Sep 24, 2018 IPAA PAW Comments on ESA Regulatory Reforms
Re: Revision of the Regulations for Prohibitions to Threatened Wildlife and Plants, 83 Fed. Reg. 35174 (July 25, 2018); Revision of the Regulations for Interagency Cooperation, 83 Fed. Reg. 35178 (July 25, 2018); Revision of the Regulations for Listing Species and Designating Critical Habitat, 83 Fed. Reg. 35193 (July 25, 2018)
Dear Sir or Madam:
The Independent Petroleum Association of America (“IPAA”) and the Petroleum Association of Wyoming (“PAW”) (together “the Associations”) submit the following comments in response to the U.S. Fish and Wildlife Service and National Marine Fisheries Service’s
(together, “the Services”) jointly-proposed Revision of the Regulations for Interagency Cooperation, 83 Fed. Reg. 35178 (July 25, 2018) (“Section 7 Regulations”) and Revision of the Regulations for Listing Species and Designating Critical Habitat, 83 Fed. Reg. 35193 (July 25,
2018) (“Critical Habitat Regulations”), as well as the U.S. Fish and Wildlife Service’s (“FWS”) proposed Revision of the Regulations for Prohibitions to Threatened Wildlife and Plants, 83 Fed. Reg. 35174 (July 25, 2018) (“Blanket 4(d) Rule”).
IPAA is a national trade association representing the thousands of independent crude oil and natural gas explorers and producers in the United States. It also operates in close cooperation with 44 unaffiliated independent national, state, and regional associations, which
together represent thousands of royalty owners and the companies that provide services and supplies to the domestic industry. IPAA is dedicated to ensuring a strong, viable domestic oil and natural gas industry, recognizing that an adequate and secure supply of energy developed in an environmentally responsible manner is essential to the national economy.
PAW is Wyoming’s largest and oldest oil and gas organization dedicated to the betterment of the state’s oil and gas industry and public welfare. PAW members, ranging from independent operators to integrated companies, account for approximately ninety percent of the
natural gas and eighty percent of the crude oil produced in Wyoming.
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