Joint comments, along with API, AXPC, and Western Energy Alliance, to the U.S. Fish and Wildlife Service in response to proposed rule to list the Texas Hornshell as endangered under the Endangered Species Act, highlighting that a listing of the species is not warranted.
API and IPAA understand that your office is reviewing rules proposed by the National Park Service and the U.S. Fish and Wildlife Service (the Services) to regulate operations on privately held minerals that lie beneath lands administered by the Services as units in the National Park System or as National Wildlife Refuges. Our more detailed comments to each rule as originally proposed are attached for your reference.
IPAA and other industry trade associations submitted an extension request to the U.S. Fish and Wildlife Service this week to extend the comment deadline for the public review period for the Service’s Endangered Species Act (ESA) Compensatory Mitigation Policy. The letter asks that the Services extend the public comment period for this proposal for at least an additional 30 days, or until November 16, 2016. The existing public comment period provides only a limited window for review and comment on a new policy that is the first comprehensive treatment of the role of compensatory mitigation in the process of the Service’s review of potential remedies for effects on species and habitats of concern from projects proposed by entities in the private or public sectors.
The Independent Petroleum Association of America (IPAA), American Petroleum Institute (API), American Exploration & Production Council (AXPC), Petroleum Association of Wyoming (PAW) and Western Energy Alliance (Alliance) (the Trades) submit these comments on the joint U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) draft revision to their Habitat Conservation Planning Handbook (Draft HCP Handbook).
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 on the National Oceanic and Atmospheric Administration (NOAA) request for comments on the Draft Environmental Impact Statement (“DEIS”) for the proposed actions of boundary expansion and application of existing regulations and management plan actions to new geographic areas of the Flower Garden Banks National Marine Sanctuary published in the Federal Register on June 10, 2016. Comments submitted on behalf of the Associations are submitted without prejudice to any member’s right to have or express different or opposing views.
This letter is being sent on behalf of the Independent Petroleum Association of America (IPAA). IPAA represents the thousands of independent oil and natural gas explorers and producers, as well as the service and supply industries that support their efforts, that will most directly be impacted by the U.S. Environmental Protection Agency (EPA) policy decisions to regulate methane directly from the oil and natural gas sector. Independent producers develop about 95 percent of American oil and natural gas wells, produce 54 percent of American oil, and produce 85 percent of American natural gas. Historically, independent producers have invested over 150 percent of their cash flow back into American oil and natural gas development to find and produce more American energy. IPAA is dedicated to ensuring a strong, viable American oil and natural gas industry, recognizing that an adequate and secure supply of energy is essential to the national economy.
OSHA is considering revisions to the 29 CFR § 1910.119 Process Safety Management (PSM) standard. This letter provides comments from the American Exploration & Production Council (AXPC) and the Independent Petroleum Association of America (IPAA) on OSHA’s Process Safety Management Small Entity Representative Background Document as well as the Small Business Advocacy Review Panel final report.
The Independent Petroleum Association of America (IPAA), American Exploration & Production Council (AXPC), Western Energy Alliance and the Petroleum Association of Wyoming (PAW) respectfully request that the U.S. Fish and Wildlife Service (USFWS) extend the comment period on the USFWS’s Draft Habitat Conservation Planning Handbook (Draft Handbook) by at least 30-days or until September 28, 2016.
These comments are filed on behalf of the Independent Petroleum Association of America (IPAA), the American Exploration and Production Council (AXPC). Additionally, they are joined by the American Association of Professional Landmen (AAPL), the Association of Energy Service Companies (AESC), the International Association of Drilling Contractors (IADC), the International Association of Geophysical Contractors (IAGC), the National Stripper Well Association (NSWA), the Petroleum Equipment & Services Association (PESA), and a number of state oil and natural gas industry trade associations regarding the U.S. Environmental Protection Agency’s proposed Information Collection Request (ICR) for oil and gas facilities.
A number of industry trade associations hereby submit this petition for administrative reconsideration of the final rule entitled “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources,” published at 81 Fed. Reg. 35824 (June 3, 2016) (“Subpart OOOOa” or “Methane NSPS”). We request that you take the time to review what and who these trade associations represent and not simply jump to the issues we are seeking reconsideration of. Many of these trade associations have been around since or before the 1950s. The trade associations represent the “independent” exploration and production companies – from the “mom and pop” operations to some of the larger producers in the country – but that is all they do and it is all they know. Subpart OOOOa, as finalized, will have a disproportionate impact on independents and especially independents that constitute “small business” under the Regulatory Flexibility Act.
