Letters & Comments

Letters and Comments May 21, 2018

This letter provides comments from the American Petroleum Institute (“API”), Association of Oil Pipe Lines (“AOPL”), American Exploration & Production Council (“AXPC”), Independent Petroleum Association of America (“IPAA”), the Domestic Energy Producers Alliance (“DEPA”), and the Marcellus Shale Coalition (“MSC”) – (collectively, “the Associations”), responding to the Environmental Protection Agency’s (“EPA’s” or “The Agency’s”) Request for Comments on Clean Water Act (“CWA” or “the Act”) Coverage of “Discharges of Pollutants” via a Direct Hydrologic Connection to Surface Water. The Associations appreciate that EPA opened this comment period. Our members share EPA’s concern that seemingly contradictory Agency guidance and conflicting case law have blurred the Act’s conspicuous delineation between those point source discharges to jurisdictional waters that require CWA permits, and releases to groundwater that do not require CWA permitting.

Letters and Comments May 18, 2018

We strongly urge the Department of Commerce to finalize its Rule as soon as possible to minimize disruptions to business and to American job creation, and to realize the Administration’s goal of achieving “energy dominance,” which necessarily relies on complex interwoven global supply chains of specialty steel and other products. Impediments to developing, transporting, refining and distributing domestic oil and gas resources could reduce supplies of critical fuels used by consumers, the U.S. military, and manufacturers, which could have the unintended consequence of negatively affecting the national security upon which these tariffs are premised.

Letters and Comments May 17, 2018

This letter urges you to refrain from imposing any action under the Department of Energy’s emergency authorities to provide economic support favoring a particular class of power plants, as urged by First Energy Solutions and its affiliates. It is submitted on behalf of the Independent Petroleum Association of America (IPAA), the American Exploration & Production Council (AXPC), the Association of Energy Service Companies (AESC), the International Association of Drilling Contractors (IADC), and the following organizations.

Letters and Comments May 17, 2018

These comments are filed on behalf of the Independent Petroleum Association of America (IPAA). The Bureau of Industry and Security solicited comments on the implications of actions taken by the Trump Administration with regard to tariffs and limitations on steel imports. In March, the Trump Administration initiated new imported steel and aluminum tariffs under the authority of Section 232 of the Trade Expansion Act of 1962. The scope of these tariffs impacts American oil and natural gas producers. The implications are numerous.

Letters and Comments May 17, 2018

These comments are submitted by the Alliance for Competitive Steel and Aluminum Trade (IPAA is a cosigner) on the interim final rule (the Interim Regulations) which amend the National Security Industrial Base Regulations (the Existing Regulations). The amendments set forth a process for U.S. companies to submit requests for exclusions from actions taken by the President under Presidential Proclamations 9704 and 9705, both dated March 8, 2018 (the Proclamations), as amended, which place additional tariffs on certain imports of steel and aluminum products pursuant to Section 232 of the Trade Expansion Act of 1962, as amended (Section 232).

Letters and Comments May 8, 2018

In proposing withdrawal of the Control Techniques Guidelines for the Oil and Natural Gas Industry (CTG), EPA states: “On June 5, 2017, the EPA granted reconsideration in regard to additional provisions of the 2016 NSPS1. Pursuant to those actions, the EPA is currently looking broadly at the 2016 NSPS. In light of the fact that the EPA is reconsidering the 2016 NSPS and because the recommendations made in the CTG are fundamentally linked to the conclusions in the 2016 NSPS, the EPA believes it is prudent to withdraw the CTG in its entirety. The EPA also believes that the withdrawal will be more efficient for states in revising their state implementation plans (SIPs).” We strongly support EPA’s proposed action for this and other reasons.

Letters and Comments Apr 23, 2018

To Whom it May Concern: Western Energy Alliance (the Alliance) and the Independent Petroleum Association of America (IPAA) appreciate the opportunity to provide comments on the Bureau of Land Management’s (BLM) proposed revisions of certain provisions of the Methane and Waste Prevention rule, or 2016 rule. The 2016 rule as promulgated exceeded BLM’s authority under the Mineral Leasing Act (MLA), and that the decision to re-evaluate the rule is required. The proposed revision rule more accurately captures the scope of BLM’s waste minimization authority, and will better ensure federal mineral interests are adequately protected without excessively burdening federal lands development with overreaching regulations.

Letters and Comments Apr 18, 2018

Dear Mr. Kudlow: The Independent Petroleum Association of America (IPAA) congratulates you as you assume the directorship of the National Economic Council. IPAA is the leading, national upstream trade association representing thousands of independent oil and natural gas producers and their service companies across the United States. Independent producers develop 95 percent of the nation’s oil and natural gas wells. These companies account for 54 percent of America’s oil production, 85 percent of its natural gas production, and support over 2.1 million American jobs.

Letters and Comments Apr 10, 2018

Dear Mr. President: The United States is now the leading natural gas producer in the world. Greater use of natural gas here in the U.S. and through LNG exports can yield tremendous benefits to our economy. The key to realizing the full value of natural gas is the continued development of a robust natural gas infrastructure along the entire value chain so that natural gas can be delivered wherever and whenever it is needed. The need for new energy infrastructure has never been more important, as new natural gas supplies present new opportunities for our economy to take advantage of this abundant and low-cost energy resource.

Letters and Comments Apr 9, 2018

Dear Leaders McConnell and Schumer: The Independent Petroleum Association of America (IPAA) supports the nomination of Andrew Wheeler to be Deputy Administrator at the Environmental Protection Agency and looks forward to the advancement of his nomination to the full Senate for consideration.

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.