Letters & Comments

Letters and Comments, Uncategorized Feb 1, 2024

This Coalition letter was sent to the Members of the U.S. House of Representatives’ Committees on Small Business and of the Judiciary, supporting reform in implementation of the Regulatory Flexibility Act.

“Dear Chairmen Williams and Jordan and Ranking Members Velazquez and Nadler:

On behalf of millions of small businesses across the country, we urge legislative action to strengthen the meaningful input of small businesses in federal regulatory processes and ensure the intent of the Regulatory Flexibility Act is fulfilled. …

Unfortunately, loopholes in the RFA allow federal regulators to bypass the law’s requirements and misrepresent the costs of new mandates on small businesses because (a) transparency requirements only apply to businesses directly regulated and (b) judges may not punish agencies for ignoring small business concerns. …

At a time when we are counting on small business growth to enrich communities and bolster America’s economy, we cannot afford to bury free enterprise under red tape emanating from Washington.

We urge the Committee to prioritize legislation that strengthens and closes loopholes in the Regulatory Flexibility Act. …”

Letters and Comments, Methane, Taxes Jan 30, 2024

Dear Mr. Ragnauth,

The Independent Petroleum Association of America (IPAA) respectfully requests a 30-day extension of the public comment period for the Environmental Protection Agency’s (EPA) Proposed Rule, “Waste Emissions Charge for Petroleum and Natural Gas Systems (“WEC Rule”) [89 FR 5318]. …

EPA has failed to adequately recognize and address the myriad crosscutting issues among the WEC Rule, EPA’s proposed Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas System (“Subpart W Rule”) [88 FR 50282], and EPA’s proposed New Source Performance Standards and Emission Guidelines for Crude Oil and Natural Gas Facilities: Climate Review (“Methane Rule”) [87 FR 74702]. EPA has also failed to recognize the risks to the workability and durability of these rules posed by an inadequately coordinated rulemaking process.

IPAA believes a 30-day extension of the WEC Rule comment period is both necessary and reasonable in order for IPAA staff and its members to fully analyze the proposed WEC Rule and its connections to the Subpart W Rule and Methane Rule, develop comments, and inform EPA’s final rule. Thank you for your prompt consideration of this request.

Infrastructure, Letters and Comments Jan 30, 2024

Dear Chairmen Graves and Rouzer and Ranking Members Larsen and Napolitano:

We, the undersigned organizations, urge the House Committee on Transportation and Infrastructure to favorably report the Nationwide Permitting Improvement Act.

Building smart, modern, resilient infrastructure through innovation and responsible development is a top priority for the business community. Linear infrastructure from pipelines and transmission lines to other critical infrastructure plays an essential role in reducing greenhouse gas emissions and providing energy security for the United States and our allies. Thousands of miles of hydrogen and CO2 pipelines will be needed to meet ambitious climate goals. This legislation will also help expedite the delivery of clean water for communities and broadband needed to support small business innovation. Ensuring a strong, stable, and predictable nationwide permitting program is critical for the United States to sustainably grow and prosper.

We support NWP-12 and the Nationwide Permitting Improvement Act for the following reasons:

  • Contributing to our national and energy security.
  • Ensuring electricity reliability.
  • Providing the foundation for decarbonization infrastructure.
  • Serving customers with affordable energy.
  • Providing predictability and regulatory certainty for NWP-12.

Letters and Comments Jan 30, 2024

“Dear Speaker Johnson, Senator Schumer, Representative Jeffries and Senator McConnell,

“On March 25th, 2022, President Biden stood with European Commission President Ursula von der Leyen and pledged to work together to lay the framework for a significant increase in U.S. LNG exports to the European Union. American supply allowed the European Union’s economies and population to survive as Russian natural gas was turned off following the brutal Russian invasion of Ukraine.

“At home, the men and women at the heart of U.S. energy production ramped up production at an unprecedented pace to meet domestic demand as well as the new demand from our allies abroad. Today, production has never been higher and energy prices and supply have remained stable in America even with the increased U.S. exports. In fact, U.S. LNG exports reached record highs in 2023 while domestic prices declined 62%.

