These comments are filed on behalf of the Independent Petroleum Association of America (IPAA) and the American Exploration and Production Council (AXPC).
The undersigned groups represent workers and companies who want to build a brighter future for America. That means developing a robust transportation system that supports the nation. That means plentiful, affordable energy for American consumers. That also means expanding the ways we deliver energy, from liquid energy to natural gas to renewable energy such as wind and solar. That means good-paying manufacturing and construction jobs for American workers. We cannot bring this future to America without new infrastructure projects.
The American Exploration and Production Council (AXPC), American Petroleum Institute (API), Independent Petroleum Association of America (IPAA), International Association of Geophysical Contractors (IAGC), and Western Energy Alliance, submit these comments on the U.S. Fish and Wildlife Service’s Draft Endangered Species Act Compensatory Mitigation Policy. The Trades share the Service’s interest in improving the efficacy and efficiency of the conservation programs implemented pursuant to the Endangered Species Act; however, we are concerned that the Draft Compensatory Mitigation Policy will not bring forth the clarity, predictability, or transparency that the Service anticipates. Indeed, we believe that the Draft Policy, if finalized as proposed, is too complex, would only deter participants from engaging in compensatory mitigation, and would make the Service’s approach to mitigation more costly, burdensome, opaque, and unpredictable. The Trades’ member companies are proud of the conservation benefits that have been realized through their participation in compensatory mitigation, and strongly wish to see the Service’s compensatory mitigation program structured in a way that maintains a focus on conservation and incentivizing participation. As such, we encourage FWS to allow stakeholder to use all the tools in the conservation toolbox and not use the Draft Policy to favor certain specific mitigation instruments.
Joint comments, along with API, AXPC, and Western Energy Alliance, to the U.S. Fish and Wildlife Service in response to proposed rule to list the Texas Hornshell as endangered under the Endangered Species Act, highlighting that a listing of the species is not warranted.
API and IPAA understand that your office is reviewing rules proposed by the National Park Service and the U.S. Fish and Wildlife Service (the Services) to regulate operations on privately held minerals that lie beneath lands administered by the Services as units in the National Park System or as National Wildlife Refuges. Our more detailed comments to each rule as originally proposed are attached for your reference.
IPAA and other industry trade associations submitted an extension request to the U.S. Fish and Wildlife Service this week to extend the comment deadline for the public review period for the Service’s Endangered Species Act (ESA) Compensatory Mitigation Policy. The letter asks that the Services extend the public comment period for this proposal for at least an additional 30 days, or until November 16, 2016. The existing public comment period provides only a limited window for review and comment on a new policy that is the first comprehensive treatment of the role of compensatory mitigation in the process of the Service’s review of potential remedies for effects on species and habitats of concern from projects proposed by entities in the private or public sectors.
The Independent Petroleum Association of America (IPAA), American Petroleum Institute (API), American Exploration & Production Council (AXPC), Petroleum Association of Wyoming (PAW) and Western Energy Alliance (Alliance) (the Trades) submit these comments on the joint U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) draft revision to their Habitat Conservation Planning Handbook (Draft HCP Handbook).
The American Petroleum Institute (API), National Ocean Industries Association (NOIA), Independent Petroleum Association of America (IPAA), International Association of Drilling Contractors (IADC), the International Association of Geophysical Contractors (IAGC), and the Offshore Operators Committee (OOC) offer the following comments on the National Oceanic and Atmospheric Administration (NOAA) request for comments on the Draft Environmental Impact Statement (“DEIS”) for the proposed actions of boundary expansion and application of existing regulations and management plan actions to new geographic areas of the Flower Garden Banks National Marine Sanctuary published in the Federal Register on June 10, 2016. Comments submitted on behalf of the Associations are submitted without prejudice to any member’s right to have or express different or opposing views.
This letter is being sent on behalf of the Independent Petroleum Association of America (IPAA). IPAA represents the thousands of independent oil and natural gas explorers and producers, as well as the service and supply industries that support their efforts, that will most directly be impacted by the U.S. Environmental Protection Agency (EPA) policy decisions to regulate methane directly from the oil and natural gas sector. Independent producers develop about 95 percent of American oil and natural gas wells, produce 54 percent of American oil, and produce 85 percent of American natural gas. Historically, independent producers have invested over 150 percent of their cash flow back into American oil and natural gas development to find and produce more American energy. IPAA is dedicated to ensuring a strong, viable American oil and natural gas industry, recognizing that an adequate and secure supply of energy is essential to the national economy.
OSHA is considering revisions to the 29 CFR § 1910.119 Process Safety Management (PSM) standard. This letter provides comments from the American Exploration & Production Council (AXPC) and the Independent Petroleum Association of America (IPAA) on OSHA’s Process Safety Management Small Entity Representative Background Document as well as the Small Business Advocacy Review Panel final report.
