Letters & Comments

Dear Mr. Nedd: With this letter, API and IPAA are pleased to submit its comments in response to the captioned public notice, published in the Federal Register October 11, 2017, describing the intention of the Bureau of Land Management (BLM) to consider amendments to “some, all or none of the BLM land use plans that were amended or revised in 2014 and 2015 regarding Greater Sage-Grouse (GRSG) conservation in the States of California, Colorado, Idaho, Nevada, Oregon, Wyoming, North Dakota, South Dakota, Utah and Mon-tana” (2015 GRSG Plans).

Dear Ms. Christensen and Ms. Jensen: The Waters Advocacy Coalition (WAC) submits the attached comments in response to the U.S. Environmental Protection Agency’s and U.S. Army Corps of Engineers’ request for written recommendations regarding the definition of “Waters of the United States” under the Clean Water Act. WAC appreciates the opportunity to comment on this important issue.

Dear Mr. Beaman: The American Exploration & Production Council (AXPC) and the Independent Petroleum Association of America (IPAA) are pleased to submit comment to the Environmental Protection Agency (EPA) on its voluntary information collection request (ICR) proposal, “Survey on Clean Water Act Hazardous Substances and Spill Impacts” published in the federal register on September 21, 2017 (Document No. 2017-20170). AXPC and IPAA member companies are currently subject to the existing spill prevention, control, and countermeasure (SPCC) regulations in addition to the many similar, supplementary state specific requirements. As such, AXPC and IPAA believe that the current regulatory environment is sufficient as it provides for adequate protection against any unplanned release of hazardous substances and submits the following response.

A diverse group of a dozen energy industry associations representing oil, natural gas, wind, solar, efficiency, and other energy technologies submitted reply comments to the Federal Energy Regulatory Commission (FERC) continuing their opposition to the Department of Energy’s (DOE) proposed rulemaking on grid resiliency pricing, in the next step in this FERC proceeding.

To Whom It May Concern: Western Energy Alliance and the Independent Petroleum Association of America (IPAA) appreciate the opportunity to provide comment on the Bureau of Land Management’s (BLM) proposed stay of effectiveness of certain provisions of the Methane and Waste Prevention rule, or 2016 rule. We believe that the original rule as promulgated exceeded BLM’s authority under the Mineral Leasing Act (MLA) and that the decision to postpone compliance dates while BLM re-evaluates the rule is prudent. Given the lengthy rulemaking process that will be needed to revise the final rule, we believe BLM should stay compliance dates for two years, rather than the proposed one year. Notably, the 2016 rule took more than two years to develop and finalize.

Chairman Bishop and Ranking Member Grijalva, As trade associations representing companies who produce the energy needed to fuel our cars and heat our homes, we support H.R. 4239, the SECURE American Energy Act, which seeks to achieve and maintain our domestic energy dominance by harnessing more onshore and offshore energy production here in the U.S.

A broad coalition of 12 energy industry associations representing oil, natural gas, wind, solar, efficiency, and other energy technologies submitted joint comments to the Federal Energy Regulatory Commission (FERC) in response to the Department of Energy’s (DOE) proposed rulemaking on grid reliability and resiliency pricing. In the joint comments, the coalition urged FERC not to adopt DOE’s proposed rule to provide out-of-market financial support to uneconomic coal and nuclear power plants in the wholesale electricity markets overseen by FERC.

Pursuant to the October 2, 2017, Notice Inviting Comment, issued by the Federal Energy Regulatory Commission (FERC or “the Commission”) in the above-referenced docket, the Independent Petroleum Association of America and the following organizations (collectively, “Independent Producers”) hereby respectfully submit the following comments on the Notice of Proposed Rulemaking in this docket. The Independent Producers urge the Commission to reject the recommendations as set forth by the Secretary of Energy in its September 28, 2017, proposal of a rule for final action by the Commission.

Pursuant to Rule 212 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission, 18 C.F.R. § 385.212 (2016), and section 403(b) of the Department of Energy Organization Act, 42 U.S.C. § 7173, the Independent Petroleum Association of America and the signed independent producers hereby respectfully submit this motion for extension of time for filing comments on the Notice of Proposed Rulemaking in this docket. The Independent Producers request at a minimum the 90-day initial comment period and 45-day reply comment period suggested by the Energy Industry Associations.

Petitioners Western Energy Alliance and the Independent Petroleum Association of America respectfully request that the Court invalidate and remand the Bureau of Land Management’s rule related to the reduction of venting and flaring from oil and gas production on federal and Indian leases, Waste Prevention, Production Subject to Royalties, and Resource Conservation, 81 Fed. Reg. 83,008 (Nov. 18, 2016). The Rule exceeds BLM’s statutory authority, is inconsistent with such statutory authority, and is arbitrary, capricious, and an abuse of discretion.