Member Login
 

Letters & Comments

Letters and Comments Jul 21, 2023

Dear Ms. Bohman:

The American Petroleum Institute, the American Exploration & Production Council, Independent Petroleum Association of America, The Petroleum Alliance of Oklahoma, and the Offshore Operators Committee (collectively “Industry Trades”) appreciate the opportunity to offer comments to the U.S. Environmental Protection Agency (EPA) on the proposed “Revisions and Confidentiality Determinations for Data Elements under the Greenhouse Gas Reporting Rule” (proposed on May 22, 2023). With this submittal, the Industry Trades seek to continue our participation in the rulemaking process as a collaborative stakeholder by providing meaningful solutions to address EPA’s goals while addressing the burden of data collection (and identifying potential unintended consequences) that could result if the rulemaking is finalized as proposed.

We have participated as key collaborative stakeholders throughout the process of developing the EPA Greenhouse Gas Reporting Program (GHGRP) by contributing expertise and proposing solutions that address EPA’s policy goals while reflecting the reality of the industry and its evolving day-to-day operating practices. The Industry Trades have directed our efforts toward seeking a balance between the burden of data collection and reporting, the need to protect sensitive information and ensure that reporting requirements are placed on the correct reporters, and the need for providing the highest quality data that will help inform decision makers and the public.

These comments reflect our continued interest in the evolution of the GHGRP to provide an accurate accounting of greenhouse gas (GHG) emissions from facilities across the full value chain of the oil and natural gas industry. Our comments cover concerns and recommendations in the wide range of sectors that relate to the operations of our collective members. …

Letters and Comments Jul 21, 2023

“These IPAA comments will focus on proposed Subpart B (Energy Consumption). The Environmental Protection Agency (EPA) argues that its initiation of Subpart B is:

…to improve the completeness of the data collected under the GHGRP, add to the EPA’s understanding of GHG data, and to better inform future EPA policy under the CAA, such as informing potential future EPA actions with respect to GHGs. Once collected, such data would also be available to improve on the estimates provided in the Inventory, by providing more information on the allocation of electricity use to different end use sectors.

In fact, it does not collect information on greenhouse gas (GHG) emissions. Instead, it requires operators to collect and submit information on the electricity and thermal energy used. Not only does this new Subpart effectively make these operators meter readers, it also misdirects their resources to obtain information far more readily available from electricity and thermal energy suppliers. From IPAA’s perspective it does not provide GHG emissions information because, for example, the electric energy source could be composited from numerous types of generation options. …”

In addition to the specific comments made herein, IPAA has joined comments submitted separately by the American Petroleum Institute (API).

Letters and Comments Jul 5, 2023

Dear Director Stone-Manning:

We appreciate the opportunity to comment on the Bureau of Land Management’s (“BLM”) Conservation and Landscape Health Proposed Rule (“Proposed Rule”). The undersigned organizations (collectively, the “Coalition”) include businesses in many areas of the broader economy, including energy, mining, grazing, and other community stakeholders that are impacted by this Proposed Rule. …

We are dedicated to ensuring that wise and lawful management practices are followed so that current and future generations may use and appreciate the natural resources with which America has been richly endowed. Our organizations and the companies and members we represent have a business presence across the country and a unique perspective on the importance and use of our public lands. Our members rely on access to public lands managed by BLM to conduct their operations and to serve their communities. Indeed, the broader business community across America depends on reliable, affordable, domestic energy and natural resources that are delivered from and across public lands to make and transport their products. As can be too often forgotten, businesses are made up of people, and hardworking Americans who live near, work on, and recreate on our public lands would be adversely affected by these proposed conservation and landscape health measures if the concerns raised in this letter are not carefully addressed. The Coalition shares the laudable goal of conserving and restoring our public lands; however, at the same time, the Coalition is concerned that the Proposed Rule exceeds BLM’s statutory authorities and conflicts with congressional directives.

