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Letters & Comments

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. …

Letters and Comments Jun 21, 2022

Dear Secretary Granholm,

On behalf of a coalition of energy trade associations representing the full spectrum of the American energy industry, we request the opportunity to meet with you to discuss ways our companies can partner with you to lower energy costs for Americans, strengthen our domestic energy security, and assist our allies by solidifying their energy security as well.

Our coalition’s member companies work together to produce 90% of American natural gas and 83% of American oil. We represent over 770,000 energy workers who work all over the United States to produce this energy and the equipment to do so. We represent all aspects of the oil and natural gas industry, from small service and technology providers, to onshore and offshore independent producers of all sizes.

While our companies are responsible for a vast majority of domestic energy production, the effects of market and policy changes on our businesses are often magnified. Large international operators with a diverse portfolio can weather major policy changes and economic downturns, but our individual companies feel disproportionate impacts of these policy and market shifts. …

Letters and Comments Jun 14, 2022

Dear Senators,

As the backbone of the American oil and natural gas industry, our respective organizations express our firm opposition to a methane emissions tax currently being considered in Congress as part of a potential budget reconciliation package.

Since 2012, the Environmental Protection Agency (EPA) has regulated methane emissions via the Clean Air Act (CAA) New Source Performance Standards (NSPS) OOOO and OOOOa, primarily through storage tank vapor capture, pneumatic controllers, and leak detection and repair. The focus is to prevent emissions from new facilities, identify leaks as early as possible, quickly fix them, and remove the emissions from the atmosphere.

Last year, EPA released proposed revisions to its NSPS rules that would further tighten emission standards for all new sources and update guidelines for existing sources. These revisions are likely to be finalized within the next year. Because EPA tightly regulates methane, any new fee is unlikely to have a large-scale impact on overall emission levels and would merely be punitive in nature. Furthermore, the extreme impracticability of a proposed tax leads us to believe that the true intent, combined with other proposals from Congress and the Administration, is not to protect the environment but to regulate American oil and natural gas production out of existence. …

Letters and Comments Jun 13, 2022

IPAA’s comments describe how the oil and natural gas production industry is uniquely affected by the SEC climate reporting proposal, and ultimately conclude that the SEC should withdraw its proposal:

“The SEC is stepping far too aggressively into a rapidly evolving arena too soon. Information on companies’ actions to address their ESG responsibilities is growing rapidly each year. At the same time the lack of a consistent framework for presenting information inhibits the value. Time is needed to allow these diverse processes to settle into a more straightforward format.

The SEC proposal does not enhance the process. It merely creates still another burden. Moreover, by adding the materials as part of an SEC filing, it creates inappropriate liability for essentially speculative information.”

…

In addition to these comments, IPAA supports comments filed by the Chamber of Commerce, the National Association of Manufacturers, the American Petroleum Institute, the Western Energy Alliance and the American Exploration and Production Council.

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.