Letters & Comments

Letters and Comments Oct 4, 2022

The Independent Petroleum Association of America (IPAA) appreciates the opportunity to comment on the Interior Department’s 2023-2028 “Proposed Program” for the Outer Continental Shelf Oil and Gas Leasing Program (National OCS Program). IPAA is the national trade association representing the thousands of independent crude oil and natural gas explorers and producers in the United States. Our members operate both onshore on federal, state, and private lands as well as offshore in the OCS and Alaska. IPAA also operates in close cooperation with forty-four unaffiliated independent national, state, and regional associations, which together represent thousands of royalty owners and the companies that provide services and supplies to the domestic industry. IPAA is dedicated to ensuring a strong and viable domestic oil and natural gas industry, recognizing that an adequate and secure supply of energy developed in an environmentally responsible manner is essential to the national economy.

On Friday, July 1, 2022, the Interior Department released its 2023-2028 “Proposed Program” for the Outer Continental Shelf Oil and Gas Leasing Program (National OCS Program). While the release of the Proposed Program was welcome after many months of delay, our nation is still left in the unfortunate position of facing a substantial gap between National OCS Programs for the first time since issuing programs were required in the early 1980s.

Perhaps the most concerning part of the Proposed Program is the fact that the proposal leaves open the possibility of scheduling no lease sales from 2023 to 2028. Simply put, a National OCS Program devoid of lease sales would be a significant blow for the country’s energy future and security needs. In addition, scheduling no lease sales would not satisfy the requirements of the OCS Lands Act.  At a time when the nation is suffering from skyrocketing energy prices and is increasingly turning to foreign nations to supply our energy needs, scheduling zero offshore lease sales for the next five years would be a devastating blow to the U.S. energy industry and do irreparable harm…

Letters and Comments Sep 7, 2022

The undersigned organizations write to express our concerns with the U.S. Environmental Protection Agency (EPA) Region 10’s 2022 Proposed Determination to prohibit and restrict the use of certain waters within defined areas as disposal sites within the Pebble Deposit Area under Section 404(c) of the Clean Water Act (CWA).

We represent a large and diverse cross-section of America’s construction, home building, mining, manufacturing, and energy sectors, as well as the broader business community. Our members are vital to building a thriving national economy and are essential to achieving the Biden administration’s ambitious climate, infrastructure, supply chain, transportation, and energy goals. Our members create much needed and well-paying jobs in communities across the country, including in Tribal communities and communities with environmental justice concerns. Fair, consistent, and predictable permitting processes are essential for our members to conduct these activities. If finalized as proposed, EPA’s preemptive veto of the Pebble Project in Alaska will set harmful precedent and create significant regulatory uncertainty for the business community.

We therefore urge EPA to withdraw the proposed determination to allow the Pebble Project to move through the established regulatory process. We also offer the following comments…

Letters and Comments Aug 15, 2022

Dear Chairman Behnam:

…Over the past 20 years, Russia has moved aggressively to link Europe’s economy to Russia’s natural gas. Russia’s war with Ukraine creates wide ranging international issues regarding natural gas. Clearly, one of these issues is volatility in the natural gas markets both in Europe and the United States. Significantly, it also gives Russia, Gazprom or their agents the possibility to utilize “perfect information” to manipulate the markets for energy commodities in both the United States and Europe.

Hopefully, the Commodity Futures Trading Commission (CFTC) is already investigating this possibility. If so, IPAA would like to know that is the case and, if not, IPAA strongly encourages the CFTC to begin an investigation under its granted authorization.

Specifically, IPAA is concerned about the following four items/issues:

  1. Excessive speculation
  2. Market manipulation, squeezes and corners
  3. Market liquidity for bona fide hedgers
  4. Price discovery disruption

IPAA would also like to know if there is any joint investigation with the CFTC’s counterparts in Europe, such as the European Commission. …

Letters and Comments Aug 11, 2022

IPAA joined with API and nearly 60 other trade groups representing America’s natural gas and oil industry in opposing the Inflation Reduction Act (IRA) as passed by the Senate. In a letter to House Speaker Nancy Pelosi and Minority Leader Kevin McCarthy, the organizations outline problematic provisions, including punitive new taxes and regulatory red tape that undermine the industry’s ability to promote energy security for the American consumer.“We share the goal of addressing climate change, as evidenced in the policies we support and in the actions that we take every day,” the letter states. “However, the considerable tax increases and new government spending in the IRA amount to the wrong policies at the wrong time.”The letter further cites the absence of comprehensive of permitting reform legislation, which is required to advance America’s infrastructure needs and meet growing demand for affordable and reliable energy.“Finally, the IRA fails to address permitting reform, which is desperately needed and is essential to effectively deliver affordable, reliable energy to consumers in a growing economy,” the signatories wrote. “To date, neither the House nor the Senate have introduced comprehensive permitting reform legislation. We urge Congress to quickly consider and pass permitting reform without delay.”