With this perspective in mind, the Coalition urges BLM to reconsider the Proposed Rule. There are many ways to conduct the lawful conservation and the wise management of our country’s natural resources through appropriate actions taken pursuant to lawful authorities, including congressional actions to designate national parks, agency recommendations to Congress for additional wilderness areas, and use of Inflation Reduction Act of 2022 (“IRA”) funds for conservation efforts. But BLM’s Proposed Rule is both misguided policy and legally problematic, including for the following reasons…

Letters and Comments Jun 27, 2023

To the leaders of the Senate Energy and Natural Resources Committee, Chairman Manchin and Ranking Member Barrasso, the Natural Gas Council wrote in support of key provisions in S. 1456, the Spur Permitting of Underdeveloped Resources (SPUR) Act, which would restore predictability and balance to the permitting of natural gas infrastructure. The letter reads that the groups “believe additional changes to our nation’s permitting statutes are still needed to address the fact that current processes to site and approve new and expanded natural gas infrastructure remain slow, inefficient, and overly litigated. These ongoing challenges continue to discourage private sector investment, delay critical projects, and undermine the value of taxpayer investments.”

Letters and Comments, Uncategorized Jun 27, 2023

To the leaders of the Senate Environment and Public Works Committee, Chairman Carper and Ranking Member Capito, the Natural Gas Council wrote in support of S. 1449, the Revitalizing the Economy by Simplifying Timelines and Assuring Regulatory Transparency (RESTART) Act. The RESTART Act would streamline the agency review process with enforceable timelines, set limits to prevent frivolous legal challenges, and modernize current laws while preserving environmental protections.

Letters and Comments Jun 15, 2023

Dear Chairman Westerman,

The Independent Petroleum Association of America (IPAA) writes in support of H.R. 3397 (Rep. Curtis), a bill to require the Director of the Bureau of Land Management (BLM) to withdraw a rule of the BLM relating to conservation and landscape health. IPAA is a national upstream trade association representing thousands of independent oil and natural gas producers and service companies across the United States. Independent producers develop 91 percent of the nation’s oil and natural gas wells. These companies account for 83 percent of America’s oil production, 90 percent of its natural gas and natural gas liquids (NGL) production, and support over 4.5 million American jobs.

IPAA is pleased to support H.R. 3397 as it aims to withdraw the misguided rule that is currently being proposed by BLM. IPAA believes the proposed rule is a gross overreach of BLM’s directive and violates the statutory authority given to BLM under the Federal Lands Policy and Management Act of 1976 as well as misaligning with the Congressional intent in creating and delegating powers to the BLM. H.R. 3397 goes far in reiterating the intent of Congress to clear any ambiguity for further regulations. …

Letters and Comments, Uncategorized Jun 5, 2023

These comments are filed on behalf of the Independent Petroleum Association of America (IPAA). IPAA represents the thousands of  independent oil and natural gas explorers and producers, as well as the service and supply industries that support their efforts, that will be the most significantly affected by the actions resulting from this regulatory proposal. Independent producers drill about 91 percent of American oil and gas wells, produce 83 percent of American oil, and produce 90 percent of American natural gas.

The Environmental Protection Agency (EPA) has opened this comment center for the purpose of receiving comments on its legislatively imposed Methane Emissions Reduction Program (Methane Tax). EPA describes this program as follows:

EPA received $1.55 billion to reduce methane emissions from the oil and gas sector by providing financial assistance (grants, rebates, contracts, loans, and other activities) and technical assistance as well as implementing a statutorily required waste emissions charge. Eligible recipients for these funds include but are not limited to air pollution control agencies, other public or nonprofit private agencies, institutions, and organizations, and individuals. The program specifies that at least $700 million must be used for activities at marginal conventional wells. Section 60113 also requires EPA to implement a waste emission charge on methane emitted from applicable oil and gas facilities that emit over 25,000 metric tons of CO2e and that exceed statutorily specified waste emissions thresholds beginning in 2024. The waste emissions charge will start at $900 and increase to $1,500 per metric ton.

