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Letters & Comments

Letters and Comments Apr 15, 2019

“This letter provides comments from the American Petroleum Institute (“API”), the Independent Petroleum Association of America (“IPAA”), the American Exploration and Production Council (“AXPC”), and the Association of Oil Pipe Lines (“AOPL”) (collectively, “the Associations”) in support of the U.S. Environmental Protection Agency’s (“EPA’s”) and the U.S. Army Corps of Engineers’ (“Army Corps’”) (collectively, “the Agencies”) Proposed Rule to Define “Waters of the United States” (“WOTUS”) (“Proposed WOTUS Rule”).1 The Associations welcome the Agencies’ commitment to transparent rulemaking and effective stakeholder engagement, and appreciate the opportunity to provide these comments and recommendations…”

Letters and Comments Apr 15, 2019

In comments filed by the Waters Advocacy Coalition, IPAA joined a large cross-section of the nation’s construction, transportation, real estate, mining, manufacturing, forestry, agriculture, energy, wildlife conservation, and public health and safety sectors supporting EPA’s step in realigning the WOTUS definition with Congress’s intent for the scope of federal jurisdiction under the Clean Water Act.

“The Waters Advocacy Coalition (“WAC” or “Coalition”) writes to provide comments on the Environmental Protection Agency’s (“EPA”) and U.S. Army Corps of Engineers’ (“Corps”) proposed rule to revise the definition of “waters of the United States” (“WOTUS”) under the Clean Water Act (“CWA” or the “Act”), 84 Fed. Reg. 4154 (Feb. 14, 2019) (the “proposed rule”). WAC appreciates the agencies’ efforts to increase predictability and consistency by clarifying the scope of WOTUS regulated under the Act. In enacting the CWA, Congress exercised its commerce power over navigation and granted EPA and the Corps (together, the “agencies”) specific, limited powers to regulate “navigable waters,” defined in the CWA as “waters of the United States.” For years, the agencies’ regulations and guidance documents have attempted to expand the WOTUS definition beyond its constitutional and statutory limits, and this proposed rule is an important step in re-aligning the WOTUS definition with Congress’s intent for the scope of federal jurisdiction under the Act. The proposed rule gives meaning to the term “navigable” and recognizes that a defining feature of the CWA is to preserve the states’ traditional and primary authority over land and water use, attempting to restore the appropriate balance between state and federal oversight authority in this area…”

Letters and Comments Apr 11, 2019

IPAA submitted April 15 comments jointly with API and NGSA in an ISO-New England proceeding at FERC (Docket No. ER19-1428).

The comments support ISO-New England’s proposed Inventoried Energy Program and its recognition of the “essential role that natural gas-fired generation resources play in supporting fuel security by including them as eligible recipients of inventoried energy payments.” It is important for natural gas producers, electricity consumers, and electric grid reliability for the organized electric markets to ensure that “all resources have the opportunity to compete on a level playing field and be appropriately compensated for the service they provide.”

Letters and Comments Apr 4, 2019

In an April 2 letter, IPAA joined with the Interstate Natural Gas Association of America, National Association of Manufacturers, Natural Gas Supply Association, and the Global Energy Institute of the U.S. Chamber of Commerce to urge the National Governors Association (NGA) to work with the Administration to clarify the permitting process under Sec. 401 of the Clean Water Act.  The signatories build or support infrastructure that has been thwarted by the overreach of certain state agencies in denying permits for water crossings under Sec. 401.  The letter stresses that Sec. 401 calls for cooperative federalism, with distinct roles for federal and state governments in certifying federally-permitted or licensed activities.  NGA is encouraged “to clarify and align legal precedent with clearer implementation of Sec. 401” to allow for “continued protection of water quality while maintaining the partnership between states and the federal government.”

Letters and Comments Mar 22, 2019

Dear Administrator Wheeler:

The consent decree driven deadline is approaching for the U.S. Environmental Protection Agency (EPA) to decide whether it needs to take steps under Subtitle D of the Resource Conservation and Recovery Act (RCRA) with regard to oil and gas production wastes. The American Petroleum Institute (API) and the Independent Petroleum Association of America (IPAA) continue to believe that state regulatory programs properly and effectively manage these wastes. Consequently, the two organizations believe EPA should conclude that additional federal action under Subtitle D is unnecessary and could be counterproductive…

Letters and Comments Mar 11, 2019

IPAA joined with API, INGAA, and NGSA in March 7 comments to PJM Interconnection, LLC (PJM) on its Valuing Fuel Security Initiative.  The initiative is part of PJM’s ongoing fuel security study, which has indicated that PJM’s system is “reliable today and will remain reliable into the future,” even with increased reliance on natural gas generation.  However, the reliability and resiliency of natural gas for electric generation continue to be targeted by groups that would advance coal and nuclear generation at the expense of natural gas.

