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Letters & Comments

Letters and Comments Mar 12, 2018

Pursuant to the public notice issued by the United States (“U.S.”) Army, Corps of Engineers (“Corps”) Fort Worth District on January 9, 2018 (“Public Notice”) and as amended on February 1, 2018 with a 30-day extension of the public comment period, the American Petroleum Institute (“API”), the Texas Oil & Gas Association (“TXOGA”), the Independent Petroleum Association of America (“IPAA”) and the American Exploration & Production Council (“AXPC”) hereinafter “the Associations,” respectfully submit these comments on the proposed Additional Guidelines Covering Specific Elements for the Establishment of New Mitigation Banks in the Fort Worth District (“draft Guidelines”). We appreciate your consideration of our request to extend the public comment period. We have taken that opportunity to more carefully review the draft Guidelines. The Associations support the goals of predictability and transparency in mitigation banking. However, the significantly expanded draft Guidelines impose numerous additional unnecessary and unreasonably stringent requirements that will have the following effects: 1) substantially reduce lands available for mitigation banking (thereby hindering conservation goals as well as delaying energy and water infrastructure project development); 2) generate further inefficiencies in an already protracted permitting process; and 3) conflict with existing federal Executive Orders and regulatory reform efforts to promote consistency among the Corps districts. In light of these significant consequences and contemporaneous relevant reform efforts at the federal level, the Associations request that the Fort Worth District refrain from finalizing these draft Guidelines and instead focus on reviewing, modifying, and updating its existing guidance in coordination with the Corps Headquarters and stakeholders.

Letters and Comments Mar 9, 2018

The Independent Petroleum Association of America (IPAA) appreciates the opportunity to submit comments regarding the Converse County Oil and Gas Project Draft Environmental Impact Statement (DEIS) and urges the BLM to adopt the Preferred Alternative (Alternative B). We also urge the agency to issue a Final Environmental Impact Statement (FEIS) and Record of Decision (ROD) before the end of 2018. IPAA is the leading, national upstream trade association representing oil and natural gas producers and service companies. IPAA represents thousands of independent oil and natural gas explorers and producers, as well as the service and supply industries that support their efforts. Many IPAA member companies actively produce oil and natural gas from leases on federal lands in Wyoming and throughout the Intermountain West.

Letters and Comments Mar 9, 2018

The American Petroleum Institute (API), National Ocean Industries Association (NOIA), Independent Petroleum Association of America (IPAA), U.S. Oil and Gas Association (USOGA), American Exploration & Production Council (AXPC), International Association of Geophysical Contractors (IAGC), Petroleum Equipment and Services Association (PESA), International Association of Drilling Contractors (IADC), Offshore Operators Committee (OOC), and the Alaska Oil and Gas Association (AOGA) (“the Associations”) offer the following comments on the Bureau of Ocean Energy Management’s (BOEM) request for comments on the 2019–2024 Draft Proposed National Oil and Gas Leasing Program (DPP) and Notice of Intent to Prepare a Programmatic Environmental Impact Statement that were published in the Federal Register on January 8, 2018. The Associations’ members have significant interest in ensuring that there are future opportunities for offshore oil and natural gas exploration and development in the United States (U.S.) so that the nation can capitalize on industry expertise that has been garnered through years of successful and beneficial exploration, development and production of domestic Outer Continental Shelf (OCS) oil and natural gas resources. We fully support keeping the DPP as is with no areas being removed from future leasing consideration. The decisions made regarding what areas are available for leasing will have long-term implications for our nation’s energy security, prospects for job creation, and government revenue generation.

Letters and Comments Mar 9, 2018

The Independent Petroleum Association of America (IPAA) appreciates the opportunity to submit comments on the 2019-2024 Draft Proposed Outer Continental Shelf (OCS) Oil and Gas Leasing Program (DPP). The federal OCS has been a foundation of American energy policy since the 1950’s and provides outstanding oil and natural gas exploration and production opportunities for independent producers. The offshore industry can and will bring large volumes of oil and natural gas safely and efficiently to market from currently unavailable areas of the OCS, if those areas are reasonably made available for leasing. As global energy demand continues to increase, a failure to provide U.S. producers with needed access to the OCS will increase U.S. energy prices, slow economic growth, and create hardship for American consumers. It is essential that the Bureau of Ocean Energy Management (BOEM) develop a leasing program that maximizes the opportunities for our nation to address its energy needs. Increasing the safe development of offshore oil and natural gas resources would create high-paying American jobs, economic development, and strengthen energy security for not only the coastal states but across the nation. IPAA believes that America’s long-term energy security and job creation should be top priorities for our nation.