The format for these comments is laid out in a series of questions. IPAA provides information
on several of those questions…

Letters and Comments, Uncategorized Apr 10, 2023

Dear Chair Mallory:

The Natural Gas Council, on behalf of the people and companies who produce, transport, and deliver U.S. natural gas across this country and around the world, urges you to withdraw the National Environmental Policy Act (“NEPA”) Guidance on Consideration of Greenhouse Gas Emissions and Climate Change, 88 Fed. Reg. 1,196 (Jan. 9, 2023) (“Guidance”).

The Guidance inappropriately transforms NEPA into a tool that promotes use of certain types of energy and obstructs use of other types. The Guidance establishes a “two track” approach to NEPA review that (1) deters development of natural gas production and infrastructure by adding unduly burdensome requirements to the NEPA review of natural gas projects and (2) expedites review of wind and solar projects by exempting those projects from the requirements imposed on natural gas production and infrastructure. This disparate treatment is not grounded in law or fact, but instead appears to reflect a mistaken belief that natural gas inexorably impedes efforts to address climate change and that the federal government must discourage natural gas production and infrastructure development to successfully address climate change.

Natural gas is not an obstacle to the clean energy transition; it is an essential component of that transition. Since 2005, carbon dioxide emissions in the electric power sector have declined by about 35 percent, with a switch from coal to natural gas accounting for about two-thirds of the decline. …

Letters and Comments Mar 27, 2023

This coalition letter was sent to Members of the United States Congress on the need for permitting reform.

To the Members of the United States Congress:

Today, the single biggest obstacle to building the infrastructure of the future is a broken permitting system. That is why the undersigned list of diverse groups across the country and economy is calling on Congress to Permit America to Build by enacting meaningful, durable legislation to modernize America’s permitting processes before the end of the summer.

Public and private sector infrastructure projects will improve our economy and the lives of millions of Americans. Investing in highways, bridges, transit systems, and ports will move people and goods more quickly and efficiently. Building new energy production, transmission, and distribution projects promises to improve energy reliability and reduce emissions. Expanding access to broadband can close the digital divide, and rebuilding failing water systems will ensure safe drinking water. And we can strengthen our national security by expanding domestic production of critical technologies and the raw materials they require. But America cannot accomplish any of this if the outdated, inefficient, and unpredictable permitting process is not improved.

We are pleased to see support for modernizing our permitting process from across the ideological spectrum, and a recognition that the current system is broken. We know there are differing perspectives in Congress on how best to address current challenges. Our organizations will not agree on every issue. We are committed, however, to working with Congress to find solutions and pass meaningful and durable legislation.

As a starting point, we are united on the following principles:

·       Predictability

·       Efficiency 

·       Transparency

·       Stakeholder Input …

Letters and Comments Mar 21, 2023

Dear Speaker McCarthy and Majority Leader Scalise:

For too long, the government has interfered with energy markets, burdening American production with undue restrictions, distorting markets with wasteful government spending, and discouraging private sector production. Biden Administration actions and the Inflation Reduction Act (IRA) have enacted further red tape, higher costs, and permitting obstacles that serve as barriers to efficient and timely production in response to national and global demand. As a result, American oil and natural gas producers have been hindered from producing up to three million barrels of oil a day,1 a government imposed scarcity that has created high costs for citizens and instability in relation to our adversaries in China and Russia.

We, the undersigned 25 oil and natural gas trade associations, strongly support H.R. 1. The bill is a welcome answer to government-imposed distortions to energy markets that have decimated the energy independence that America enjoyed just a few short years ago. Make no mistake, we wholeheartedly believe in producing energy in an environmentally responsible manner that protects the nation’s air, water, land, wildlife, and cultural resources while providing billions in taxes and royalties that sustain communities and vital public services at every level of government. We are proud that American oil and natural gas are developed under the world’s most protective standards and our companies readily comply with the bedrock environmental laws. However the red tape we have experienced over the past few years is not intended to protect the environment but to handcuff American oil and natural gas production in a misguided attempt to quickly transition to an alternative reality that does not exist. The result is higher prices for all Americans and more imports from unfriendly countries. …

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.