Letters & Comments

Dear Administrator Pruitt: The following comments are submitted on the above-referenced proposed rule and notice of data availability (NODA) on behalf of the following national and state trade associations: the Independent Petroleum Association of America (IPAA), American Exploration & Production Council (AXPC), Domestic Energy Producers Alliance (DEPA), Eastern Kansas Oil & Gas Association (EKOGA), Illinois Oil & Gas Association (IOGA), Independent Oil and Gas Association of West Virginia, Inc. (IOGA-WV), Indiana Oil and Gas Association (INOGA), International Association of Drilling Contractors (IADC), Kansas Independent Oil & Gas Association (KIOGA), Kentucky Oil & Gas Association (KOGA), Michigan Oil and Gas Association (MOGA), National Stripper Well Association (NSWA), North Dakota Petroleum Council (NDPC), Ohio Oil and Gas Association (OOGA), Oklahoma Independent Petroleum Association (OIPA), Pennsylvania Independent Oil & Gas Association (PIOGA), Texas Alliance of Energy Producers (Texas Alliance), Texas Independent Products & Royalty Owners Association (TIPRO), and West Virginia Oil and Natural Gas Association (WVONGA) (collectively, “Independent Producers”). We respectively ask that you consider these comments.  We are here to respond to any questions or comments you may have.

In accordance with the Federal Register notice, issued on October 2, 2017 and revised on November 3, 2017, the Independent Petroleum Association of America (IPAA) and its members, along with the Kentucky Oil & Gas Association, the Ohio Oil and Gas Association, and the Pennsylvania Independent Oil & Gas Association (collectively, Independent Producers), submit the following comments on existing rules and other agency actions that are good candidates for repeal, replacement, suspension, or modification. The Independent Producers represent the companies that drill 90 percent of the nation’s oil and natural gas wells. These companies produce 82 percent of American natural gas and 68 percent of American oil. The Independent Producers’ members represent the full range of producers, from small family‐owned businesses, to the large independent companies that are some of the largest American natural gas producers. The Independent Producers’ recommendations focus on three issues under the auspices of the Pipeline and Hazardous Materials Safety Administration (PHMSA): Sampling and testing for unrefined petroleum‐based products; Regulatory treatment of farm taps off production lines; and Proposed regulations affecting gathering lines and production facilities.

Dear Mr. Nedd: With this letter, API and IPAA are pleased to submit its comments in response to the captioned public notice, published in the Federal Register October 11, 2017, describing the intention of the Bureau of Land Management (BLM) to consider amendments to “some, all or none of the BLM land use plans that were amended or revised in 2014 and 2015 regarding Greater Sage-Grouse (GRSG) conservation in the States of California, Colorado, Idaho, Nevada, Oregon, Wyoming, North Dakota, South Dakota, Utah and Mon-tana” (2015 GRSG Plans).

Dear Ms. Christensen and Ms. Jensen: The Waters Advocacy Coalition (WAC) submits the attached comments in response to the U.S. Environmental Protection Agency’s and U.S. Army Corps of Engineers’ request for written recommendations regarding the definition of “Waters of the United States” under the Clean Water Act. WAC appreciates the opportunity to comment on this important issue.

Dear Mr. Beaman: The American Exploration & Production Council (AXPC) and the Independent Petroleum Association of America (IPAA) are pleased to submit comment to the Environmental Protection Agency (EPA) on its voluntary information collection request (ICR) proposal, “Survey on Clean Water Act Hazardous Substances and Spill Impacts” published in the federal register on September 21, 2017 (Document No. 2017-20170). AXPC and IPAA member companies are currently subject to the existing spill prevention, control, and countermeasure (SPCC) regulations in addition to the many similar, supplementary state specific requirements. As such, AXPC and IPAA believe that the current regulatory environment is sufficient as it provides for adequate protection against any unplanned release of hazardous substances and submits the following response.

A diverse group of a dozen energy industry associations representing oil, natural gas, wind, solar, efficiency, and other energy technologies submitted reply comments to the Federal Energy Regulatory Commission (FERC) continuing their opposition to the Department of Energy’s (DOE) proposed rulemaking on grid resiliency pricing, in the next step in this FERC proceeding.

To Whom It May Concern: Western Energy Alliance and the Independent Petroleum Association of America (IPAA) appreciate the opportunity to provide comment on the Bureau of Land Management’s (BLM) proposed stay of effectiveness of certain provisions of the Methane and Waste Prevention rule, or 2016 rule. We believe that the original rule as promulgated exceeded BLM’s authority under the Mineral Leasing Act (MLA) and that the decision to postpone compliance dates while BLM re-evaluates the rule is prudent. Given the lengthy rulemaking process that will be needed to revise the final rule, we believe BLM should stay compliance dates for two years, rather than the proposed one year. Notably, the 2016 rule took more than two years to develop and finalize.

Chairman Bishop and Ranking Member Grijalva, As trade associations representing companies who produce the energy needed to fuel our cars and heat our homes, we support H.R. 4239, the SECURE American Energy Act, which seeks to achieve and maintain our domestic energy dominance by harnessing more onshore and offshore energy production here in the U.S.

A broad coalition of 12 energy industry associations representing oil, natural gas, wind, solar, efficiency, and other energy technologies submitted joint comments to the Federal Energy Regulatory Commission (FERC) in response to the Department of Energy’s (DOE) proposed rulemaking on grid reliability and resiliency pricing. In the joint comments, the coalition urged FERC not to adopt DOE’s proposed rule to provide out-of-market financial support to uneconomic coal and nuclear power plants in the wholesale electricity markets overseen by FERC.