Letters & Comments

Dear Mr. Cohen: The Independent Petroleum Association of America (IPAA) submits the following in response to the May 30, 2017, Federal Register notice seeking comments and information as part of the U.S. Department of Energy (DOE) implementation of Executive Order 13771, “Reducing Regulation and Controlling Regulatory Costs.” IPAA represents the thousands of independent oil and natural gas explorers and producers that will be the most significantly affected, either positively or negatively, by potential changes in regulations. Independent producers drill about 90 percent of American oil and gas wells, produce 54 percent of American oil and produce 85 percent of American natural gas. IPAA focuses on three areas where DOE can encourage development of American oil and natural gas production.

Dear Ms. Biercevicz: American Petroleum Institute (API), the American Exploration & Production Council (AXPC), Independent Petroleum Association of America (IPAA), the Natural Gas Supply Association (NGSA), US Oil & Gas Association (USOGA), and the Council of Petroleum Accountants Societies (COPAS) respectfully submit comments in response to the Federal Register notice issued on April 4, 2017 [FR Doc. 2017-06501] (“April 4 Notice”). In the April 4 Notice, the Energy Information Administration (EIA) requested industry comments on its proposal to expand its crude oil, lease condensate, and natural gas data collection to include five additional states/areas; collect crude oil and condensate stabilizer data; increase commentary details through multiple default-options as well as to provide a three-year extension of the EIA Form EIA-914 “Monthly Crude Oil, Lease Condensate, and Natural Gas Production Report.” Given that members of our organizations account for a large portion of the companies that are responsible for gathering and reporting production data to EIA, we appreciate the opportunity to comment on EIA’s proposal.

Dear Mr. Botwin: Together, the signatory trade associations (hereafter, “the Associations”) represent the majority of the oil and natural gas industry in the United States, across exploration and production (the “upstream”), transportation (the “midstream”) and manufacturing/refining (the “downstream”).
The Associations acknowledge the underlying objective for the nation to assess whether US imports of aluminum impair national security, per Section 232 of the Trade Expansion Act of 1962, as amended (hereafter referred to as “Section 232”). As the Associations articulated in our comments on Section 232 National Security Investigation of Imports of Steel, we urge the Department of Commerce to define “national security” narrowly.

Dear Chairman Walden and Ranking Member Pallone: The undersigned associations are writing to express our support for H.R. 2910, legislation introduced by Rep. Bill Flores (R-TX) to improve interagency coordination in the review of proposed natural gas pipelines. The legislation is scheduled for consideration by the Energy Subcommittee on June 22 and has our united support.

Dear Majority Leader McConnell and Democratic Leader Schumer: The undersigned associations urge you to act quickly to restore a quorum at the Federal Energy Regulatory Commission (FERC). FERC has lacked a quorum for more than four months, placing energy infrastructure permitting and approvals on an indefinite hold and creating an unexpected barrier to improving the permitting process for infrastructure projects. The Senate Energy and Natural Resources Committee recently cleared two nominees on strong bipartisan votes; their nominations now await a vote by the full Senate.

Dear Mr. Botwin: The Associations acknowledge the underlying objective for the nation to assess whether US imports of steel impair national security, per Section 232 of the Trade Expansion Act of 1962, as amended (hereafter referred to as “Section 232”). In doing so, the Associations urge the Department of Commerce to define “national security” narrowly so as to exclude steel supplied to the US oil and natural gas industry. The Associations remind the Department of Commerce that “national security” for this current Section 232 investigation is defined in 15 CFR § 705.4 with reference to eight specific factors. Most of these factors naturally focus specifically on considerations particular to “national defense;” it also includes certain catch-all language that would permit consideration of any “relevant” factors. However, the Associations caution the Department of Commerce to strictly limit its reliance on any “relevant” factor, which could dilute the strength – and legal defensibility – of the Department of Commerce’s analysis, and divert it from its core assessments related to national defense.

IPAA and AXPC urge PHMSA to reconsider the ANPRM, as it is premature given ongoing studies and the directive from the Office of Management and Budget (OMB), “Promoting Energy Independence and Economic Growth.” In keeping with the OMB guidance, PHMSA also should reevaluate its sampling and testing program as it applies to crude oil transported by truck. PHMSA implemented its sampling and testing program in a joint rulemaking with the Federal Railroad Administration (FRA), with the notice directed exclusively at crude transported by rail. As such, the program did not clearly solicit input from affected producers. PHMSA’s efforts to enforce the program have resulted in an ad hoc compliance program, with producers being forced to comply with extremely tight time constraints. The process and the resulting program do not achieve the goals of producers and PHMSA to transport hazardous materials in a safe manner.

The American Petroleum Institute (API), the International Association of Drilling Contractors (IADC), the Independent Petroleum Association of America (IPAA), the National Ocean Industries Association (NOIA), the Offshore Operators Committee (OOC), the Petroleum Equipment & Services Association (PESA), and the US Oil and Gas Association are pleased to see the Administration and the Department of the Interior (DOI) continuing to take strides to put in place a lasting, domestically-focused energy policy that will help the U.S. “maintain the Nation’s position as a global energy leader.” For too long the U.S. has been hampered by the lack of a strong domestic oil and natural gas energy policy. The oil and natural gas industry is committed to developing and producing domestic energy resources for the benefit of all Americans and doing so in a safe and environmentally sound manner.

These comments are filed on behalf of the Independent Petroleum Association of America (IPAA), the American Association of Professional Landmen (AAPL), the American Exploration and Production Council (AXPC), the Association of Energy Service Companies (AESC), the Domestic Energy Producers Alliance (DEPA), the International Association of Drilling Contractors (IADC), the International Association of Geophysical Contractors (IAGC), the National Stripper Well Association (NSWA), the Petroleum Equipment & Services Association (PESA), and the following organizations. Collectively, these groups represent the thousands of independent oil and natural gas explorers and producers, as well as the service and supply industries that support their efforts, that are significantly affected by Environmental Protection Agency (EPA) regulatory actions.

Dear Mr. Aguilar: I write on behalf of the membership of the Independent Petroleum Association of America (IPAA) in response to the Advance Notice of Proposed Rulemaking, published at 82 Federal Register 16,325 (April 4, 2017), concerning royalty valuation for federal oil and gas, as well as federal and Indian coal. We appreciate the willingness of the Office of Natural Resource Revenues (ONRR) to re-examine royalty valuation.