Letters & Comments

Letters and Comments Dec 14, 2015

Dear Mr. Kornze: On September 30, 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 Oil” (80 Fed. Reg. 58,952). This Proposed Rule would replace Onshore Oil and Gas Order No. 4, Measurement of Oil (Onshore Order No. 4), which prescribes standards for the measurement of oil produced from federal and Indian onshore oil and gas leases, with new, more expansive regulations that would be codified in Title 43 of the Code of Federal Regulations.

Letters and Comments Dec 14, 2015

Dear Director Kornze: Western Energy Alliance and the Independent Petroleum Association of America (IPAA), appreciate that the Bureau of Land Management (BLM) has reopened the comment period for Onshore Order No. 3. Onshore Order No. 3 is highly complex, technical, and closely interrelated with Onshore Orders No. 4 and 5, and we appreciate this opportunity to reflect on No. 3 now that we have had some time to review 4 and 5. However, we are concerned that the timeframe to review these three proposed rules remains inadequate at just 21 days of overlap, given the fact that they run to a combined total of 591 pages in length.

Letters and Comments Dec 11, 2015

Dear Administrator McCarthy: This letter is being sent on behalf of the Independent Petroleum Association of America (IPAA), as well as several of its national, regional and state cooperating associations. A full listing of those organizations can be found at the conclusion of this letter.

Letters and Comments Dec 4, 2015

Comments for Three Regulatory Proposals issued September 18, 2015: 1) Oil and Natural Gas Sector: Emission Standards for New and Modified Sources (80 Fed. Reg. 56,593), 2) Release of Draft Control Technique Guidelines for the Oil and Natural Gas Industry (80 Fed. Reg. 56,577), 3) Source Determination for Certain Emission Units in the Oil and Natural Gas Sector (80 Fed. Reg. 56,579). These comments are filed on behalf of the Independent Petroleum Association of America (IPAA) and the American Exploration and Production Council (AXPC).

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.

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.