Aug 2, 2019 IPAA Amicus Curiae Brief in Support of Petitioners’ Joint Motion for Preliminary Injunction
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. (Id.) This purpose includes advocating for rational and fair policies on the valuation of royalties on oil and gas from Federal and Indian leases.
On federal, Indian, state, and private land, IPAA’s members develop over 91 percent of domestic oil and gas wells, produce 83 percent of domestic oil, and produce 90 percent of domestic natural gas.
In the next few weeks, IPAA’s members will be required to begin complying with a final rule that the Department of the Interior (“Department”) issued entitled Consolidated Federal Oil & Gas and Federal Indian & Coal Valuation Reform, 81 Fed. Reg. 43,338 (July 1, 2016) (“Rule”). Compliance will impose massive unrecoverable costs on IPAA members who lease, produce, transport, pay royalties
on, or are otherwise involved with Federal oil and gas. (Naatz Decl. ¶ 5.) IPAA estimates its members are likely to suffer unrecoverable injuries of at least $100 million in compliance costs if the Rule is not preliminarily enjoined.
With regard to the Rule itself, IPAA joined with the American Petroleum Institute (“API”) and the National Ocean Industries Association in comments on the proposed rule preceding the adoption of the final Rule…
