IPAA and Cooperating Associations Comments to the U.S. Department of Transportation on its Notification of Regulatory ReviewLetters and Comments Dec 1, 2017
In accordance with the Federal Register notice, issued on October 2, 2017 and revised on November 3, 2017, the Independent Petroleum Association of America (IPAA) and its members, along with the Kentucky Oil & Gas Association, the Ohio Oil and Gas Association, and the Pennsylvania Independent Oil & Gas Association (collectively, Independent Producers), submit the following comments on existing rules and other agency actions that are good candidates for repeal, replacement, suspension, or modification. The Independent Producers represent the companies that drill 90 percent of the nation’s oil and natural gas wells. These companies produce 82 percent of American natural gas and 68 percent of American oil. The Independent Producers’ members represent the full range of producers, from small family‐owned businesses, to the large independent companies that are some of the largest American natural gas producers. The Independent Producers’ recommendations focus on three issues under the auspices of the Pipeline and Hazardous Materials Safety Administration (PHMSA): Sampling and testing for unrefined petroleum‐based products; Regulatory treatment of farm taps off production lines; and Proposed regulations affecting gathering lines and production facilities.