Letters & Comments

Letters and Comments Apr 23, 2018

To Whom it May Concern: Western Energy Alliance (the Alliance) and the Independent Petroleum Association of America (IPAA) appreciate the opportunity to provide comments on the Bureau of Land Management’s (BLM) proposed revisions of certain provisions of the Methane and Waste Prevention rule, or 2016 rule. The 2016 rule as promulgated exceeded BLM’s authority under the Mineral Leasing Act (MLA), and that the decision to re-evaluate the rule is required. The proposed revision rule more accurately captures the scope of BLM’s waste minimization authority, and will better ensure federal mineral interests are adequately protected without excessively burdening federal lands development with overreaching regulations.

Letters and Comments Apr 18, 2018

Dear Mr. Kudlow: The Independent Petroleum Association of America (IPAA) congratulates you as you assume the directorship of the National Economic Council. IPAA is the leading, national upstream trade association representing thousands of independent oil and natural gas producers and their service companies across the United States. Independent producers develop 95 percent of the nation’s oil and natural gas wells. These companies account for 54 percent of America’s oil production, 85 percent of its natural gas production, and support over 2.1 million American jobs.

Letters and Comments Apr 10, 2018

Dear Mr. President: The United States is now the leading natural gas producer in the world. Greater use of natural gas here in the U.S. and through LNG exports can yield tremendous benefits to our economy. The key to realizing the full value of natural gas is the continued development of a robust natural gas infrastructure along the entire value chain so that natural gas can be delivered wherever and whenever it is needed. The need for new energy infrastructure has never been more important, as new natural gas supplies present new opportunities for our economy to take advantage of this abundant and low-cost energy resource.

Letters and Comments Apr 9, 2018

Dear Leaders McConnell and Schumer: The Independent Petroleum Association of America (IPAA) supports the nomination of Andrew Wheeler to be Deputy Administrator at the Environmental Protection Agency and looks forward to the advancement of his nomination to the full Senate for consideration.

Letters and Comments Mar 27, 2018

Dear Deputy Secretary Bernhardt: We would you like thank you and the Department of the Interior (DOI) for recent actions that rescinded and revised mitigation policies that far exceeded statutory authority. The oil and natural gas industry continues to follow the statutory mitigation hierarchy to avoid, minimize, rectify, reduce and compensate for the impacts to lands and natural resources from energy development that powers our Nation. We look forward to working with DOI in developing reasonable mitigation policies that allow for the proper balance of species and habitat conservation with responsible resource development.

Letters and Comments Mar 22, 2018

Dear Chairman Brady and Ranking Member Neal: The associations submitting this letter request that our comments be included in the record for the hearing
held on March 22 with Commerce Secretary Wilbur Ross. Our specific comments relate to the Section 232 tariffs recently imposed on steel imports, and the impact these new tariffs will have on the entire energy sector, including pipelines.

Letters and Comments Mar 19, 2018

With this letter, the American Exploration and Production Council (AXPC), the Independent Petroleum Association of America (IPAA), and the American Petroleum Institute (API) are pleased to submit these comments in response to the captioned public notice, published in the Federal Register December 20, 2017, in which the U.S. Fish & Wildlife Service (USFWS or the Service) announced 90-day findings on several petitions to list or reclassify wildlife or plants under the Endangered Species Act of 1973, as amended (ESA), including the Tricolored bat (Perimyotis subflavus).

Letters and Comments Mar 19, 2018

Pursuant to Rule 212 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“Commission” or “FERC”), 18 C.F.R. § 385.212 (2016), the Advanced Energy Economy, American Council on Renewable Energy, American Petroleum Institute, American Wind Energy Association, American Public Power Association, Electric Power Supply Association, Electricity Consumers Resource Council, Interstate Natural Gas Association of America, Independent Petroleum Association of America, Natural Gas Supply Association and Solar Energy Industries Association (collectively, “Energy Industry Associations”) hereby respectfully submit this motion for extension of time for filing reply comments in response to the filings made in this proceeding on March 9, 2018 by the Regional Transmission Organizations/Independent System Operators (“RTOs/ISOs”). For the reasons discussed below, the Energy Trade Associations request a thirty (30) day extension of the deadline for reply comments established in the Commission’s January 8, 2018 Order in this proceeding.

Letters and Comments Mar 12, 2018

Pursuant to the public notice issued by the United States (“U.S.”) Army, Corps of Engineers (“Corps”) Fort Worth District on January 9, 2018 (“Public Notice”) and as amended on February 1, 2018 with a 30-day extension of the public comment period, the American Petroleum Institute (“API”), the Texas Oil & Gas Association (“TXOGA”), the Independent Petroleum Association of America (“IPAA”) and the American Exploration & Production Council (“AXPC”) hereinafter “the Associations,” respectfully submit these comments on the proposed Additional Guidelines Covering Specific Elements for the Establishment of New Mitigation Banks in the Fort Worth District (“draft Guidelines”). We appreciate your consideration of our request to extend the public comment period. We have taken that opportunity to more carefully review the draft Guidelines. The Associations support the goals of predictability and transparency in mitigation banking. However, the significantly expanded draft Guidelines impose numerous additional unnecessary and unreasonably stringent requirements that will have the following effects: 1) substantially reduce lands available for mitigation banking (thereby hindering conservation goals as well as delaying energy and water infrastructure project development); 2) generate further inefficiencies in an already protracted permitting process; and 3) conflict with existing federal Executive Orders and regulatory reform efforts to promote consistency among the Corps districts. In light of these significant consequences and contemporaneous relevant reform efforts at the federal level, the Associations request that the Fort Worth District refrain from finalizing these draft Guidelines and instead focus on reviewing, modifying, and updating its existing guidance in coordination with the Corps Headquarters and stakeholders.

Letters and Comments Mar 9, 2018

The Independent Petroleum Association of America (IPAA) appreciates the opportunity to submit comments regarding the Converse County Oil and Gas Project Draft Environmental Impact Statement (DEIS) and urges the BLM to adopt the Preferred Alternative (Alternative B). We also urge the agency to issue a Final Environmental Impact Statement (FEIS) and Record of Decision (ROD) before the end of 2018. IPAA is the leading, national upstream trade association representing oil and natural gas producers and service companies. IPAA represents thousands of independent oil and natural gas explorers and producers, as well as the service and supply industries that support their efforts. Many IPAA member companies actively produce oil and natural gas from leases on federal lands in Wyoming and throughout the Intermountain West.

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.