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Letters & Comments

Letters and Comments Mar 24, 2021

In advance of the Thursday, March 25 Department of Interior virtual forum regarding the federal oil and gas program, the Independent Petroleum Association of America (IPAA) submitted a written statement to inform the department’s interim report that the agency said will be released early summer with findings from their comprehensive review.

“…IPAA and our members are extremely concerned about efforts by the Biden Administration to alter the foundational elements of the Department of Interior’s oil and natural gas leasing program for onshore and offshore federal lands. Federal lands and waters together accounted for 22 percent of total U.S. oil production and 12 percent of U.S. natural gas production in 2019, according to the Energy Information Administration. ... Production of oil and natural gas from these areas are an important part of the nation’s energy portfolio and will be key to ensuring the United States remains a key player in the worldwide energy picture. …

“Responsible development of federal lands in the West and in federal offshore waters with a regulatory program designed to protect the environment and public is achievable. IPAA and our members look to coordinate and cooperate with federal and state regulators to find innovative solutions that address climate issues, management of methane and protect and reclaim federal lands…” 

Click here for IHS Markit study on independent oil and natural gas operators referenced in the statement. 

Infrastructure, Letters and Comments Mar 2, 2021

As Congress develops infrastructure legislation to stimulate the economy and improve the quality of life for every American, the undersigned organizations urge you to prioritize improvements to the federal permitting process. We fully support the fundamental environmental stewardship goals of the National Environmental Policy Act (NEPA), and believe a modernized NEPA process would enhance the ability to realize our shared goals of COVID-19 economic recovery and continued progress on environmental protections, including climate change.

Letters and Comments Feb 23, 2021

Madam Speaker:

The Independent Petroleum Association of America (IPAA) is opposed to H.R. 803, the “Protecting America’s Wilderness and Public Lands Act.” This bill creates nearly 1.5 million acres of new wilderness and permanently withdraws 1.2 million acres from mineral production. It is in direct opposition to the multiple use mandate given to the Department of the Interior to manage the federal estate. Many of the local communities impacted by this measure, including Garfield County in Colorado which has existing mineral leases and planned for further development, have raised significant concerns due to the elimination of multiple use of the land and the overall threat to local economies and rural jobs…

Letters and Comments Feb 16, 2021

Subject: Updates to the Social Cost of Carbon, Social Cost of Nitrous Oxide and Social Cost of Methane; Modernizing Regulatory Review Memorandum for Heads of Executive Departments and Agencies. 

Dear Acting Director Fairweather, Ms. Leonard, Dr. Fisher and Deputy Administrator Mancini: 

On January 20, President Biden signed Executive Order 13990, “Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis.”1 A key component of that order focuses on accounting for the benefits and costs of reducing greenhouse gas emissions, including revising guidance regarding the Social Cost of Carbon (SCC), Social Cost of Nitrous Oxide (SCN) and Social Cost of Methane (SCM). 

Under the order, the President has directed an interagency working group to update these estimates based in part on recommendations from the National Academies of Sciences (NAS). The group is tasked with publishing interim estimates of these economically significant values within 30 days of the Order and a final set of updated estimates by January 2022. 

The undersigned associations support the establishment of an Interagency Working Group on Social Cost of Greenhouse Gases (the “IWG”) with broad interagency representation. We encourage the IWG to adhere objectively and comprehensively to the directed mission and methodology to “consider recommendations of the National Academies of Science, Engineering, and Medicine as reported in Valuing Climate Damages: Updating Estimation of the Social Cost of Carbon Dioxide (2017).” 

However, it is not clear what the process is to solicit public and stakeholder input for developing the interim estimates presumably by February 19, 2021 or final estimates by January 2022…

…In summary, we believe that the directives associated with updating these values should adhere to rigorous methodology including ample channels and opportunities for public and stakeholder input. 

As members of the regulated community, we look forward to participating in this process.

Letters and Comments Dec 29, 2020

The Office of the Comptroller of the Currency (OCC) solicits comments on issues related to the fair access to financial services related to potential actions taken by the largest banks that might categorically exclude certain sectors or industries from access to the capital they need to develop their businesses. …

Unfortunately, for the past several years, America’s essential oil and natural gas production industry has become a target for several “Keep It in the Ground” environmentalist lobbying operations. These organizations have turned from their historic regulatory focus to a broader arena of actions including attacking capital sources.

Letters and Comments, Offshore Dec 14, 2020

This week, IPAA submitted formal comments to the Bureau of Ocean Energy Management (BOEM) rulemaking regarding offshore company financial assurance and bonding. While IPAA represents member companies that advocated for differing interests with this rule, we are ultimately glad to see the Administration try to offer solutions to the current system, which all Member companies agree is broken. Furthermore, we commend the Administration for going through the proper regulatory channels to propose this rule.

Letters and Comments, Offshore Dec 11, 2020

IPAA signed a National Ocean Policy Coalition-led letter to President-elect Biden requesting support for collaborative, transparent, and balanced multi-use ocean policies that support economic and environmental goals and help achieve mutual desires for greater economic prosperity and job creation.

The letter was signed by 70 groups representing a wide array of commercial and recreational interests from across the United States.

Letters and Comments, Offshore Dec 8, 2020
IPAA joined numerous offshore trade associations in supporting the Conservation Funding Protection Act, which aims to provide much needed certainty to help maintain robust domestic energy production in the Gulf of Mexico and shore up conservation programs. The bill was introduced by Sen. John Kennedy (R-La.) and co-sponsored by Sens. Cindy Hyde-Smith (R-Miss.), Bill Cassidy (R-La.), Ted Cruz (R-Texas), John Cornyn (R-Texas) and Roger Wicker (R-Miss.).
Enacting the Conservation Funding Protection Act is an important step in meeting our national goals of economic recovery, supporting national fiscal health, and supporting national security and national environmental objectives. In this letter to House and Senate leadership, the offshore trades called attention to the bill and urged enactment as Congress wraps up negotiations on legislation to meet our nation’s critical needs during this trying time.

Letters and Comments Nov 30, 2020

IPAA submitted comments to the record for the Office of Natural Resources Revenue (ONRR) proposed rules on royalty valuation and civil penalties. The Obama Administration arbitrarily changed the rules during its tenure to impose unreasonable civil penalties and even went so far as to penalize operators for failure to disclose information that could not be known. This broad overreach could cost IPAA members hundreds of millions of dollars. For this reason, IPAA has long sought to see a rule change that would reign in accounting practices and limit fines to instances which could have been known.

Infrastructure, Letters and Comments Nov 19, 2020

Dear Majority Leader McConnell and Democratic Leader Schumer:

The undersigned organizations represent a broad constituency of industries, companies, and labor unions who build and provide equipment, materials, supplies, services and human capital to energy infrastructure projects. Our broad group relies on that infrastructure to produce and deliver the energy that powers America.

We ask you to schedule floor votes as soon as possible to confirm new commissioners to the Federal Energy Regulatory Commission (FERC) to fill current vacancies. The Senate Energy and Natural Resources Committee recently cleared both a Republican and a Democratic nominee with bipartisan support, and their nominations now await a vote by the full Senate.

FERC plays a critical role in ensuring that Americans have access to reliable and affordable energy. The Commission reviews and permits certain new interstate infrastructure projects and expansions intended to modernize existing energy transportation systems. FERC also reviews and approves rates and services for interstate energy infrastructure companies. The COVID-19 pandemic has emphasized the importance of affordable and reliable energy, and energy infrastructure will play an essential role in supporting America’s economic recovery…

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.