Letters & Comments

Dear Leader McConnell and Leader Schumer, As associations representing businesses of all industries, forms, and sizes in all 50 states, we urge the Senate to take expeditious steps to ensure the timely confirmation of qualified pending nominees to administration positions. The slow pace of confirmations is depriving agencies across the government of critical leadership and in the case of independent agencies, the quorum necessary to conduct critical business.

Dear Senator Lankford and Representative Jenkins: We, the undersigned organizations, wish to express our full support for the Transparency and Honesty in Energy Regulations Act (THERA) of 2017. This important bill builds upon the Trump administration’s Executive Order 13783, which implemented critical reforms to the use of social cost of greenhouse gases in rulemaking. This bill provides needed regulatory certainty, ensuring key rulemaking principles are upheld regardless of the administration in power, which will help grow the economy, create jobs and strengthen our energy independence.

To whom it may concern: The American Petroleum Institute (API), National Ocean Industries Association (NOIA), Independent Petroleum Association of America (IPAA), International Association of Drilling Contractors (IADC), the International Association of Geophysical Contractors (IAGC), and the Offshore Operators Committee (OOC) offer the following comments in response to the National Oceanic and Atmospheric Administration (NOAA) request for comments on designations and expansion of Nation Marine Sanctuaries and Marine National Monuments over the past 10 years pursuant to Executive Order 13795.

In June 2017, the Environmental Protection Agency’s (EPA) Office of Inspector General (OIG) announced that it intended to initiate a preliminary investigation regarding EPA’s estimation of methane emissions from the oil and natural gas production sector. … IPAA’s member companies are significantly affected by the methane emissions and Volatile Organic Compound (VOC) regulations and Control Techniques Guidelines (CTG) that EPA has promulgated over the past several years. A key part of the debate over these regulations relates to their justification – justification that is based on EPA estimates of methane emissions. Throughout this debate, IPAA has been concerned that EPA has overestimated methane and VOC emissions. These overestimations then become critical to the justification of EPA’s regulations; several estimation actions occurred at key times in the regulatory process when the Obama Administration sought to move aggressively to expand federal regulation of oil and natural gas production.

Dear Speaker Ryan and Democratic Leader Pelosi: The undersigned associations are writing to express our support for H.R. 2910, legislation introduced by Rep. Bill Flores (R-TX) to improve interagency coordination in the review of proposed natural gas pipelines. The legislation is scheduled for consideration by the House this week and has our united support.

Dear Majority Leader McConnell, Speaker Ryan, and Minority Leaders Schumer and Pelosi: The undersigned, which represent a diverse group of industries from across the country, write to express our strong support for H.R. 806 and S. 263, the “Ozone Standards Implementation Act of 2017.” This legislation provides a common-sense approach for implementing national ambient air quality standards, recognizes ongoing state efforts to improve air quality through a reasonable implementation schedule for the 2015 ozone standards, streamlines the air permitting process for businesses to expand operations and create jobs, and includes other reforms that bring more regulatory certainty to federal air quality standards. Additionally, the undersigned support language including certain elements of H.R. 806 and S. 263 included in the Fiscal Year 2018 Interior, Environment and Related Agencies Appropriations bill.

The Independent Petroleum Association of America (IPAA) and its Cooperating Associations submit the following comments in response to the request for stakeholder input to the Senate Finance Committee’s consideration of tax reform. Collectively, these organizations represent the thousands of independent oil and natural gas explorers and producers, as well as the millions of royalty owners, in the United States that would be adversely affected by changes to Intangible Drilling Costs (IDC), the Percentage Depletion deduction and the Passive Loss Exception for Working Oil and Gas Interests. As defined by the Internal Revenue Code (IRC) Section 613(A), an independent producer is a producer that does not have more than $5 million in retail sales of oil and gas in a year or one that does not refine more than an average of 75,000 barrels per day of crude oil in a given year. Independent producers drill about 95 percent of American oil and natural gas wells, produce about 54 percent of American oil, and more than 85 percent of American natural gas. Independent producers historically reinvest over 100 percent of American oil and natural gas cash flow back into new American production.

Dear Mr. Cohen: The Independent Petroleum Association of America (IPAA) submits the following in response to the May 30, 2017, Federal Register notice seeking comments and information as part of the U.S. Department of Energy (DOE) implementation of Executive Order 13771, “Reducing Regulation and Controlling Regulatory Costs.” IPAA represents the thousands of independent oil and natural gas explorers and producers that will be the most significantly affected, either positively or negatively, by potential changes in regulations. Independent producers drill about 90 percent of American oil and gas wells, produce 54 percent of American oil and produce 85 percent of American natural gas. IPAA focuses on three areas where DOE can encourage development of American oil and natural gas production.

Dear Ms. Biercevicz: American Petroleum Institute (API), the American Exploration & Production Council (AXPC), Independent Petroleum Association of America (IPAA), the Natural Gas Supply Association (NGSA), US Oil & Gas Association (USOGA), and the Council of Petroleum Accountants Societies (COPAS) respectfully submit comments in response to the Federal Register notice issued on April 4, 2017 [FR Doc. 2017-06501] (“April 4 Notice”). In the April 4 Notice, the Energy Information Administration (EIA) requested industry comments on its proposal to expand its crude oil, lease condensate, and natural gas data collection to include five additional states/areas; collect crude oil and condensate stabilizer data; increase commentary details through multiple default-options as well as to provide a three-year extension of the EIA Form EIA-914 “Monthly Crude Oil, Lease Condensate, and Natural Gas Production Report.” Given that members of our organizations account for a large portion of the companies that are responsible for gathering and reporting production data to EIA, we appreciate the opportunity to comment on EIA’s proposal.

Dear Mr. Botwin: Together, the signatory trade associations (hereafter, “the Associations”) represent the majority of the oil and natural gas industry in the United States, across exploration and production (the “upstream”), transportation (the “midstream”) and manufacturing/refining (the “downstream”).
The Associations acknowledge the underlying objective for the nation to assess whether US imports of aluminum impair national security, per Section 232 of the Trade Expansion Act of 1962, as amended (hereafter referred to as “Section 232”). As the Associations articulated in our comments on Section 232 National Security Investigation of Imports of Steel, we urge the Department of Commerce to define “national security” narrowly.