Letters & Comments

These materials were submitted to the Environmental Protection Agency public meeting on stormwater management during oil and gas construction activities. They were submitted by IPAA on its behalf and for a number of national, regional, and state associations. They discuss the IPAA position on EPA’s approach to regulating stormwater during oil and gas construction activities, the current management practices, and the consequences of applying EPA’s Construction General Permit.

These comments were submitted to the Environmental Protection Agency (EPA) supporting its proposal to delay the effectiveness of new stormwater related construction permit requirements for until March 2005 for Phase II (one to five acre sized) oil and gas exploration and production facilities. The comments also address suspending these permit requirements on larger facilities and other problems with the new proposed permit. The comments were filed by IPAA on its behalf and numerous federal, regional, and state trade associations.

These comments were submitted to the Environmental Protection Agency (EPA) supporting its proposal to extend the compliance dates for new Spill Prevention, Control, and Countermeasure (SPCC) Plan regulations. Additionally, they identify a number of specific issues that need to be addressed during the extension period. The comments were filed by IPAA on its behalf and numerous federal, regional, and state trade associations.

Written comments submitted by Chuck Davidson, Chairman, IPAA’s Offshore Committee

Written comments submitted for draft EPA design on the environmental risks of hydraulic fracturing.