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Letters & Comments

Letters and Comments, Taxes Sep 12, 2024

To the Members of the United States Congress and New Administration:

Absent congressional action, at the end of 2025 American families and employers will be hit with the largest tax increase in American history.

The pro-growth tax reforms enacted in 2017 have been instrumental in driving economic growth, fostering capital investment, job creation, and higher wages. The expiration of many of these reforms will reduce economic growth, increase costs for families, harm main street businesses, reduce take-home pay for workers, and result in significant job losses. These outcomes are unacceptable and completely avoidable.

We are calling on the next Congress and Administration to commit to pursuing a pro-growth agenda and acting to prevent any tax increases on American families or businesses. By maintaining a pro-growth tax code, we can continue to build a robust economy that benefits all Americans and ensures that our nation remains a leader in global competitiveness and economic opportunity.

Infrastructure, Letters and Comments Jul 25, 2024

To the U. S. Army Corps of Engineers:

We are writing today to support Enbridge’s Line 5 Wisconsin Segment Relocation Project, your Draft Environmental Assessment, and clearing the project to move forward expeditiously.

The undersigned organizations represent the workers and businesses of the energy infrastructure supply chain. They comprise the vast segment of the American economy that supplies construction, equipment, materials and services to energy infrastructure critical to production, transmission, processing, and consumption; and to energy reliability, affordability and security.

Line 5 is a critical and irreplaceable element of the Upper Midwest’s energy infrastructure, transporting essential fuels to heat homes, schools, farms and businesses throughout the region, and providing energy for the region’s surface and air transportation, industrial operations and agriculture. …

Infrastructure, Letters and Comments Jul 24, 2024

Dear Chairman Manchin and Ranking Member Barrasso:

On behalf of our respective industry associations which collectively produce 80% of our nation’s energy, we express our strong support for the Energy Permitting Reform Act of 2024 and thank you both for your tireless efforts and countless hours devoted to streamlining the federal permitting process for energy and mineral projects.

This comprehensive bill is a critical step forward in enhancing the efficiency and effectiveness of our nation’s energy and mineral development processes while still maintaining robust environmental protections and legal review standards that protect our public lands and waters. …

Letters and Comments, Methane Jun 28, 2024

Dear Chairman Simpson and Ranking Member Pingree:

This letter is submitted on behalf of the organizations listed below. These organizations want to express serious concerns regarding the impact of the Environmental Protection Agency’s (EPA) new methane emissions regulation (Subpart OOOOc) on oil and natural gas marginal well owners. We write to request that targeted regulatory relief be included in Title II of the report accompanying the Subcommittee on Interior, Environment, and Related Agencies’ FY 2025 appropriations bill. Specifically, we seek a tailored accommodation from the U.S. Environmental Protection Agency’s new final rule entitled, “Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review,” 89 Fed. Reg. 16,820 (Mar. 8, 2024) (the “Final Rule”).

The Final Rule fails to adequately consider many important factors, including the extraordinary damage it will cause to thousands of marginal oil and gas wells (i.e., those that produce less than 15 barrels of oil per day and less than 90 Mcf of gas per day) that are vital to the energy security of our states and country. Many of these small family businesses will be forced to close their wells, resulting in the loss of thousands of good paying jobs, and harming the millions of people who rely on their energy output. Prior rulemakings in this area have recognized that accommodations for marginal wells are necessary, and we believe such careful balancing in this rule would have been appropriate, as well. …

Letters and Comments Jun 13, 2024

Dear Majority Leader Schumer, Speaker Johnson, and Leaders McConnell and Jeffries,

The Natural Gas Council, on behalf of the individuals and companies who produce, transport, and deliver natural gas across the nation, urges Congress to enact H.R. 4470, the Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2023. Importantly, this proposal would reauthorize for two years the Department of Homeland Security (DHS) Chemical Facility Anti-Terrorism Standards (CFATS) program, which plays a crucial role in ensuring the security of the United States’ critical infrastructure.

