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Federal Lands, Letters and Comments, Regulations Apr 2, 2026

To Whom It May Concern:

The American Petroleum Institute (“API”), Independent Petroleum Association of America (“IPAA”), Alaska Oil and Gas Association (“AOGA”), Colorado Oil and Gas Association (“COGA”), Montana Petroleum Association (“MPA”), New Mexico Oil and Gas Association (“NMOGA”), North Dakota Petroleum Council (“NDPC”), the Petroleum Alliance of Oklahoma, the Petroleum Association of Wyoming, and the Western States Petroleum Association (“WSPA”)— collectively “The Associations” — respectfully submit the following coalition comments on the Bureau of Land Management’s (“BLM”) proposed Requirements for Site Security and Production Handling; Applying for Commingling and Allocation Approval (“Proposed Rule”) that was published in the Federal Register on January 30, 2026. This letter contains both our substantive comments and a suggested redline of regulatory text (Attachment 1). On March 2, 2026, the API and ten industry partners submitted comments to the BLM in response to the Office of Management and Budget’s Information Collection Request (“ICR”) pertaining to the revised information collection requirements in the Proposed Rule. …

Federal Lands, Letters and Comments Mar 19, 2026

Dear Representative Kennedy:

On behalf of the undersigned trade associations representing companies that invest in and develop energy resources on federal lands, we strongly support your bill to reauthorize the Permit Processing Improvement Fund (PPIF) and respectfully urge Congress to enact a straightforward extension of the PPIF Fee Account before September 30, 2026.

Federal Lands, Letters and Comments Feb 25, 2026

Dear Chairman Lee and Ranking Member Heinrich:

As a coalition of trade associations that represent the hardworking men and women who collectively produce approximately 80% of our nation’s oil and natural gas, we strongly support Steve Pearce’s nomination by President Donald Trump to be the next director of the Bureau of Land Management (BLM), and we urge the U.S. Senate to quickly approve his confirmation.

While we celebrate America 250 and remember our nation’s founding, we also reflect upon the vast expansion beyond the original 13 states that came following the fight for independence. The legacy of which is overseen by BLM, the nation’s largest public lands management agency. Often referred to as the Nation’s Largest Landlord, BLM is responsible for managing 245 million acres of multiple-use public lands and 700 million acres of subsurface mineral estate. BLM’s public lands are predominantly within 12 western states, but it also oversees parcels and minerals across all 50 states. Altogether, these vital lands are set aside for the good of the American public, and they contribute to the food, fiber, fuel, and fun that sustain our nation. …

Federal Lands, Letters and Comments Feb 25, 2026

Dear Chairman Lee and Ranking Member Heinrich:

We write to express our strong support for the nomination of Former Congressman Steve Pearce to serve as Director of the Bureau of Land Management (BLM), and we respectfully urge the Committee to advance his nomination and facilitate timely consideration and confirmation by the Senate.

As trade associations representing America’s oil and natural gas producers and the broader upstream energy sector, we recognize the central role that the BLM plays in administering the federal onshore oil and gas program and managing the federal mineral estate. Leadership of this agency is critical to ensuring that the Department of the Interior (DOI) can effectively carry out its statutory multiple-use mission while supporting responsible energy development, economic growth, and national security. …

Infrastructure, Letters and Comments Feb 23, 2026

IPAA joined hundreds of national, regional, state and local organizations in a coalition letter sent to the Members of the United States Senate in support of permitting reform. The initiative was led by the United States Chamber of Commerce.

“On behalf of the undersigned organizations, we urge you to prioritize and pass bipartisan, comprehensive permitting reform legislation as early this year as possible. Communities across America are counting on Congress to deliver a modernized, efficient, predictable, and transparent permitting process—one that provides the project certainty needed to secure investment today, unlock economic growth, and foster innovation that creates opportunity and a stronger future for families and neighborhoods. …”

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.”

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.