilization to reduce diesel production to equal domestic demand. Falling utilization would result in less gasoline and jet fuel production and higher prices for those products as well…This could not come at a worse time for consumers as home heating oil season is about to begin.” 
  • “Beyond price impacts, restricting exports would be a gift to our competitors. American energy dominance comes from being a reliable supplier to the world. If we pull back, other countries will step in, our influence will shrink, and our adversaries will gain ground.” 

Letters and Comments Sep 10, 2026

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

Days ago, catastrophic flooding in Grand Canyon National Park claimed human lives, forced large-scale evacuations, destroyed critical infrastructure, and closed lodging and campgrounds throughout the park. As families grieve lost loved ones and emergency crews work on the ground, Congress must turn its attention to the broader challenges facing public lands. Floods, wildfires, severe storms, and acts of vandalism have damaged visitor facilities, historic structures, trails, bridges, and infrastructure across the country. National parks, forests, wetlands, and other federally managed lands already face $46.2 billion in backlogged repairs, and destructive events in 2026 are adding to the burden.1

While Congress cannot prevent disasters caused by nature and man, it can ensure land managers have the resources necessary to repair infrastructure when damage occurs. Congress should act before the end of the session to reauthorize the Legacy Restoration Fund (LRF), a proven conservation program that repairs public lands infrastructure and reduces a growing backlog of maintenance needs. …

Federal Lands, Letters and Comments Aug 31, 2026

IPAA and the Western Energy Alliance (the “Associations”) represent many members who are responsible for the filing of the Federal production and royalty reports to the Office of Natural Resources Revenue (“ONRR”).

The following tenets underly the Associations’ comments that follow:

1. The Associations support Secretary Burgum’s efforts to repeal regulations that are burdensome and unneeded. The Associations support the Secretary’s efforts to make regulations clearer, more consistent, and more certain in their application.

2. The Associations agree that free markets are the best way to create jobs, provide energy, and increase the nation’s wealth. To further those goals, the Associations continue to believe that the Department’s decision in 1988 to use the gross proceeds from arm’s length contracts as the best indication of market value is still the correct approach to follow in royalty valuation.

3. The Associations welcome this rulemaking as an opportunity to correct ill-considered trends in recent years in ONRR’s valuation and enforcement practices. More specifically, ONRR has altered its interpretation of the rules in recent years through ad hoc decisions that lead to costly, long drawn out disputes. …

Federal Lands, Letters and Comments, Regulations Aug 24, 2026

Western Energy Alliance (Alliance), the Independent Petroleum Association of America (IPAA), Colorado Oil and Gas Association, Independent Petroleum Association of New Mexico, Montana Petroleum Association, New Mexico Oil and Gas Association, North Dakota Petroleum Council, Petroleum Association of Wyoming, Utah Petroleum Association, and West Slope Colorado Oil and Gas Association, collectively the Trades, appreciate the opportunity to comment on the Bureau of Land Management’s (BLM) proposal to modify its existing regulations pertaining to royalties due on oil and natural gas lost on Federal and Indian leases.

The Trades represent member companies who are engaged in the environmentally responsible development of oil and natural gas on BLM lands across the West. Our members will be directly impacted by this rulemaking and have a substantial interest in ensuring it aligns with BLM’s 2 of statutory authority and achieves the appropriate balance between environmental protection and energy development on federal lands. The Trades support the proposed updates, with some edits suggested , and urge BLM to expeditiously finalize the rule.

Federal Lands, Letters and Comments, Regulations Aug 24, 2026

Western Energy Alliance, the Independent Petroleum Association of America, Colorado Oil and Gas Association, Montana Petroleum Association, New Mexico Oil and Gas Association, North Dakota Petroleum Council, Petroleum Association of Wyoming, Utah Petroleum Association, and West Slope Colorado Oil and Gas Association, collectively the Trades, appreciate the opportunity to comment on the Bureau of Land Management’s (BLM) draft rule on Oil and Gas Leasing. The Trades support the proposed updates, with minor comments and edits suggested, and urge BLM to expeditiously finalize the rule.

If finalized, the draft rule would create a more streamlined onshore oil and gas leasing and permitting program, while maintaining environmental protections on federal lands. The rule would also make oil and natural gas development on federal lands more competitive with production on state and private lands, ensuring the costs to operate and timelines for development of federal acreage more closely resemble those on non-federal lands. The proposed changes appropriately reflect FLPMA’s requirement that BLM manage these lands for multiple and sustained yield of resources such as oil and gas.

As BLM’s website notes, production of federal minerals “accounted for approximately 15 percent of domestically produced oil and 9 percent of domestically produced natural gas” in the most recent year for which data are available. Thus, BLM’s management of the onshore oil and gas program is undoubtedly critical to ensuring our country’s energy dominance and national security. Once again, the Trades appreciate that BLM’s draft rule would help achieve those goals.

Our comments highlight support for specific changes in the proposal, provide details on why those changes are necessary, and offer suggestions on ways in which the rule could be strengthened or clarified, including in response to questions posed by BLM within the draft. The comments proceed section-by-section through the proposed rule, although not all of the sections necessitate a response. In lieu of repeating previous discussion of deficiencies with the 2024 Rule, the Trades also provide our prior comment letters as attachments at the end of this submission. …

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.