Letters & Comments

The Waters Advocacy Coalition submits the following comments in response to the U.S. Army Corps of Engineers Proposal to Reissue and Modify Nationwide Permits. See Notice of Proposed Rulemaking, 81 Fed. Reg. 35,186 (June 1, 2016). The Coalition represents a large cross-section of the nation’s construction, housing, transportation, recreational, mining, agriculture, manufacturing, and energy sectors, all of which are vital to a thriving national economy, including providing much-needed jobs, products, and services.1 Projects, activities, and operations in these sectors are often subject to regulation under Section 404 of the Clean Water Act (CWA) and members of the Coalition often rely on nationwide permits to ensure compliance with the CWA.

Pursuant to Section 307(b)(1) of the federal Clean Air Act (CAA), 42 U.S.C. § 7607(b)(1), the Independent Petroleum Association of America (IPAA) and a number of industry trade partners and state independent producer associations hereby petition this Court for review of final agency action that respondent United States Environmental Protection Agency took under Sections 111(b)(1)(B) and 112(d)(2) of the CAA, 42 U.S.C. §§ 7411(b)(1)(B) and 7412(d), entitled Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources, 81 Fed. Reg. 35824 (June 3, 2016) (the Oil and Natural Gas New Source Performance Standards).

The American Exploration & Production Council (AXPC) and the Independent Petroleum Association of America (IPAA) are pleased to submit comment to the U.S. Army Corps of Engineers (USACE) on its Proposal to Reissue and Modify Nationwide Permits published in the federal register on June 1, 2016 (Volume 81, Number 105). While AXPC and IPAA jointly requested a comment extension deadline of 60-days, in a June 13, 2016 letter to USACE, AXPC understands USACE’s refusal to grant such a request in an effort to ensure adequate time for publishing the 2017 Nationwide Permits (NWP) prior to the expiration of the 2012 NWPs. Thus, having only a 60-day comment deadline has caused AXPC and IPAA to focus only on some of the principal topics that USACE is specifically seeking for comment and submits the following response.

In response to the June 27, 2016, Federal Register notice, the Independent Petroleum Association of America (IPAA) provides comments on PHMSA’s approach for establishing minimum pipeline safety standards for the transportation of carbon dioxide (CO2) in a gaseous state. IPAA represents the thousands of independent oil and natural gas explorers and producers. Independent producers develop about 95 percent of American oil and gas wells, produce 54 percent of American oil, and produce 85 percent of American natural gas.

The Independent Petroleum Association of America (IPAA) and its members, along with the American Exploration & Production Council, the Colorado Oil and Gas Association, the Independent Oil & Gas Association of West Virginia, the Kansas Independent Oil & Gas Association, the Kentucky Oil & Gas Association, the Michigan Oil and Gas Association, the Ohio Oil and Gas Association, the Pennsylvania Independent Oil & Gas Association, the Texas Alliance of Energy Producers, the Virginia Oil and Gas Association, and the West Virginia Oil and Natural Gas Association (collectively, Independent Producers), appreciate this opportunity to respond to the Pipeline and Hazardous Materials Safety Administration’s (PHMSA’s) notice of proposed rulemaking (NOPR) on Safety of Gas Transmission and Gathering Pipelines.

The American Exploration & Production Council (AXPC) and the Independent Petroleum Association of America (IPAA) were pleased to see the publication of the Proposal to Reissue and Modify Nationwide Permits in the federal register on June 1, 2016, (Volume 81, Number 105) and submits the following in response to the request for comments concerning the information collection requirements for the proposed rule.

The Independent Petroleum Association of America (IPAA) submits these comments on the changes proposed by the United States Fish and Wildlife Service (Service) “to the regulations concerning enhancement of survival permits issued under the Endangered Species Act” (ESA), and on the related “proposed revisions to the Candidate Conservation Agreements with Assurances policy.”

The Independent Petroleum Association of America (IPAA) requests a 60 day extension on the initial comment period related to the Information Collection Request for Oil and Gas Facilities. IPAA requests this extension because the current comment period is too short for industry professionals to analyze the complexities of an Information Collection Request (ICR) given the simultaneous requirement to develop implementation plans for compliance with Subpart OOOOa that results from its formal promulgation. However, it is also too short for the Agency to address many issues that it needs to consider before initiating the ICR.

The American Petroleum Institute (API), the Offshore Operators Committee (OOC), the National Ocean Industries Association (NOIA), the Independent Petroleum Association of America (IPAA), the International Association of Drilling Contractors (IADC), and the Offshore Marine Services Association (OMSA) submit comments on the Bureau of Ocean Energy Management’s (BOEM), proposed rule Air Quality Control, Reporting and Compliance, 81 Federal Register 19718 (April 5, 2016), Docket Id: BOEM-2013-0081.

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 and Services Association (PESA), and the Alaska Oil and Gas Association (AOGA) (collectively, the Associations) offer the following comments on the Bureau of Ocean Energy Management’s (BOEM) request for comments on the Proposed Outer Continental Shelf (OCS) Oil and Gas Leasing Program 2017-2022 published in the Federal Register on March 18, 2016.