“The Biden Administration’s recent announcement to pause new non-FTA permits for LNG export facilities could not have come at a worse time. This action threatens to stifle the progress made by the unprecedented ramp up of our domestic industry and the fundamental shift in dependence made by Europe. …

“We strongly support the re-introduction of Unlocking Our Domestic LNG Potential Act by Rep. August Pfluger (TX-11) which will counter this misguided decision by the Administration and put the Federal Energy Regulatory Commission in charge of all LNG export permitting in the United States. Removing DOE from the process will help to ensure that political maneuvers will not interfere with energy supplies. It is vital that Congress send an immediate message to our allies, and enemies, abroad that U.S LNG will continue to flow uninterrupted for many years to come.

Infrastructure, Letters and Comments Jan 29, 2024

Dear Chairman Graves and Ranking Member Larsen:

The Waters Advocacy Coalition (WAC) strongly supports the below series of bills introduced by Members of the Water Resources and Environment Subcommittee. We encourage you to report these bills favorably to the full House.

These bills provide practical fixes to certain sections of the Clean Water Act (CWA) Section 402 National Pollutant Discharge Elimination System (NPDES) permit program, Section 404 dredge and fill permit program, and Section 304(a) process for establishing water quality criteria. These targeted reforms represent significant steps toward streamlining regulatory procedures,  providing greater certainty for businesses in our sectors, and helping meet our nation’s ambitious climate and infrastructure priorities.

  1. H.R. 7023 Nationwide Permitting Improvement Act (introduced by Rep. David Rouzer)
  2. H.R. 7026 Reducing Permitting Uncertainty Act (introduced by Rep. Pete Stauber)
  3. H.R. 7021 Water Quality Criteria Development and Transparency Act (introduced by Rep. Burgess Owens)
  4. H.R. 7008 Judicial Review Timeline Clarity Act (introduced by Rep. Eric Burlison)
  5. H.R. 7013 Confidence in Clean Water Permits Act (introduced by Rep. John Duarte)
  6. H.R. 5089 Reducing Regulatory Burdens Act of 2023 (introduced by Rep. David Rouzer)

Letters and Comments Jan 24, 2024

In a letter to Secretary Granholm and senior administration officials, the industry groups led by the American Petroleum Institute (API) and including the Independent Petroleum Association of America (IPAA), the American Exploration and Production Council (AXPC), Center for LNG (CLNG), LNG Allies and dozens of other industry groups, emphasized the critical role that continued U.S. LNG exports play in safeguarding national security, creating U.S. jobs, supporting our European allies and contributing to global climate goals.

“Our nation’s abundant supply of natural gas is an impactful geopolitical tool, helping insulate American consumers from increasing global instability while advancing American national interests and ensuring the energy security of key U.S. allies,” the groups wrote. “Moving forward with a pause on new U.S. LNG export approvals would only bolster Russian influence and undercut President Biden’s own commitment to supply our allies with reliable energy, undermining American credibility and threatening American jobs.”

Infrastructure, Letters and Comments Dec 13, 2023

Dear Mr. Cossette,

The Independent Petroleum Association of America (IPAA) appreciates the opportunity to provide comments on the Draft Environmental Impact Statement (DEIS) for the Dakota Access Pipeline (DAPL). …

IPAA would like to specifically emphasize the critical importance of maintaining the existing pipeline crossing as defined in Alternative Three. This alternative has the least environmental and safety impact, is the most economic, and provides the most energy security for consumers, landowners, and tribal communities.

The existing DAPL crossing is a critical linchpin in the nation’s energy infrastructure. It has been constructed with meticulous attention to safety and environmental considerations. Maintaining this crossing is crucial for ensuring safe, efficient, and uninterrupted transportation of crude oil. Altering the operations of the pipeline as suggested in several of the alternatives would not only impose significant financial and logistical burdens on the industry and the region, but also undermine the years of planning and investment that have gone into developing this critical energy asset.  The strategic importance of this crossing is demonstrated by its robust construction, adherence to the highest safety standards, and its minimal environmental footprint. Maintaining the existing route and continued uninterrupted operation guarantees the least ecological impact while offering maximum efficiency.

