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Letters and Comments Dec 17, 2018

The Independent Producers have participated individually or through the Independent Producers in most, if not all, of the rulemakings and associated litigation since the Environmental Protection Agency (“EPA” or “Agency”) proposed to revise the New Source Performance Standards (“NSPS”) for the Oil and Natural Gas Sector in August 2011. 76 Fed. Reg. 52,738 (Aug. 23, 2011).1 While many of the Independent Producers represent companies that engage in large volume hydraulic fracturing with horizontal legs, often referred to as unconventional drilling, a significant portion of their membership is comprised of smaller, family run operations that engage in some form of hydraulic fracturing, involving vertical wells without horizontal legs, referred to as conventional oil or gas wells. Many of the individual members constitute as small businesses under the Small Business Regulatory Enforcement Fairness Act of 1996. From the beginning of these rulemakings, the Independent Producers have tried to illustrate to the EPA that their “one-size-fits-all” approach to regulating this industry is a) inappropriate and b) disproportionally impacts conventional operations and small businesses.

Letters and Comments Dec 5, 2018

The Pipeline and Hazardous Materials Safety Administration (PHMSA) in 2016 proposed several changes to the existing regulations applicable to gathering lines in rural areas as part of its larger natural gas pipeline rulemaking. Those proposed changes have elicited fairly consistent comments from the Independent Petroleum Association of America (IPAA) and the Texas Pipeline Association (TPA). As PHMSA prepares to present its proposed response to comments in the pending rulemaking to the Gas Pipeline Advisory Committee (GPAC), IPAA and TPA suggest a path forward as described herein. The proposed path forward would ensure rural, larger diameter, high-pressure gas gathering lines for which PHMSA has expressed concern would meet certain, minimum requirements going forward. It would provide an initial step in addressing the risk of rural gathering pipelines by expanding the scope of regulated gathering while also providing additional information on gathering pipelines to assist future regulatory initiatives.

Endangered Species, Letters and Comments Sep 24, 2018

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.

…

Letters and Comments Aug 21, 2018

Since its enactment, requirements involving NEPA have grown considerably and place a heavy burden on independent oil and gas producers operating on federal lands.  As more than forty years of experience with implementing NEPA have demonstrated, overly broad NEPA reviews add unreasonable costs and delays to projects.  While the Act has remained unchanged, court decisions, Executive Orders and regulations have defined and significantly expanded the scope of NEPA.

Letters and Comments Aug 14, 2018

The organizations filing these comments support the Environmental Protection Agency’s and the Army Corps of Engineers’ proposal to repeal the 2015 Rule Defining Waters of the United States (“2015 Rule”), and many have submitted individual comment letters detailing reasons for supporting the proposal. This letter separately addresses an issue of particular importance to the trade groups: the effect of the Supreme Court’s decision in Solid Waste Agency of Northern Cook County v. U.S. Army Corps of Engineers, 531 U.S. 159 (2001) (“SWANCC”). As EPA and the Corps move forward with this rulemaking, the agencies must recognize the limitations SWANCC imposes on jurisdiction.

Letters and Comments Jul 25, 2018

Pursuant to the April 19, 2018, Notice of Inquiry, issued by the Federal Energy Regulatory Commission (“Commission”) in the above-referenced docket, the Independent Petroleum Association of America (“IPAA”) hereby respectfully submits the following comments on Certification of New Interstate Natural Gas Facilities. IPAA urges the Commission to retain its policies that have served the regulated community and the public by approving construction of pipelines that have allowed for increased consumption of natural gas while reducing greenhouse gas emissions.

Letters and Comments Jul 25, 2018

Dear Chairman McIntyre: We are writing you on behalf of the Natural Gas Council (NGC) to express our views in connection with the referenced Notice of Inquiry (NOI) issued by the Federal Energy Regulatory Commission (Commission), in Docket No. PL18-1-000. Formed in 1992, the NGC unites all sectors of the natural gas industry to work together toward common goals.

Letters and Comments Jul 19, 2018

Dear Secretary Zinke: The Independent Petroleum Association of America (IPAA) is dedicated to supporting and promoting the safe and responsible development of our nation’s abundant energy resources. One of the keys to increasing American oil and natural gas production is to have a reasonable and predictable regulatory program for energy production on federal lands. Effective reorganization of the Department of the Interior (DOI) will help the nation improve management of public lands throughout the United States and support President Trump’s efforts to reduce administrative and jurisdictional barriers throughout the federal government.

Letters and Comments Jul 10, 2018

Dear Chairman Gosar: The Independent Petroleum Association of America writes to express its support for the nine bills included in the Congressional Western Caucus Endangered Species Act Modernization Package. IPAA believes both exploration and development of America’s oil and natural gas resources and conservation can coexist through reasonable and balanced wildlife policy. This legislative package would aid in the modernization of the 1973 Endangered Species Act and benefit not only the regulated community, but further enhance protection of endangered plants and animals across the United States.

Letters and Comments Jul 2, 2018

Dear Deputy Director Chapman: This document provides comments from the IPAA in response to the U.S. Environmental Protection Agency’s (“EPA’s” or “the Agency’s”) request for comments on its proposed changes to EPA’s 2000 policy titled “Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations” (the “Audit Policy”) for new owners of oil and natural gas exploration and production facilities and, in particular, the Agency’s Draft Standard Audit Policy Agreement (“Draft Agreement”). IPAA believes that the Audit Policy is an important tool in furtherance of environmental compliance and appreciates EPA’s interest in expanding its use by proposing to adopt a more flexible approach to eligibility and administration.

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.