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Letters & Comments

Letters and Comments Mar 9, 2018

The Independent Petroleum Association of America (IPAA) appreciates the opportunity to submit comments on the 2019-2024 Draft Proposed Outer Continental Shelf (OCS) Oil and Gas Leasing Program (DPP). The federal OCS has been a foundation of American energy policy since the 1950’s and provides outstanding oil and natural gas exploration and production opportunities for independent producers. The offshore industry can and will bring large volumes of oil and natural gas safely and efficiently to market from currently unavailable areas of the OCS, if those areas are reasonably made available for leasing. As global energy demand continues to increase, a failure to provide U.S. producers with needed access to the OCS will increase U.S. energy prices, slow economic growth, and create hardship for American consumers. It is essential that the Bureau of Ocean Energy Management (BOEM) develop a leasing program that maximizes the opportunities for our nation to address its energy needs. Increasing the safe development of offshore oil and natural gas resources would create high-paying American jobs, economic development, and strengthen energy security for not only the coastal states but across the nation. IPAA believes that America’s long-term energy security and job creation should be top priorities for our nation.

Letters and Comments Mar 8, 2018

Dear President Trump: As the Trump Administration has so clearly identified and stressed, America is now poised to enter an era where it can exert an energy dominance in the world energy marketplace. The growth and potential growth of American oil and natural gas production creates this opportunity. Yet, as the past few years of low commodity prices have shown, this future can be vulnerable. International trade policies present a similar challenge and the current initiatives on steel tariffs are a specific example.

Letters and Comments Jan 31, 2018

Pursuant to Rules 207(a)(4) and (a)(5) of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. §§ 385.207(a)(4) and (a)(5) (2017), the undersigned Petitioners, representing a broad-based coalition of the natural gas industry that are dependent upon services provided by interstate natural gas pipeline and storage companies, hereby petition the Commission to take immediate action under Sections 5(a), 10(a), and 14(a) and (c) of the Natural Gas Act (NGA) to initiate show cause proceedings against all interstate natural gas pipeline and storage companies, excluding (1) Section 311 pipelines (which are otherwise required to file updated rate justifications on an ongoing basis); and (2) natural gas pipeline and storage companies that are obligated to file a Section 4 rate case in 2018. Petitioners request the Commission to require all other regulated interstate natural gas pipeline and storage entities (unless barred by a settlement moratorium) to demonstrate that their existing jurisdictional rates continue to be just and reasonable following the passage of the Tax Cuts and Jobs Act of 2017 (“Tax Act”).

Letters and Comments Jan 22, 2018

Dear Mr. Sheehan: With this letter, API, IPAA, AXPC, and IAGC (together “the Associations”) are pleased to submit these comments in response to the U.S. Fish and Wildlife Service’s (FWS, or “the Service”) Candidate Conservation Agreements with Assurances (CCAAs) Policy, which the Services announced that they were intending to review and possibly to revise in a notice pub-lished at 82 Fed. Reg. 55,625 (November 22, 2017). The Services finalized a revision of the CCAA policy on December 27, 2016 (81 FR 95164). The Associations request the FWS revise the existing policy as described below.

Letters and Comments Jan 22, 2018

Dear Mr. Sheehan: With this letter, API, IPAA, AXPC, and IAGC (together “the Associations”) are pleased to submit these comments in response to the U.S. Fish and Wildlife Service’s (FWS, or “the Service”) Candidate Conservation Agreements with Assurances (CCAAs) Regulations found at 50 C.F.R. 17.22(d) and 17.32(d), which the Service announced that it was intending to review and possibly to revise in a notice published at 82 Fed. Reg. 55,550 (November 22, 2017). We request the FWS revise the existing rule as described below.

Letters and Comments Jan 10, 2018

Dear Member of Congress, On behalf of the Independent Petroleum Association of America, I want to thank you for your recent vote supporting the enactment of the Tax Cuts and Jobs Act. Once in a generation, Congress gets the opportunity to address comprehensive revisions to the federal tax code. No one, at the beginning of 2017, would have expected that this legislation could have been created and passed in a year. Your participation in this process is commendable.

Letters and Comments Jan 5, 2018

Dear Mr. Sheehan: With this letter, API, IPAA, AXPC, IAGC, and Western Energy Alliance (together “the Associations”) are pleased to submit these comments in response to the captioned public notice, published in the Federal Register November 6, 2017, in which the U.S. Fish and Wildlife Service (FWS or the Service) requests public comment to the use of the terms “net conservation gain” and “no net loss” to describe planning goals for the Service’s Endangered Species Act (“ESA”) Compensatory Mitigation Policy. We appreciate the FWS seeking public comments on this policy. However, we have significant concerns with many as-pects of the policy as discussed below. As such, we request the FWS withdraw and revise this policy.

Letters and Comments Jan 5, 2018

Dear Mr. Sheehan: With this letter, API, IPAA, AXPC, IAGC, and Western Energy Alliance (together “the Associations”) are pleased to submit these comments in response to the captioned public notice, published in the Federal Register November 6, 2017, in which the U.S. Fish and Wildlife Service (FWS or the Service) requests public comment to portions of the Service’s Mitigation Policy. We appreciate the FWS seeking public comments on this policy. However, we have significant concerns, as discussed below. We request the FWS withdraw and revise this policy.

Letters and Comments Dec 8, 2017

Dear Administrator Pruitt: The following comments are submitted on the above-referenced proposed rule and notice of data availability (NODA) on behalf of the following national and state trade associations: the Independent Petroleum Association of America (IPAA), American Exploration & Production Council (AXPC), Domestic Energy Producers Alliance (DEPA), Eastern Kansas Oil & Gas Association (EKOGA), Illinois Oil & Gas Association (IOGA), Independent Oil and Gas Association of West Virginia, Inc. (IOGA-WV), Indiana Oil and Gas Association (INOGA), International Association of Drilling Contractors (IADC), Kansas Independent Oil & Gas Association (KIOGA), Kentucky Oil & Gas Association (KOGA), Michigan Oil and Gas Association (MOGA), National Stripper Well Association (NSWA), North Dakota Petroleum Council (NDPC), Ohio Oil and Gas Association (OOGA), Oklahoma Independent Petroleum Association (OIPA), Pennsylvania Independent Oil & Gas Association (PIOGA), Texas Alliance of Energy Producers (Texas Alliance), Texas Independent Products & Royalty Owners Association (TIPRO), and West Virginia Oil and Natural Gas Association (WVONGA) (collectively, “Independent Producers”). We respectively ask that you consider these comments.  We are here to respond to any questions or comments you may have.

Letters and Comments Dec 1, 2017

In accordance with the Federal Register notice, issued on October 2, 2017 and revised on November 3, 2017, the Independent Petroleum Association of America (IPAA) and its members, along with the Kentucky Oil & Gas Association, the Ohio Oil and Gas Association, and the Pennsylvania Independent Oil & Gas Association (collectively, Independent Producers), submit the following comments on existing rules and other agency actions that are good candidates for repeal, replacement, suspension, or modification. The Independent Producers represent the companies that drill 90 percent of the nation’s oil and natural gas wells. These companies produce 82 percent of American natural gas and 68 percent of American oil. The Independent Producers’ members represent the full range of producers, from small family‐owned businesses, to the large independent companies that are some of the largest American natural gas producers. The Independent Producers’ recommendations focus on three issues under the auspices of the Pipeline and Hazardous Materials Safety Administration (PHMSA): Sampling and testing for unrefined petroleum‐based products; Regulatory treatment of farm taps off production lines; and Proposed regulations affecting gathering lines and production facilities.

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.