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Letters & Comments

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…”

 

Letters and Comments, Methane Feb 9, 2024

“Dear Mr. Speaker, Leader Jeffries, Leader Schumer, and Leader McConnell:

This letter is submitted on behalf of the 26 organizations listed below. These organizations want to express serious concerns regarding the impact of the Environmental Protection Agency’s (EPA) new methane emissions regulations (Subparts OOOOb and OOOOc) and the Methane Emissions Reduction Program (Methane Tax) on oil and natural gas marginal well owners. Both actions threaten marginal wells continued operations by creating unfair, unworkable, and uneconomic regulations. These small business energy producers need assistance to find a regulatory or legislative solution to mitigate these threats. …”

The letter provides definitions and information on the impact to producers in the following areas –

  • Regulatory Applicability to Marginal Wells
  • Subparts OOOOb and OOOOc
  • The Methane Tax

“Collectively, the Subpart OOOOc regulations and the Methane Tax pose serious and direct threats to hundreds of thousands of marginal wells. These threats have not been remotely addressed in the current regulatory actions completed or pending at EPA. Congress needs to step up and step in to prevent irresponsible agency actions that would savage the nation’s marginal oil and natural gas wells.”

 

Letters and Comments, Taxes Feb 2, 2024

Dear Majority Leader Schumer and Leader McConnell,

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. 7024, the Tax Relief for American Families and Workers Act, which would extend the benefits of 100-percent bonus depreciation, enhanced interest deductibility, and immediate expensing of domestic research and development (R&D) expenses.

As a capital-intensive industry with extended project lead times, the natural gas sector benefits from provisions that allow immediate expensing or bonus depreciation. The ability to completely deduct the cost of making acquisitions of all new and used equipment reduces the average cost of capital across all business investments. By substantially lowering the cost of capital for depreciable investments for equipment to maintain, operate, and deploy our critical infrastructure systems, immediate expensing further spurs activities that might otherwise be delayed to later years. …

Infrastructure, Letters and Comments Feb 2, 2024

The Natural Gas Council, on behalf of the individuals and companies who produce, transport, and deliver natural gas across the nation, writes in support of H.R. 7023, Creating Confidence in Clean Water Permitting Act. This proposal would ensure the continued availability of the Nationwide Permit (NWP) program for the construction of new natural gas infrastructure projects and the maintenance of existing infrastructure to ensure safety and reliability. …

Letters and Comments, Uncategorized Feb 1, 2024

This Coalition letter was sent to the Members of the U.S. House of Representatives’ Committees on Small Business and of the Judiciary, supporting reform in implementation of the Regulatory Flexibility Act.

“Dear Chairmen Williams and Jordan and Ranking Members Velazquez and Nadler:

On behalf of millions of small businesses across the country, we urge legislative action to strengthen the meaningful input of small businesses in federal regulatory processes and ensure the intent of the Regulatory Flexibility Act is fulfilled. …

Unfortunately, loopholes in the RFA allow federal regulators to bypass the law’s requirements and misrepresent the costs of new mandates on small businesses because (a) transparency requirements only apply to businesses directly regulated and (b) judges may not punish agencies for ignoring small business concerns. …

At a time when we are counting on small business growth to enrich communities and bolster America’s economy, we cannot afford to bury free enterprise under red tape emanating from Washington.

We urge the Committee to prioritize legislation that strengthens and closes loopholes in the Regulatory Flexibility Act. …”

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.