Letters and Comments Mar 8, 2018

Dear President Trump: As the Trump Administration has so clearly identified and stressed, America is now poised to enter an era where it can exert an energy dominance in the world energy marketplace. The growth and potential growth of American oil and natural gas production creates this opportunity. Yet, as the past few years of low commodity prices have shown, this future can be vulnerable. International trade policies present a similar challenge and the current initiatives on steel tariffs are a specific example.

Letters and Comments Jan 31, 2018

Pursuant to Rules 207(a)(4) and (a)(5) of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. §§ 385.207(a)(4) and (a)(5) (2017), the undersigned Petitioners, representing a broad-based coalition of the natural gas industry that are dependent upon services provided by interstate natural gas pipeline and storage companies, hereby petition the Commission to take immediate action under Sections 5(a), 10(a), and 14(a) and (c) of the Natural Gas Act (NGA) to initiate show cause proceedings against all interstate natural gas pipeline and storage companies, excluding (1) Section 311 pipelines (which are otherwise required to file updated rate justifications on an ongoing basis); and (2) natural gas pipeline and storage companies that are obligated to file a Section 4 rate case in 2018. Petitioners request the Commission to require all other regulated interstate natural gas pipeline and storage entities (unless barred by a settlement moratorium) to demonstrate that their existing jurisdictional rates continue to be just and reasonable following the passage of the Tax Cuts and Jobs Act of 2017 (“Tax Act”).

Letters and Comments Jan 22, 2018

Dear Mr. Sheehan: With this letter, API, IPAA, AXPC, and IAGC (together “the Associations”) are pleased to submit these comments in response to the U.S. Fish and Wildlife Service’s (FWS, or “the Service”) Candidate Conservation Agreements with Assurances (CCAAs) Policy, which the Services announced that they were intending to review and possibly to revise in a notice pub-lished at 82 Fed. Reg. 55,625 (November 22, 2017). The Services finalized a revision of the CCAA policy on December 27, 2016 (81 FR 95164). The Associations request the FWS revise the existing policy as described below.

Letters and Comments Jan 22, 2018

Dear Mr. Sheehan: With this letter, API, IPAA, AXPC, and IAGC (together “the Associations”) are pleased to submit these comments in response to the U.S. Fish and Wildlife Service’s (FWS, or “the Service”) Candidate Conservation Agreements with Assurances (CCAAs) Regulations found at 50 C.F.R. 17.22(d) and 17.32(d), which the Service announced that it was intending to review and possibly to revise in a notice published at 82 Fed. Reg. 55,550 (November 22, 2017). We request the FWS revise the existing rule as described below.

Letters and Comments Jan 10, 2018

Dear Member of Congress, On behalf of the Independent Petroleum Association of America, I want to thank you for your recent vote supporting the enactment of the Tax Cuts and Jobs Act. Once in a generation, Congress gets the opportunity to address comprehensive revisions to the federal tax code. No one, at the beginning of 2017, would have expected that this legislation could have been created and passed in a year. Your participation in this process is commendable.

Letters and Comments Jan 5, 2018

Dear Mr. Sheehan: With this letter, API, IPAA, AXPC, IAGC, and Western Energy Alliance (together “the Associations”) are pleased to submit these comments in response to the captioned public notice, published in the Federal Register November 6, 2017, in which the U.S. Fish and Wildlife Service (FWS or the Service) requests public comment to the use of the terms “net conservation gain” and “no net loss” to describe planning goals for the Service’s Endangered Species Act (“ESA”) Compensatory Mitigation Policy. We appreciate the FWS seeking public comments on this policy. However, we have significant concerns with many as-pects of the policy as discussed below. As such, we request the FWS withdraw and revise this policy.

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.