In the joint comments, the associations urged PJM to: (1) provide time for a more deliberative process; (2) avoid assumptions about what market and operation changes, if any, will result from the task force efforts; (3) revise the review parameters to encompass all risks that threaten electric grid stability, not just fuel security; (4) explain why current reserve margin levels and successful capacity performance program are insufficient for addressing outages that may occur with increased reliance on natural gas; (5) ensure fuel neutrality when developing criteria for defining a “fuel secure” resource; and (6) recognize that all fuel sources have vulnerabilities and not single out natural gas for special attention.

Letters and Comments Jan 29, 2019

Dear Mr. President,
The undersigned organizations represent workers and companies who build and provide equipment, materials, supplies and services to energy infrastructure projects and energy production operations.
We urge you to nominate a candidate at your earliest opportunity to fill the vacancy on the Federal Energy Regulatory Commission created by the untimely passing of Commissioner McIntyre earlier this month.
His loss leaves the Commission with four members, creating significant risk of deadlock on the large number of pending FERC decisions authorizing critical natural gas pipelines and export facilities that are essential to your Administration’s priorities…

Letters and Comments Dec 17, 2018

The Independent Producers have participated individually or through the Independent Producers in most, if not all, of the rulemakings and associated litigation since the Environmental Protection Agency (“EPA” or “Agency”) proposed to revise the New Source Performance Standards (“NSPS”) for the Oil and Natural Gas Sector in August 2011. 76 Fed. Reg. 52,738 (Aug. 23, 2011).1 While many of the Independent Producers represent companies that engage in large volume hydraulic fracturing with horizontal legs, often referred to as unconventional drilling, a significant portion of their membership is comprised of smaller, family run operations that engage in some form of hydraulic fracturing, involving vertical wells without horizontal legs, referred to as conventional oil or gas wells. Many of the individual members constitute as small businesses under the Small Business Regulatory Enforcement Fairness Act of 1996. From the beginning of these rulemakings, the Independent Producers have tried to illustrate to the EPA that their “one-size-fits-all” approach to regulating this industry is a) inappropriate and b) disproportionally impacts conventional operations and small businesses.

Letters and Comments Dec 5, 2018

The Pipeline and Hazardous Materials Safety Administration (PHMSA) in 2016 proposed several changes to the existing regulations applicable to gathering lines in rural areas as part of its larger natural gas pipeline rulemaking. Those proposed changes have elicited fairly consistent comments from the Independent Petroleum Association of America (IPAA) and the Texas Pipeline Association (TPA). As PHMSA prepares to present its proposed response to comments in the pending rulemaking to the Gas Pipeline Advisory Committee (GPAC), IPAA and TPA suggest a path forward as described herein. The proposed path forward would ensure rural, larger diameter, high-pressure gas gathering lines for which PHMSA has expressed concern would meet certain, minimum requirements going forward. It would provide an initial step in addressing the risk of rural gathering pipelines by expanding the scope of regulated gathering while also providing additional information on gathering pipelines to assist future regulatory initiatives.

Endangered Species, Letters and Comments Sep 24, 2018

Re: Revision of the Regulations for Prohibitions to Threatened Wildlife and Plants, 83 Fed. Reg. 35174 (July 25, 2018); Revision of the Regulations for Interagency Cooperation, 83 Fed. Reg. 35178 (July 25, 2018); Revision of the Regulations for Listing Species and Designating Critical Habitat, 83 Fed. Reg. 35193 (July 25, 2018)

Dear Sir or Madam:

The Independent Petroleum Association of America (“IPAA”) and the Petroleum Association of Wyoming (“PAW”) (together “the Associations”) submit the following comments in response to the U.S. Fish and Wildlife Service and National Marine Fisheries Service’s
(together, “the Services”) jointly-proposed Revision of the Regulations for Interagency Cooperation, 83 Fed. Reg. 35178 (July 25, 2018) (“Section 7 Regulations”) and Revision of the Regulations for Listing Species and Designating Critical Habitat, 83 Fed. Reg. 35193 (July 25,
2018) (“Critical Habitat Regulations”), as well as the U.S. Fish and Wildlife Service’s (“FWS”) proposed Revision of the Regulations for Prohibitions to Threatened Wildlife and Plants, 83 Fed. Reg. 35174 (July 25, 2018) (“Blanket 4(d) Rule”).

IPAA is a national trade association representing the thousands of independent crude oil and natural gas explorers and producers in the United States. It also operates in close cooperation with 44 unaffiliated independent national, state, and regional associations, which
together represent thousands of royalty owners and the companies that provide services and supplies to the domestic industry. IPAA is dedicated to ensuring a strong, viable domestic oil and natural gas industry, recognizing that an adequate and secure supply of energy developed in an environmentally responsible manner is essential to the national economy.

PAW is Wyoming’s largest and oldest oil and gas organization dedicated to the betterment of the state’s oil and gas industry and public welfare. PAW members, ranging from independent operators to integrated companies, account for approximately ninety percent of the
natural gas and eighty percent of the crude oil produced in Wyoming.

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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.