IPAA Comments on the Department of the Interior, Office of Natural Resources Revenue’s Proposed Rule, ONRR 2020 Valuation Reform and Civil Penalty Rule: Notification of Proposed Withdrawal

The Independent Petroleum Association of America (“IPAA”) thanks you for this opportunity to submit comments on the Office of Natural Resources Revenue’s (“ONRR’s”) proposal1 to withdraw the ONRR Valuation Reform and Civil Penalty Rule. IPAA is the leading national upstream trade association representing approximately eight thousand independent oil and natural gas producers and service companies across the United States. Independent producers generally include non-integrated oil and gas companies that receive nearly all revenue from production at the wellhead. IPAA’s members operate in 33 states and offshore and employ an average of just 12 people.

One of IPAA’s primary purposes is to advocate for its members’ interests in continued and responsible oil and gas development before Congress and federal agencies and in the judicial system. This purpose includes advocating for rational and fair policies on the valuation of royalties on oil and gas from Federal and Indian leases. …