Letters & Comments

To the Members of the United States Congress: We urge Congress to expeditiously pass a budget resolution with reconciliation instructions so that the promise of tax reform can be made a reality. It has been 31 years since Congress last reformed the tax code. Since then, the code has become an anchor weighing down the economy, job creation, and wage growth for American families.

Dear Secretary Zinke: The Independent Petroleum Association of America (IPAA) and the American Exploration and Production Council (AXPC) appreciate the opportunity to submit comments regarding ways the Department of the Interior can improve management of federal lands and reform the regulatory process utilized by the agency. The comments contained in this document specifically address regulatory reform at the Bureau of Land Management (BLM). We welcome the Trump Administration’s efforts to make American energy dominance a cornerstone of Administration policy. However, the current regulatory process at the BLM hampers that important goal.

Dear Ms. MacGregor and Mr. Nedd: On July 25, 2017, the Bureau of Land Management (BLM) published a proposed rule that would rescind a final rule BLM issued in March 2015. The “2015 Rule” was designed to regulate hydraulic fracturing on federal and Indian lands. This submission constitutes comments on the July 2017 proposal from the Independent Petroleum Association of America (IPAA) and the Western Energy Alliance (collectively, the Associations). The Associations collectively represent thousands of independent oil and natural gas explorers and producers, as well as the service and supply industries that support their efforts. It is the members of these groups that the proposed rescission will most significantly affect. Independent producers drill about ninety-five percent of American oil and natural gas wells, produce about fifty-four percent of American oil, and more than eighty-five percent of American natural gas. From the beginning, the Associations have actively engaged to assist BLM’s rulemaking efforts related to hydraulic fracturing.

Dear Secretary Zinke: The Independent Petroleum Association of America (IPAA) submits the following comments in response to the Department of Interior’s (DOI’s) request for public comment on ways to improve implementation of regulatory reform initiatives, policies, and identify regulations for repeal, replacement or modification under Executive Order 13777, “Enforcing the Regulatory Reform Agenda.” The comments contained herein specifically address regulatory reform at the U.S. Fish and Wildlife Service, highlighting the Endangered Species Act, Migratory Bird Treaty Act, and mitigation efforts.

The Independent Petroleum Association of America (IPAA) submits the following comments in support of the expeditious review and approval of the Department of Environmental Quality’s 401 Water Quality Certification for the proposed Atlantic Coast Pipeline. IPAA submits that the final Environmental Impact Statement issued by the Federal Energy Regulatory Commission supports issuance of the certification, finding that Atlantic Coast’s “surface water and wetlands impacts would be effectively minimized or mitigated.”

The American Petroleum Institute (API), National Ocean Industries Association (NOIA), Independent Petroleum Association of America (IPAA), U.S. Oil and Gas Association (USOGA), American Exploration & Production Council (AXPC), International Association of Drilling Contractors (IADC), International Association of Geophysical Contractors (IAGC), Petroleum Equipment Suppliers Association (PESA), and the Alaska Oil and Gas Association (AOGA) offer the following comments on the Bureau of Ocean Energy Management’s (BOEM) request for information and comments on the preparation of the 2019-2024 Outer Continental Shelf Oil and Gas Leasing Program published in the Federal Register on July 3, 2017. The Associations’ members are involved in exploring for and developing oil and natural gas resources found on the OCS and are interested in the development of the 2019-2024 OCS Leasing Program. In 2015, the U.S. oil and natural gas industry supported more than 10.3 million jobs nationwide and made up more than 7.5% of GDP. The decisions made regarding areas to include in the program will have long-term implications for our nation’s energy security, prospects for job creation, and future revenue generation.

Dear Administrator Pruitt: The Independent Producers have participated individually or through IPAA in most, if not all, of the rulemakings and associated litigation since the Environmental Protection Agency (EPA) 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). While most of the Independent Producers represent companies that engage in large volume hydraulic fracturing horizontal or unconventional drilling, a significant portion of their membership is also comprised of “mom and pop” operations that engage in some form of hydraulic fracturing, generally involving vertical wells drilled into geological formations currently referred to as conventional wells. From the beginning of these rulemakings, most of the Independent Producers have tried to explain to the EPA that their “one-size-fits-all” approach to regulating this industry is inappropriate. The Proposed Rule represents another, necessary, opportunity to work with the EPA to tailor 40 C.F.R. Part 60, Subpart 0000a to reduce the impact on the Independent Producers and their individual members while still providing adequate protection of the environment. The Independent Producers’ Petition for Reconsideration submitted on August 2, 2016, to the EPA outlines the primary issues that should be addressed during the two-year time period set forth in the Proposed Rule.1 As a result of various factors, including the regulatory burden, many individual members of the Independent Producers have not drilled a single well in the past five years. The Proposed Rule will have a tremendous benefit to the Independent Producers and their individual members, while having little to no negative impact on the environment. The proposed two-year time period is entirely appropriate for the Independent Producers to educate the new Administration on their concerns as well as make the appropriate and necessary changes to current regulations.

Dear Ambassador Lighthizer, Secretaries Ross, Tillerson and Mnuchin and Director Cohn: As associations representing millions of small, medium and large companies across every major sector of the U.S. economy employing tens of millions of U.S. workers, we urge that robust market access commitments and investment protections, enforceable through investor-state dispute settlement (ISDS), be maintained and upgraded in the negotiations to modernize the North American Free Trade Agreement (NAFTA). The original NAFTA included basic access, protection and enforcement provisions that have helped grow manufacturing, services and agricultural industries by enabling our businesses to reach new consumers and to participate in foreign infrastructure, energy and resource development projects. The negotiations to modernize NAFTA provide an important opportunity to upgrade the agreement to improve protection and enforcement tools against the theft, discrimination and unfair treatment of U.S. property overseas.

The Independent Petroleum Association of America (IPAA) submits the following comments on the June 2017 Independent Alternatives Analysis of Enbridge’s Line 5 Pipelines, conducted by Dynamic Risk Assessment Systems (Analysis) for the State of Michigan. IPAA represents 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. IPAA members represent the full range of producers, from small family-owned businesses, to the large independent companies that are some of the largest domestic natural gas producers.