Re: Comments on Clean Water Act Section 401 Water Quality Certification Rulemaking [Docket ID No. EPA-HQ-OW-2018-0855]
To whom it may concern:
The Independent Petroleum Association of America (“IPAA”) submits the following comments for pre-proposal recommendations on the forthcoming Clean Water Act (“CWA”) Section 401 Water Quality Certification rulemaking and guidance from the U.S. Environmental Protection Agency (“EPA”).
IPAA represents the thousands of companies that drill 95 percent of America’s onshore and offshore oil and natural gas wells. America’s independents produce 54 percent of American oil and produce 85 percent of American natural gas. While most IPAA members will not apply directly for a Sec. 401 permit, our members are affected by the process. When some states misuse their authority as part of a cooperative process, permits are denied and needed infrastructure to transport natural gas is not built….