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Letters & Comments

Letters and Comments May 16, 2018

These comments are submitted by the Alliance for Competitive Steel and Aluminum Trade (IPAA is a cosigner) on the interim final rule (the Interim Regulations) which amend the National Security Industrial Base Regulations (the Existing Regulations). The amendments set forth a process for U.S. companies to submit requests for exclusions from actions taken by the President under Presidential Proclamations 9704 and 9705, both dated March 8, 2018 (the Proclamations), as amended, which place additional tariffs on certain imports of steel and aluminum products pursuant to Section 232 of the Trade Expansion Act of 1962, as amended (Section 232).

Letters and Comments May 8, 2018

In proposing withdrawal of the Control Techniques Guidelines for the Oil and Natural Gas Industry (CTG), EPA states: “On June 5, 2017, the EPA granted reconsideration in regard to additional provisions of the 2016 NSPS1. Pursuant to those actions, the EPA is currently looking broadly at the 2016 NSPS. In light of the fact that the EPA is reconsidering the 2016 NSPS and because the recommendations made in the CTG are fundamentally linked to the conclusions in the 2016 NSPS, the EPA believes it is prudent to withdraw the CTG in its entirety. The EPA also believes that the withdrawal will be more efficient for states in revising their state implementation plans (SIPs).” We strongly support EPA’s proposed action for this and other reasons.

Letters and Comments Apr 23, 2018

To Whom it May Concern: Western Energy Alliance (the Alliance) and the Independent Petroleum Association of America (IPAA) appreciate the opportunity to provide comments on the Bureau of Land Management’s (BLM) proposed revisions of certain provisions of the Methane and Waste Prevention rule, or 2016 rule. The 2016 rule as promulgated exceeded BLM’s authority under the Mineral Leasing Act (MLA), and that the decision to re-evaluate the rule is required. The proposed revision rule more accurately captures the scope of BLM’s waste minimization authority, and will better ensure federal mineral interests are adequately protected without excessively burdening federal lands development with overreaching regulations.

Letters and Comments Apr 18, 2018

Dear Mr. Kudlow: The Independent Petroleum Association of America (IPAA) congratulates you as you assume the directorship of the National Economic Council. IPAA is the leading, national upstream trade association representing thousands of independent oil and natural gas producers and their service companies across the United States. Independent producers develop 95 percent of the nation’s oil and natural gas wells. These companies account for 54 percent of America’s oil production, 85 percent of its natural gas production, and support over 2.1 million American jobs.

Letters and Comments Apr 10, 2018

Dear Mr. President: The United States is now the leading natural gas producer in the world. Greater use of natural gas here in the U.S. and through LNG exports can yield tremendous benefits to our economy. The key to realizing the full value of natural gas is the continued development of a robust natural gas infrastructure along the entire value chain so that natural gas can be delivered wherever and whenever it is needed. The need for new energy infrastructure has never been more important, as new natural gas supplies present new opportunities for our economy to take advantage of this abundant and low-cost energy resource.

Letters and Comments Apr 9, 2018

Dear Leaders McConnell and Schumer: The Independent Petroleum Association of America (IPAA) supports the nomination of Andrew Wheeler to be Deputy Administrator at the Environmental Protection Agency and looks forward to the advancement of his nomination to the full Senate for consideration.

Letters and Comments Mar 27, 2018

Dear Deputy Secretary Bernhardt: We would you like thank you and the Department of the Interior (DOI) for recent actions that rescinded and revised mitigation policies that far exceeded statutory authority. The oil and natural gas industry continues to follow the statutory mitigation hierarchy to avoid, minimize, rectify, reduce and compensate for the impacts to lands and natural resources from energy development that powers our Nation. We look forward to working with DOI in developing reasonable mitigation policies that allow for the proper balance of species and habitat conservation with responsible resource development.

Letters and Comments Mar 22, 2018

Dear Chairman Brady and Ranking Member Neal: The associations submitting this letter request that our comments be included in the record for the hearing
held on March 22 with Commerce Secretary Wilbur Ross. Our specific comments relate to the Section 232 tariffs recently imposed on steel imports, and the impact these new tariffs will have on the entire energy sector, including pipelines.

Letters and Comments Mar 19, 2018

With this letter, the American Exploration and Production Council (AXPC), the Independent Petroleum Association of America (IPAA), and the American Petroleum Institute (API) are pleased to submit these comments in response to the captioned public notice, published in the Federal Register December 20, 2017, in which the U.S. Fish & Wildlife Service (USFWS or the Service) announced 90-day findings on several petitions to list or reclassify wildlife or plants under the Endangered Species Act of 1973, as amended (ESA), including the Tricolored bat (Perimyotis subflavus).

Letters and Comments Mar 19, 2018

Pursuant to Rule 212 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“Commission” or “FERC”), 18 C.F.R. § 385.212 (2016), the Advanced Energy Economy, American Council on Renewable Energy, American Petroleum Institute, American Wind Energy Association, American Public Power Association, Electric Power Supply Association, Electricity Consumers Resource Council, Interstate Natural Gas Association of America, Independent Petroleum Association of America, Natural Gas Supply Association and Solar Energy Industries Association (collectively, “Energy Industry Associations”) hereby respectfully submit this motion for extension of time for filing reply comments in response to the filings made in this proceeding on March 9, 2018 by the Regional Transmission Organizations/Independent System Operators (“RTOs/ISOs”). For the reasons discussed below, the Energy Trade Associations request a thirty (30) day extension of the deadline for reply comments established in the Commission’s January 8, 2018 Order in this proceeding.

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.