Letters & Comments

Dear Secretary Zinke and Acting Director Kurth: Pursuant to the Right to Petition Government Clause of the First Amendment of the U.S. Constitution and Section 553(e) of the Administrative Procedure Act, the American Petroleum Institute, CropLife America, Independent Petroleum Association of America, National Association of Home Builders, National Cotton Council, and National Rural Electric Cooperative Association hereby submit this petition, on an emergency basis, to the U.S. Department of the Interior and the U.S. Fish and Wildlife Service. Petitioners ask the Department and the Service to extend the current March 21, 2017 effective date of the final rule listing the rusty patched bumble bee as endangered under the Endangered Species Act (ESA), 16 U.S.C. §§ 1531 et seq., until January 11, 2018.

Dear BOEM FOIA Officer: This Freedom of Information Act (FOIA) request is directed to the United States Department of the Interior, Bureau of Ocean Energy Management (BOEM). It is made pursuant to 5 U.S.C. § 552, and the Department of the Interior’s implementing regulations under 43 C.F.R. Part 2. The National Ocean Industries Association (NOIA), the Independent Petroleum Association of America (IPAA), the Louisiana Mid-Continent Oil and Gas Association (LMOGA), and the Gulf Economic Survival Team (GEST) are interested in obtaining the below described information relating to Notice to Lessees No. 2016-N01 entitled “Requiring Additional Security” issued by BOEM with an effective date of September 12, 2016. The date range for this request is January 1, 2014 through the present.

The Independent Petroleum Association of America submits the following comments in support of the Application by Spire STL Pipeline LLC for Certificates of Public Convenience and Necessity to construct, own, and operate a new interstate natural gas pipeline and to provide interstate natural gas transportation and transportation‐related services subject to the jurisdiction of the Federal Energy Regulatory Commission.

Dear Congressman Tipton: The Independent Petroleum Association of America (IPAA) strongly supports your efforts to use the Congressional Review Act (CRA) to vacate the Department of the Interior Office of Natural Resource Revenue’s (ONRR) royalty valuation rule (81 FR 43338-01 July 1, 2016). The ONRR rule imposes significant compliance costs on independent producers and is designed to make operating on federal and tribal lands overly complex and costly. This rule will hamper the ability of independent producers operating both onshore and offshore and will ultimately reduce the amount of oil and natural gas produced on America’s federal lands.

Dear Acting Secretary Haugrud, Acting Director Kurth, and Regional Director Tuggle: On behalf of the American Stewards of Liberty and the Independent Petroleum Association of America, we write to inform you of our intent to file a civil suit against the U.S. Fish and Wildlife Service (“Service”) pursuant to the citizen suit provision of the Endangered Species Act (“ESA”), 16 U.S.C. § 1540(g). We provide this letter to you pursuant to the 60-day notice requirement of the ESA citizen suit provision. Specifically, the basis for the intended lawsuit is that the Service has failed to timely make its required 12-month finding on the petition to delist the American burying beetle (Nicrophorus americanus) in accordance with 16 U.S.C. § 1533(b)(3)(B).

The Independent Petroleum Association of America (IPAA) submits the following comments in response to the Interim Final Rule (IFR) issued on December 19, 2016, by the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) in Docket No. PHMSA-2016-0016. IPAA represents the companies that drill 90 percent of the nation’s oil and natural gas wells. These companies produce 85 percent of American natural gas and 54 percent of American oil. IPAA members represent the full range of producers, from small family-owned businesses, to the large independent companies that are some of the largest domestic natural gas producers. IPAA’s comments focus on the need for PHMSA to clarify that its underground gas storage regulations do not apply to storage associated with production.

Dear Majority Leader McConnell and Democratic Leader Schumer: The undersigned 616 groups from each of the 50 states strongly urge you to consider and pass the Regulatory Accountability Act of 2017 (RAA), to be introduced by Senator Portman. The RAA recently passed the House with a bipartisan vote of 238-183, and now we urge you to do the same. We believe that federal regulations should be narrowly tailored, supported by strong and credible data and evidence, and impose the least burden possible, while implementing congressional intent.

Dear Mr. President: We write to you regarding the imminent lack of a quorum at the Federal Energy Regulatory Commission (“FERC”), which will occur upon the departure of Commissioner Norman C. Bay, effective February 3, 2017. The absence of a quorum will leave the agency unable to tackle much of its important work promoting energy infrastructure for the benefit of U.S. energy consumers.

IPAA submitted joint comments with API, the Permian Basin Petroleum Association, and Western Energy Alliance stating that the best scientific and commercial information available demonstrates that the Lesser Prairie Chicken (LPC) does not meet the Endangered Species Act’s (ESA) definitions of either a threatened or endangered species. As outlined in the comments, the Trades believe that the best scientific and commercial information available demonstrate that the LPC does not meet the ESA’s definitions of either a threatened or endangered species. LPC abundance has rebounded from historic lows, and through a combination of public and private efforts, the LPC is now better protected than at any previous time. A listing as threatened or endangered will not provide any additional conservation benefits above what already exists.

Dear Mr. President: The Independent Petroleum Association of America (IPAA) urges the White House to expeditiously submit nominees to the Senate Energy and Natural Resources Committee to fill open seats on the Federal Energy Regulatory Commission that will return the Commission to a quorum.