Comments on the Inflation Reduction Act-Financial and Technical Assistance

Comments on the Inflation Reduction Act-Financial and Technical Assistance

These comments are filed on behalf of the Independent Petroleum Association of America (IPAA). IPAA represents the thousands of  independent oil and natural gas explorers and producers, as well as the service and supply industries that support their efforts, that will be the most significantly affected by the actions resulting from this regulatory proposal. Independent producers drill about 91 percent of American oil and gas wells, produce 83 percent of American oil, and produce 90 percent of American natural gas.

The Environmental Protection Agency (EPA) has opened this comment center for the purpose of receiving comments on its legislatively imposed Methane Emissions Reduction Program (Methane Tax). EPA describes this program as follows:

EPA received $1.55 billion to reduce methane emissions from the oil and gas sector by providing financial assistance (grants, rebates, contracts, loans, and other activities) and technical assistance as well as implementing a statutorily required waste emissions charge. Eligible recipients for these funds include but are not limited to air pollution control agencies, other public or nonprofit private agencies, institutions, and organizations, and individuals. The program specifies that at least $700 million must be used for activities at marginal conventional wells. Section 60113 also requires EPA to implement a waste emission charge on methane emitted from applicable oil and gas facilities that emit over 25,000 metric tons of CO2e and that exceed statutorily specified waste emissions thresholds beginning in 2024. The waste emissions charge will start at $900 and increase to $1,500 per metric ton.

The format for these comments is laid out in a series of questions. IPAA provides information
on several of those questions…