Letters and Comments Aug 9, 2022

With the Senate having passed H.R. 5376 this past weekend, our industry again wishes to express our sincere concerns with several of the provisions included in the bill. These concerns are nothing new as we have been discussing various provisions in legislative initiatives since the beginning of the Congress.

We collectively represent most of the small and mid-sized exploration and production industry and the millions of workers in the United States. With that in mind, we request your consideration of the negative impacts this bill will have on the oil and gas industry as well as our consumers, the manufacturers who rely on us, the agriculture industry, and the transportation industry. In short – this bill will exacerbate supply concerns at a time of high crude and gasoline prices.

Letters and Comments Aug 8, 2022

This letter provides comments in response to the U.S. Environmental Protection Agency’s  proposed rule revising and replacing the Agency’s 2020 Clean Water Act Section 401 Certification regulations1 (“2020 Rule”). As explained in more detail below, the 2020 Rule provided long-overdue clarification on the role of states and other certifying authorities under Section 401 of the Clean Water Act (“CWA” or “the Act”). The proposed rule would eliminate the clarity and consistency that the 2020 Rule afforded project proponents and certifying authorities alike, while needlessly delaying nationally important projects or critical infrastructure such as those to modernize our nation’s means of generating and transporting energy, as well as our commitment to directing investment to the infrastructure needs of underserved communities.

Letters and Comments Aug 4, 2022

Dear Senator:

We, the undersigned trade associations, representing hundreds of thousands of businesses across the nation that collectively employ millions of Americans, write to express our opposition to the inclusion of a tax on the financial statement income of certain businesses (“book tax”) in H.R. 5376, the “Inflation Reduction Act” reconciliation legislation.

Economic analyses demonstrate the harmful impact of this provision. The nonpartisan Joint Committee on Taxation found that nearly 50% of the burden of this tax would fall on manufacturers. The National Association of Manufacturers found that in 2023 alone this would result in 218,108 fewer jobs, reduce real GDP by $68.45 billion and decrease total wages by $17.11 billion.

Letters and Comments Jul 21, 2022

IPAA joined API and other oil industry groups in writing a letter to White House officials on how the EPA’s potential move to issue a nonattainment designation for parts of the Permian Basin could lead to “increased operating expenses, decreased federal leasing revenues, permitting delays and decreased oil and natural gas production in the nation’s most productive basin.

Letters and Comments Jul 20, 2022

IPAA joined the American Exploration & Production Council and other industry trade groups in writing to President Biden opposing the declaration of a climate emergency that would advance false climate solutions. The groups urge him to reject ill-conceived policies that would drive up energy costs and global emissions. Rather than declare a climate emergency with policies that reduce domestic oil and natural gas production, the letter calls on the president to work with American energy producers to meet the dual challenge of providing affordable and reliable energy to the world, while addressing global climate change.

Letters and Comments Jun 23, 2022

Dear Mr. President,

On behalf of millions of Americans working in the U.S. oil and natural gas industry, we wish you every success on your upcoming trip to Saudi Arabia. But before you visit Riyadh, we invite you to visit Reynoldsville, Pa. It’s the heart of the Marcellus Shale in the state where you were born, one of the most prolific natural gas-producing regions in the world.

It’s also one of many places that America, the world’s largest producer of oil and natural gas, has a chance to assert new leadership in the face of today’s energy crisis. Before you board Air Force One for the Middle East, we hope you will consider taking another look at made-in-America energy. We would be honored to show you how our industry is involved in every step of the energy process, from fuel pumps to critical product delivery infrastructure to production zones across our vast nation.

First, come tour one of America’s refineries – currently operating at 94% of capacity, among the highest in the world – where the fuels are made to keep America’s 275 million registered vehicles running. America’s 125 refineries are producing more diesel (and renewable diesel), jet fuel, gasoline, and other refined product than at any point on average over the past five years.

Next, come visit Colonial Pipeline’s state-of-the-art command center, which controls the 5,500-mile critical infrastructure that safely carries millions of gallons of fuel products from Gulf Coast refineries through the South and up the East Coast every day.

Finally, join us in one of America’s major energy-producing areas – along the shores of the Gulf of Mexico; in Alaska, the Marcellus, the Permian or the Bakken basins; or even Kern County, Calif. – which together launched the American energy revolution that ended decades of U.S. energy scarcity and growing dependence on foreign governments. In the process, American energy has created millions of good-paying U.S. jobs, worked to shrink our environmental footprint, boosted economic growth, funded conservation in nearly every U.S. county, and transformed entire states – as the Marcellus did, turning Pennsylvania into a powerhouse of natural gas. …

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.