Letters & Comments

The Independent Petroleum Association of America (IPAA), the Western Energy Alliance (Alliance), and the American Exploration and Production Council (AXPC) (collectively “the Associations”) appreciate the opportunity to comment to the Office of Management and Budget (OMB) in relation to the information collection requirements that would be imposed by the Bureau of Land Management’s (BLM) proposed Waste Prevention, Production Subject to Royalties, and Resource Conservation Rule. The proposed information collection requirements would result, contrary to the requirements of the Paperwork Reduction Act (44 USC §§ 3501-3521), in unnecessary new costs and burdens, without compensating benefits, to domestic oil and natural gas producers, the vast majority of which are small, independent businesses.

Dear Representative Jenkins: We strongly support your introduction of legislation to remove the net income limitation on percentage depletion for oil and natural gas produced from marginal properties. This important relief is critical to preserving the production of oil and natural gas from the most marginal oil and natural gas prospects. We appreciate your sponsorship of this legislation and plan to work to urge other Representatives to support your efforts for this important legislation that will protect jobs, strengthen America’s energy security, and enhance the climate for small businesses in America.

The American Exploration & Production Council (AXPC) and the Independent Petroleum Association of America (IPAA) appreciate the opportunity to provide comments on the Occupational Safety and Health Administration’s (OSHA) Safety and Health Program Management Guidelines. AXPC and IPAA fully support OSHA’s efforts to revise the Safety and Health Program Management Guidelines (first published in 1989) to reflect modern technology and practices.

The American Petroleum Institute and the Independent Petroleum Association of America submitted comments on the Draft Methodology for prioritizing status reviews and accompanying 12-month findings on petitions for listing species under the Endangered Species Act. API and IPAA appreciate that the Draft Methodology recognizes that the Service can only make decisions under the ESA based on the best available scientific and commercial data. By giving a higher priority to species for which there is ample data currently available, the Service can correctly ensure that it does not base its ESA decisions on speculative, incomplete, or unreliable information. The comments strongly encourage the Service to use sound science as a fundamental tool when assigning a priority level to any species, including any decision that a species warrants the highest priority level.

This letter provides the comments of the American Petroleum Institute (API) and the Independent Petroleum Association of America (IPAA) (the “Associations”) in response to the U.S. Fish and Wildlife Service’s proposed rule and associated draft environmental impact statement (DEIS) addressing the management of non-federal oil and gas rights on National Wildlife Refuge System (NWRS) lands and waters. See 80 Fed. Reg. 77,200 (Dec. 11, 2015). The Associations appreciate the Service’s consideration of these comments.

On behalf of the Center for Liquefied Natural Gas, the Natural Gas Supply Association and the Independent Petroleum Association of America, we write to applaud the Senate Energy and Natural Resources Committee for the hard work you have done moving S. 2012 – The Energy Policy Modernization Act (EPMA) – through Committee in July of 2015 and bringing it to Senate floor. Specifically, we are encouraged to see the inclusion of Section 1306 (Vehicle Research and Development), Section 1308 (Commercial and Transit Vehicles), Section 2201 (Action on applications to export liquefied natural gas), Section 2202 (Public disclosure of liquefied natural gas export destinations) and Section 3102 (Study on the economic impacts of liquefied natural gas exports) in the bipartisan legislative proposal. We strongly believe the passage of this legislation will help to accelerate the creation of a thriving domestic liquefied natural gas (LNG) industry.

Joint Letter with the American Stewards of Liberty, the Texas Public Policy Foundation, and Dr. Steven Carothers notifying the U.S. Fish and Wildlife Service that petitioners intended to file a civil suit against the agency in 60 days, following the Service’s failure to announce its 90-day finding on the petition to delist the American burying beetle.

The Independent Petroleum Association of America (IPAA) and its members welcome this opportunity to respond to the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) notice of proposed rulemaking referenced above. In particular, that notice proposes (i) the extension of reporting requirements to all gathering lines, (ii) the extension of reporting requirements to all gravity lines moving hazardous liquids, (iii) the inspection of all pipelines in areas affected by extreme weather or natural disasters, (iv) to require periodic integrity testing of pipelines outside of High Consequence Areas (HCAs), (v) to require the use of leak detection systems on hazardous liquid pipelines in all areas, (vi) to add additional conservatism to provisions requiring pipeline repairs as well as requiring repairs on all pipelines even those outside HCAs, and (vii) that all Integrity Management (IM) subject pipelines be capable of supporting inline inspection tools (ILIs) within twenty years, unless the basic construction thereof will not support ILIs.

Dear Mr. Kassman: On October 26, 2015 the National Park Service (NPS) issued a proposed rule entitled “General Provisions and Non-Federal Oil and Gas Rights; Proposed Rule” (80 Fed. Reg. 65571, the Proposed Rule). This Proposed Rule would modify service-wide regulations governing the exercise of non-federal oil and gas rights on NPS units, under 36 CFR part 9, subpart B (9B regulations). API, the Independent Petroleum Association of America, Western Energy Alliance, and the American Exploration & Production Council join in submitting these comments to the proposed rule.

Dear Mr. Kornze: On October 13, 2015, the Bureau of Land Management (BLM) issued a proposed rule entitled “Onshore Oil and Gas Operations; Federal and Indian Oil and Gas Leases; Measurement of Gas” (80 Fed. Reg. 61,646). This Proposed Rule would replace Onshore Oil and Gas Order No. 5, Measurement of Gas, which prescribes standards for the measurement of gas produced from onshore federal and Indian oil and gas leases with new, more expansive regulations that would be codified in Title 43 of the Code of Federal Regulations (CFR). It would also replace, and incorporate into Title 43 of the CFR, various nationwide and state-specific Notices to Lessees (NTLs), which contain BLM policy and guidance for the measurement of gas produced from onshore federal and Indian oil and gas leases.