Letters & Comments

Letters and Comments Nov 17, 2015

The Independent Petroleum Association of America (IPAA) and the American Petroleum Institute (API) respectfully submit the following comments on the U.S. Fish & Wildlife Service’s 90-Day Finding on the petition of Xerces Society for Invertebrate Conservation to list the rusty-patched bumble bee (RPBB) as an endangered species under the Endangered Species Act. 80 Fed. Reg. 56,423, 56,429 (Sept. 18, 2015).

Letters and Comments Nov 16, 2015

On behalf of our members, the Independent Petroleum Association of America (IPAA) would like to provide additional comments on the Bureau of Ocean Energy Management’s (BOEM) proposed guidance on the agency’s supplemental bonding requirements. IPAA submitted detailed comments to the Department of the Interior in response to the Advanced Notice of Proposed Rulemaking (ANPR) on this matter last year and is disappointed that the agency decided to forgo a formal rulemaking process. We are greatly concerned that new regulations will be issued through a revised Notice to Lessee (NTL) without any corresponding changes to the Code of Federal Regulations, thus creating new binding requirements outside the rulemaking procedures of the Administrative Procedures Act (APA). The BOEM contemplates significant changes to the regulations governing offshore activities and such changes should be promulgated as rules through the APA, not through a guidance document such as an NTL. Attached is a copy of the extensive comments IPAA filed on this matter with the Department last November.

Letters and Comments Oct 20, 2015

The American Petroleum Institute (API), the National Ocean Industries Association (NOIA), the Offshore Operators’ Committee (OOC) and the Independent Petroleum Association of America (IPAA) respectfully request that the Bureau of Ocean Energy Management (BOEM) extend the 45 day period for comments on the proposed guidance that BOEM will use to determine a lessee’s financial ability to carry out its obligations, primarily the decommissioning of OCS facilities, and the potential need for additional security posted on BOEM’s website on September 22, 2015. We appreciate the opportunity to review the draft guidance and the workshop that BOEM held on October 9. After reviewing the proposal and hearing BOEM’s presentation at the workshop, industry feels that 30 additional days are needed to fully analyze the potential impacts of the changes and to provide constructive feedback. Accordingly, we respectfully request that the deadline for comments on this proposed guidance be extended to December 6, 2016.

Letters and Comments Oct 9, 2015

Dear Director Kornze: Western Energy Alliance and the Independent Petroleum Association of America (IPAA), appreciate the opportunity to comment on the proposed changes to Bureau of Land Management (BLM) Onshore Order No. 3, which would be codified in the Code of Federal Regulations through modifications to 43 C.F.R. Part 3160 and the addition of new Part 3170. While recognizing the need to keep regulations current with modern technology and industry standards, the Associations are concerned that the proposed rule change would result in substantial changes to the way domestic onshore oil and gas operations are conducted, leading to an unwarranted increase in costs and burdens to domestic oil and natural gas producers. These costs would be incurred largely without a concomitant benefit to the federal government or the public at large and create further disincentives for oil and natural gas producers to invest in development on federal public and tribal lands. Moreover, some of these revisions would require physical changes with impacts to the environment and socio-economic impacts that have not been adequately analyzed in the Environmental Assessment for the proposed rule.

Letters and Comments Sep 18, 2015

The United States Fish and Wildlife Service and the National Marine Fisheries Service proposed a series of amendments to the regulations at 50 CFR § 424.14 that govern the content and consideration of petitions filed with the Services pursuant to the Endangered Species Act. The proposed amendments are intended to “improve the specificity of petitions and to enhance the efficiency and effectiveness of the petition process to support species conservation.” IPAA and API strongly support the efforts of the Services to achieve those goals by, among other things: 1) requiring that petitions be limited to a single species; 2) requiring consultation with states prior to the submission of petitions; 3) ensuring that petitions identify, clearly label and append all reasonably available information relevant to the petitioned action and species, including information that may support a finding that the petitioned action is not warranted; 4) providing clear direction as to the information necessary for submission of a complete petition; and 5) clarifying that a petitioner’s submission of supplemental information after filing of a petition will re-start the statutory timeframe for review.

Letters and Comments Jul 27, 2015

IPAA and API submitted joint comments to the U.S. Fish and Wildlife Service as it looks at permitting incidental take under the Migratory Bird Treaty Act. The comments question whether the approaches described in the Service’s Notice of Intent are authorized by or consistent with the intent of the statute upon which the Service relies.

Letters and Comments Jul 24, 2015

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 introducing the Energy Policy and Modernization Act of 2015 (EPMA 2015). Specifically, we are encouraged by the inclusion of Section 2201 (Action on applications to export liquefied natural gas) and Section 2202 (Public disclosure of liquefied natural gas export destinations) in the bipartisan legislative proposal. We believe that the passage of this legislation will help to accelerate the creation of a thriving domestic liquefied natural gas (LNG) industry by providing greater certainty to the export permit review process.

Letters and Comments Jul 16, 2015

To whom it may concern: The American Petroleum Institute (API), the International Association of Drilling Contractors (IADC), the Independent Petroleum Association of America (IPAA), the National Ocean Industries Association (NOIA), the Offshore Operators Committee (OOC), the Petroleum Equipment & Services Association (PESA), and the US Oil and Gas Association respectfully submit the following comments on the proposed regulatory changes to Blowout Prevention Systems and Well Control requirements in 30 C.F.R. part 250. The Bureau of Safety and Environmental Enforcement (BSEE) announced these proposed changes on April 17, 2015, in a notice of proposed rulemaking entitled, “Oil and Gas and Sulphur Operations in the Outer Continental Shelf—Blowout Preventer Systems and Well Control.”

Letters and Comments Jul 16, 2015

We believe that EPA’s analysis is flawed and fails to realistically undertake its responsibilities under the Clean Water Act (CWA) to create ELGs that meet not only current circumstances but future needs as well. Consequently, we recommend that EPA withdraw the current proposed pretreatment ELG for UOG extraction waste water, that it conduct a thorough review of actual waste water management technologies, that it determine best available technology economically achievable and new source performance standards based on these technologies, and that it then repropose an appropriately revised pretreatment ELG.

IPAA is the industry's strongest presence in the nation's capital and these are important times. The entire oil and gas industry remains under fire from anti-development groups; but with these challenges arise unique opportunities that IPAA is seizing for our members.