Letters & Comments

Dear Mr. Southall: On January 6, 2015, the Office of Natural Resources Revenue (ONRR) issued a Proposed Rule entitled “Consolidated Federal Oil & Gas and Federal & Indian Coal Valuation Reform.” This rule would significantly alter regulations applicable to gas valuation for royalty reporting and payment by oil and gas lessees (and other lessees) on federal lands onshore and on the Outer Continental Shelf (OCS). It also would materially amend the corresponding regulations governing oil valuation last overhauled in 2000. The American Petroleum Institute (API), the Independent Petroleum Association of America (IPAA), and the National Ocean Industries Association (NOIA) appreciate the opportunity to submit comments on this Proposed Rule.

The American Exploration & Production Council (AXPC) and the Independent Petroleum Association of America (IPAA) appreciates the opportunity to offer comments on the Revised Guidelines for Implementing Executive Order 11988, Floodplain Management of 28 January, 2015, issued by the Mitigation Framework Leadership Group (MFLG) of the Federal Emergency Management Agency (FEMA) of the Department of Homeland Security. Additionally, we support and incorporate, by reference, the comment letter of the American Petroleum Institute (API) “Comments on proposed Revised Guidelines for Implementing Executive Order 11988, Floodplain Management”.

The American Chemistry Council, American Coalition for Clean Coal Electricity, American Coke and Coal Chemicals Institute, American Forest & Paper Association, American Fuel & Petrochemical Manufacturers, American Iron and Steel Institute, American Petroleum Institute, American Wood Council, Brick Industry Association, Council of Industrial Boiler Owners, Electricity Consumers Resource Council, Independent Petroleum Association of America, Industrial Energy Consumers of America, International Liquid Terminals Association, National Association of Manufacturers, National Lime Association, National Mining Association, National Oilseed Processors Association, Portland Cement Association, Texas 2 Cotton Ginners’ Association, The Aluminum Association, and the U.S. Chamber of Commerce appreciate the opportunity to submit the following comments in response to the Environmental Protection Agency’s (EPA’s) proposed Approval and Promulgation of Implementation Plans; Texas and Oklahoma; Regional Haze State Implementation Plans; Interstate Transport State Implementation Plan to Address Pollution Affecting Visibility and Regional Haze; Federal Implementation Plan for Regional Haze and Interstate Transport of Pollution Affecting Visibility, Proposed Rule, Docket ID No. EPA-R06- OAR-2014-0754, FRL-9920-11-Region-6.

The Natural Gas Council submits these comments in response to the Council on Environmental Quality’s (“CEQ”) revised draft guidance regarding the consideration of greenhouse gas (“GHG”) emissions and the effects of climate change in federal departmental and agency reviews under the National Environmental Policy Act (“NEPA”). The Natural Gas Council collectively represents segments along the entire natural gas value chain that produce, transport, deliver, and use clean, affordable, natural gas throughout the United States. The draft CEQ guidance calls upon over 80 federal agencies and departments to consider GHG and climate impacts analysis as part of any NEPA review required for federal proposed actions and would be applicable to all land and resource management decisions. Natural gas pipeline and related facility projects must undergo NEPA review and, therefore, the Natural Gas Council value chain has a direct interest in the outcome of this proceeding.

Dear Chairman LaFleur: The Natural Gas Council, and other entities representing the natural gas value chain, submit these comments in response to the fuel assurance reports Independent System Operators and Regional Transmission Organizations filed on February 19, 2015, as directed by the Federal Energy Regulatory Commission’s November 20, 2014 Order on Technical Conferences in the above-referenced proceedings. The Order directed each ISO/RTO to file a report on the status of its efforts to address fuel assurance.

The United States Fish and Wildlife Service (FWS) is currently considering whether to list the northern-long-eared bat (NLEB) as endangered or threatened under the Endangered Species Act (ESA). The Independent Petroleum Association of America (IPAA) and the American Petroleum Institute (API) believe, as stated in their previous comments, that a listing is not necessary and will have little impact on the future of the NLEB.

Assessing the need for a revised Ozone National Ambient Air Quality Standard (Ozone NAAQS) hinges on the quality of the health analysis to determine the ambient concentrations of ozone that create adverse effects and on the implications of control strategies to meet the Ozone NAAQS. IPAA’s analysis of the Environmental Protection Agency (EPA) material on its proposed revisions to the Ozone NAAQS concludes that EPA fails to justify any change in the
current NAAQS.

The following comments are provided on behalf of the American Petroleum Institute and the Independent Petroleum Association of America in response to the re-opened comment period for the proposed rule by the U.S. Fish and Wildlife Service (FWS) to List the Eastern Small Footed Bat and the Northern Long-Eared Bat as Endangered or Threatened Species; Listing the Northern Long-Eared Bat as an Endangered Species (78 Fed. Reg. 60146).