Letters and Comments, Regulations Dec 1, 2023

The Waters Advocacy Coalition (“WAC” or “Coalition”) submitted comments on the Interim Draft of the National Ordinary High Water Mark Field Delineation Manual for Rivers and Streams (“Draft Manual”). WAC represents a large cross-section of America’s construction, transportation, real estate, mining, manufacturing, forestry, agriculture, energy, wildlife conservation, and public health and safety sectors—all of which are vital to a thriving economy and provide much-needed jobs. WAC members’ activities, projects, and operations are often subject to Clean Water Act (“CWA”) regulation.

The comments detail how:

I. EPA and the Corps Must Go Through Rulemaking to Change the Scope of CWA Jurisdiction

II. At a Minimum, the Agencies Must Reaffirm That the OHWM Has No Relevance to the Relatively Permanent Standard

 

Letters and Comments, Offshore Nov 1, 2023

The American Petroleum Institute (API), Energeo Alliance (Energeo), Independent Petroleum Association of America (IPAA), Louisiana Mid-Continent Oil & Gas Association (LMOGA), National Ocean Industries Association (NOIA), and Offshore Operators Committee (OOC) (collectively, the Associations) offer the following comments on the Bureau of Ocean Energy Management’s (BOEM) Notice of Intent (NOI) to prepare another Programmatic Environmental Impact Statement (PEIS) for a “representative oil and gas lease sale” in the Gulf of Mexico (GOM) Eastern, Central and Western Planning Areas scheduled as part of the 2024-2029 Five-Year Outer Continental Shelf (OCS) Leasing Program. 88 Fed. Reg. at 67,803. For many years, the Associations and our members have worked collaboratively with the Department of the Interior (DOI) and its agencies (including BOEM) in support of the continued safety of industry workers and protection of the environment both offshore and onshore. At the same time, our members rely heavily on Congress’ statutory mandates (repeatedly recognized by the courts) that DOI make the OCS available for leasing and expeditious development. Many of our members are involved in exploring for and developing oil and natural gas resources in the GOM and we support BOEM holding all lease sales as scheduled in the 2024-2029 Proposed Final Program and offering all unleased acreage not subject to moratorium in those lease sales. Accordingly, BOEM should pursue Alternative B in the NOI.

Letters and Comments, Offshore Nov 1, 2023

The American Petroleum Institute (API), Energeo Alliance (Energeo), Independent Petroleum Association of America (IPAA), and Louisiana Mid-Continent Oil & Gas Association (LMOGA) (collectively, the Associations) offer the following comments on the Bureau of Ocean Energy Management’s (BOEM) call for information and nominations (Call) for lease sales in the Gulf of Mexico (GOM) Eastern, Central and Western Planning Areas scheduled as part of the 2024-2029 Five-Year Outer Continental Shelf (OCS) Leasing Program. Many of our members operate on the OCS and on federal lands onshore. For many years, the Associations and our members have worked collaboratively with the Department of the Interior (DOI) and its agencies (including BOEM) in support of the continued safety of industry workers and protection of the environment. At the same time, our members rely heavily on Congress’ statutory mandates (repeatedly recognized by the courts) that DOI make the OCS available for leasing and expeditious development. Our members are involved in exploring for and developing oil and natural gas resources in the GOM and we support holding all lease sales as scheduled in the 2024-2029 Proposed Final Program and offering all unleased acreage not subject to moratorium in those lease sales. …

The Associations reiterate their request that BOEM duly finalize its Five-Year Leasing Program, hold all GOM lease sales as scheduled during the 2024-2029 timeframe, and in those lease sales offer on a Region-wide basis all unleased acreage not subject to moratorium.

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.