Letters & Comments

Letters and Comments Jul 19, 2018

Dear Secretary Zinke: The Independent Petroleum Association of America (IPAA) is dedicated to supporting and promoting the safe and responsible development of our nation’s abundant energy resources. One of the keys to increasing American oil and natural gas production is to have a reasonable and predictable regulatory program for energy production on federal lands. Effective reorganization of the Department of the Interior (DOI) will help the nation improve management of public lands throughout the United States and support President Trump’s efforts to reduce administrative and jurisdictional barriers throughout the federal government.

Letters and Comments Jul 10, 2018

Dear Chairman Gosar: The Independent Petroleum Association of America writes to express its support for the nine bills included in the Congressional Western Caucus Endangered Species Act Modernization Package. IPAA believes both exploration and development of America’s oil and natural gas resources and conservation can coexist through reasonable and balanced wildlife policy. This legislative package would aid in the modernization of the 1973 Endangered Species Act and benefit not only the regulated community, but further enhance protection of endangered plants and animals across the United States.

Letters and Comments Jul 2, 2018

Dear Deputy Director Chapman: This document provides comments from the IPAA in response to the U.S. Environmental Protection Agency’s (“EPA’s” or “the Agency’s”) request for comments on its proposed changes to EPA’s 2000 policy titled “Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations” (the “Audit Policy”) for new owners of oil and natural gas exploration and production facilities and, in particular, the Agency’s Draft Standard Audit Policy Agreement (“Draft Agreement”). IPAA believes that the Audit Policy is an important tool in furtherance of environmental compliance and appreciates EPA’s interest in expanding its use by proposing to adopt a more flexible approach to eligibility and administration.

Letters and Comments Jun 21, 2018

Dear Administrator Rao, The public relies on smart regulations to set clear rules that support a clean environment, safe workplaces, and a better quality of life. At the same time, every regulation comes with a price tag, and those costs matter – especially to small businesses and local communities. Cost-benefit analysis, although not perfect, is the best tool agencies have available to them to ensure that regulations promote the public good and do more good than harm. We believe the time has come for EPA to reexamine its statutory interpretations, and unless prohibited by statute, implement its regulatory statutes through cost-benefit balancing.

Letters and Comments Jun 19, 2018

Dear Chairman Bishop, The Independent Petroleum Association of America (IPAA) appreciates the opportunity to speak in favor of the common-sense onshore regulatory reform bills before the Committee for markup. IPAA is the leading, national upstream trade association representing thousands of independent oil and natural gas producers, as well as the service and supply industries that support their efforts across the United States. Many IPAA member companies – small businesses with an average of 12 employees – actively produce oil and natural gas from leases on federally-controlled lands throughout the Intermountain West.

Letters and Comments Jun 18, 2018

Dear Chairmen and Ranking Members: The undersigned organizations represent a broad array of U.S. manufacturers, retailers, technology companies, farmers and agribusinesses and other supply chain stakeholders. We are writing to express our deep and increasing concern with the direction of America’s trade policy. In particular, we see the growing willingness of the current Administration to use tariffs (and the related use of absolute import quotas) as a major policy tool in an increasing number of trade disputes with our allies as a trend that needs to be addressed by Congress. There are valid reasons for Congress to have delegated significant authority to the President in order to address unfair trade practices and liberalize world trade. However, this extensive unilateral use of tariffs by the Executive Branch is upsetting the historic balance between Congressional and Executive powers, which has worked effectively for many decades to strengthen our economy and grow export opportunities for American manufacturers, service providers, ranchers and farmers, and needs to be reassessed.

Letters and Comments Jun 14, 2018

Dear Mr. Stringer – On behalf of Divestment Facts, a project of the Independent Petroleum Association of America (IPAA), I’m writing in response to the Request for Information (RFI) on Mayor Bill de Blasio’s proposal to divest $5 billion in fossil fuel assets from the New York City Retirement System (NYCRS), which includes five separate pension funds.

Letters and Comments Jun 8, 2018

Dear Chairman Barrasso: The Independent Petroleum Association of America (IPAA) writes to express its support for the Endangered Species Act Amendments of 2018. IPAA believes both exploration and development of America’s oil and natural gas resources and conservation can coexist through reasonable and balanced wildlife policy. Your legislation would aid in the modernization of the 1973 Endangered Species Act to benefit not only species recovery, but also the regulated community.

Letters and Comments May 24, 2018

Dear Governor Northam: The undersigned trade organizations represent businesses and workers who build and provide equipment, materials, supplies and services to energy infrastructure projects. Prominent among those projects is the Atlantic Coast Pipeline (ACP), which will provide Virginians with greatly expanded access to affordable and reliable natural gas and the clean power it provides.

Letters and Comments May 21, 2018

This letter provides comments from the American Petroleum Institute (“API”), Association of Oil Pipe Lines (“AOPL”), American Exploration & Production Council (“AXPC”), Independent Petroleum Association of America (“IPAA”), the Domestic Energy Producers Alliance (“DEPA”), and the Marcellus Shale Coalition (“MSC”) – (collectively, “the Associations”), responding to the Environmental Protection Agency’s (“EPA’s” or “The Agency’s”) Request for Comments on Clean Water Act (“CWA” or “the Act”) Coverage of “Discharges of Pollutants” via a Direct Hydrologic Connection to Surface Water. The Associations appreciate that EPA opened this comment period. Our members share EPA’s concern that seemingly contradictory Agency guidance and conflicting case law have blurred the Act’s conspicuous delineation between those point source discharges to jurisdictional waters that require CWA permits, and releases to groundwater that do not require CWA permitting.

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.