Endangered Species, Letters and Comments Jun 12, 2024
IPAA joined API in submitting comments for the Draft Resource Management Plan Amendment and Environmental Impact Statement for Greater Sage-Grouse Rangewide Planning. IPAA has a keen interest in how BLM plans to manage land with respect to the greater sage-grouse and its habitat as many of our members operating on public lands currently hold existing leases and are interested in future oil and natural gas leases and exploration opportunities that will be directly affected by the BLM’s management decisions.
Our submitted comments detail the significant interest our members have in being active participants in developing RMP’s to address the greater sage-grouse. We have consistently urged BLM to be guided by sound science in considering measures to conserve greater sage-grouse on lands managed by the BLM and ensure that any such measures are grounded in BLM’s statutory authority and respect existing commitments to leaseholders.

Letters and Comments Jun 10, 2024

Dear Leaders Schumer and McConnell,

On behalf of the organizations representing industries, companies, and individuals who depend on regulatory decisions relating to energy infrastructure and markets, we write to express our appreciation for moving swiftly on the process to confirm the candidates approved by the Senate Committee on Energy and Natural Resources to fill current vacancies and another pending vacancy at the Federal Energy Regulatory Commission (FERC or Commission). We ask that you schedule votes to confirm all the nominees to be Commissioners at FERC as soon as possible. …

Letters and Comments, Methane Mar 26, 2024

The Independent Petroleum Association of America (IPAA) submits these comments regarding the Environmental Protection Agency (EPA) proposal to implement a Waste Emissions Charge for Petroleum and Natural Gas Systems (WEC) under the Inflation Reduction Act Methane Emissions Reduction Program (Methane Tax).

In addition to the comments filed here, unless there are specific comments presented herein, IPAA endorses the comments filed by the American Petroleum Institute (API).

The Methane Tax process includes multiple features. However, a key factor in conjunction with this WEC proposal is the application of information from Subpart W. IPAA previously filed comments on the EPA proposal to modify Subpart W (EPA-HQ-OAR-2023-0234-0265). These comments are included in this submission as Appendix A.

Because the emissions calculations under Subpart W are the building blocks for calculation of the WEC, these comments will reiterate and expand on those prior comments. Then, it will address key issues in the WEC proposal.

 

 

Letters and Comments, Methane Mar 26, 2024

IPAA joined with the American Petroleum Institute (API) and 18 other associations representing all segments of the U.S. oil and natural gas industry operating across the country in calling on the U.S. Environmental Protection Agency (EPA) to revise its misguided methane fee on American energy. In comments submitted to the agency on the “waste emissions charge” proposed rulemaking, the associations argued that EPA’s proposed rule creates an incoherent regulatory regime, fails to meet the statutory requirements outlined by the Inflation Reduction Act and disincentivizes emissions reduction efforts by the industry.

In their comment letter, the associations raised significant concerns about the proposed rule’s nexus to other methane regulations underway, highlighting the Biden administration’s disharmonized approach to methane regulations. The associations urged the administration to coordinate this proposed rule with other regulations, including Subpart W and EPA’s final Methane Rule. Additionally, the associations called for more flexibility on netting requirements to incentivize greater emissions reductions, clarification to the rule’s exemptions as intended by Congress, and commonsense compliance and reporting timelines.

Letters and Comments Feb 14, 2024

“On behalf of undersigned energy associations, we urge a yes vote on H.R. 7176 Unlocking Our Domestic LNG Potential Act. …

“The Biden Administration’s recent announcement to pause new non-FT A permits for LNG export facilities could not have come at a worse time. This action threatens to stifle the progress made by the unprecedented ramp up of our domestic industry and the fundamental shift in dependence made by Europe. …

“U.S. LNG exports have received bipartisan support in the past that continues to this day. Given the national security implications of this misguided decision for both the United States and our European allies, we urge you to quickly advance legislation to remove the Department of Energy from the non-FT A permitting process to allow critical LNG infrastructure to move forward.

“Our associations strongly support the passage of H.R. 7176 Unlocking Our Domestic LNG Potential Act by Rep. August Pfluger (TX-11) which will counter this misguided decision by the Administration and put the Federal Energy Regulatory Commission in charge of all LNG export permitting in the United States…”

 

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.