Letters & Comments

Pursuant to the October 2, 2017, Notice Inviting Comment, issued by the Federal Energy Regulatory Commission (FERC or “the Commission”) in the above-referenced docket, the Independent Petroleum Association of America and the following organizations (collectively, “Independent Producers”) hereby respectfully submit the following comments on the Notice of Proposed Rulemaking in this docket. The Independent Producers urge the Commission to reject the recommendations as set forth by the Secretary of Energy in its September 28, 2017, proposal of a rule for final action by the Commission.

Pursuant to Rule 212 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission, 18 C.F.R. § 385.212 (2016), and section 403(b) of the Department of Energy Organization Act, 42 U.S.C. § 7173, the Independent Petroleum Association of America and the signed independent producers hereby respectfully submit this motion for extension of time for filing comments on the Notice of Proposed Rulemaking in this docket. The Independent Producers request at a minimum the 90-day initial comment period and 45-day reply comment period suggested by the Energy Industry Associations.

Petitioners Western Energy Alliance and the Independent Petroleum Association of America respectfully request that the Court invalidate and remand the Bureau of Land Management’s rule related to the reduction of venting and flaring from oil and gas production on federal and Indian leases, Waste Prevention, Production Subject to Royalties, and Resource Conservation, 81 Fed. Reg. 83,008 (Nov. 18, 2016). The Rule exceeds BLM’s statutory authority, is inconsistent with such statutory authority, and is arbitrary, capricious, and an abuse of discretion.

To the Members of the United States Congress: We urge Congress to expeditiously pass a budget resolution with reconciliation instructions so that the promise of tax reform can be made a reality. It has been 31 years since Congress last reformed the tax code. Since then, the code has become an anchor weighing down the economy, job creation, and wage growth for American families.

Dear Secretary Zinke: The Independent Petroleum Association of America (IPAA) and the American Exploration and Production Council (AXPC) appreciate the opportunity to submit comments regarding ways the Department of the Interior can improve management of federal lands and reform the regulatory process utilized by the agency. The comments contained in this document specifically address regulatory reform at the Bureau of Land Management (BLM). We welcome the Trump Administration’s efforts to make American energy dominance a cornerstone of Administration policy. However, the current regulatory process at the BLM hampers that important goal.

Dear Ms. MacGregor and Mr. Nedd: On July 25, 2017, the Bureau of Land Management (BLM) published a proposed rule that would rescind a final rule BLM issued in March 2015. The “2015 Rule” was designed to regulate hydraulic fracturing on federal and Indian lands. This submission constitutes comments on the July 2017 proposal from the Independent Petroleum Association of America (IPAA) and the Western Energy Alliance (collectively, the Associations). The Associations collectively represent thousands of independent oil and natural gas explorers and producers, as well as the service and supply industries that support their efforts. It is the members of these groups that the proposed rescission will most significantly affect. Independent producers drill about ninety-five percent of American oil and natural gas wells, produce about fifty-four percent of American oil, and more than eighty-five percent of American natural gas. From the beginning, the Associations have actively engaged to assist BLM’s rulemaking efforts related to hydraulic fracturing.

Dear Secretary Zinke: The Independent Petroleum Association of America (IPAA) submits the following comments in response to the Department of Interior’s (DOI’s) request for public comment on ways to improve implementation of regulatory reform initiatives, policies, and identify regulations for repeal, replacement or modification under Executive Order 13777, “Enforcing the Regulatory Reform Agenda.” The comments contained herein specifically address regulatory reform at the U.S. Fish and Wildlife Service, highlighting the Endangered Species Act, Migratory Bird Treaty Act, and mitigation efforts.

The Independent Petroleum Association of America (IPAA) submits the following comments in support of the expeditious review and approval of the Department of Environmental Quality’s 401 Water Quality Certification for the proposed Atlantic Coast Pipeline. IPAA submits that the final Environmental Impact Statement issued by the Federal Energy Regulatory Commission supports issuance of the certification, finding that Atlantic Coast’s “surface water and wetlands impacts would be effectively minimized or mitigated.”

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 Drilling Contractors (IADC), International Association of Geophysical Contractors (IAGC), Petroleum Equipment Suppliers Association (PESA), and the Alaska Oil and Gas Association (AOGA) offer the following comments on the Bureau of Ocean Energy Management’s (BOEM) request for information and comments on the preparation of the 2019-2024 Outer Continental Shelf Oil and Gas Leasing Program published in the Federal Register on July 3, 2017. The Associations’ members are involved in exploring for and developing oil and natural gas resources found on the OCS and are interested in the development of the 2019-2024 OCS Leasing Program. In 2015, the U.S. oil and natural gas industry supported more than 10.3 million jobs nationwide and made up more than 7.5% of GDP. The decisions made regarding areas to include in the program will have long-term implications for our nation’s energy security, prospects for job creation, and future revenue generation.