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Infrastructure, Letters and Comments Jan 29, 2024

Dear Chairman Graves and Ranking Member Larsen:

The Waters Advocacy Coalition (WAC) strongly supports the below series of bills introduced by Members of the Water Resources and Environment Subcommittee. We encourage you to report these bills favorably to the full House.

These bills provide practical fixes to certain sections of the Clean Water Act (CWA) Section 402 National Pollutant Discharge Elimination System (NPDES) permit program, Section 404 dredge and fill permit program, and Section 304(a) process for establishing water quality criteria. These targeted reforms represent significant steps toward streamlining regulatory procedures,  providing greater certainty for businesses in our sectors, and helping meet our nation’s ambitious climate and infrastructure priorities.

  1. H.R. 7023 Nationwide Permitting Improvement Act (introduced by Rep. David Rouzer)
  2. H.R. 7026 Reducing Permitting Uncertainty Act (introduced by Rep. Pete Stauber)
  3. H.R. 7021 Water Quality Criteria Development and Transparency Act (introduced by Rep. Burgess Owens)
  4. H.R. 7008 Judicial Review Timeline Clarity Act (introduced by Rep. Eric Burlison)
  5. H.R. 7013 Confidence in Clean Water Permits Act (introduced by Rep. John Duarte)
  6. H.R. 5089 Reducing Regulatory Burdens Act of 2023 (introduced by Rep. David Rouzer)

Letters and Comments Jan 24, 2024

In a letter to Secretary Granholm and senior administration officials, the industry groups led by the American Petroleum Institute (API) and including the Independent Petroleum Association of America (IPAA), the American Exploration and Production Council (AXPC), Center for LNG (CLNG), LNG Allies and dozens of other industry groups, emphasized the critical role that continued U.S. LNG exports play in safeguarding national security, creating U.S. jobs, supporting our European allies and contributing to global climate goals.

“Our nation’s abundant supply of natural gas is an impactful geopolitical tool, helping insulate American consumers from increasing global instability while advancing American national interests and ensuring the energy security of key U.S. allies,” the groups wrote. “Moving forward with a pause on new U.S. LNG export approvals would only bolster Russian influence and undercut President Biden’s own commitment to supply our allies with reliable energy, undermining American credibility and threatening American jobs.”

Infrastructure, Letters and Comments Dec 13, 2023

Dear Mr. Cossette,

The Independent Petroleum Association of America (IPAA) appreciates the opportunity to provide comments on the Draft Environmental Impact Statement (DEIS) for the Dakota Access Pipeline (DAPL). …

IPAA would like to specifically emphasize the critical importance of maintaining the existing pipeline crossing as defined in Alternative Three. This alternative has the least environmental and safety impact, is the most economic, and provides the most energy security for consumers, landowners, and tribal communities.

The existing DAPL crossing is a critical linchpin in the nation’s energy infrastructure. It has been constructed with meticulous attention to safety and environmental considerations. Maintaining this crossing is crucial for ensuring safe, efficient, and uninterrupted transportation of crude oil. Altering the operations of the pipeline as suggested in several of the alternatives would not only impose significant financial and logistical burdens on the industry and the region, but also undermine the years of planning and investment that have gone into developing this critical energy asset.  The strategic importance of this crossing is demonstrated by its robust construction, adherence to the highest safety standards, and its minimal environmental footprint. Maintaining the existing route and continued uninterrupted operation guarantees the least ecological impact while offering maximum efficiency.

Letters and Comments, Regulations Dec 1, 2023

The Waters Advocacy Coalition (“WAC” or “Coalition”) submitted comments on the Interim Draft of the National Ordinary High Water Mark Field Delineation Manual for Rivers and Streams (“Draft Manual”). WAC represents a large cross-section of America’s construction, transportation, real estate, mining, manufacturing, forestry, agriculture, energy, wildlife conservation, and public health and safety sectors—all of which are vital to a thriving economy and provide much-needed jobs. WAC members’ activities, projects, and operations are often subject to Clean Water Act (“CWA”) regulation.

The comments detail how:

I. EPA and the Corps Must Go Through Rulemaking to Change the Scope of CWA Jurisdiction

II. At a Minimum, the Agencies Must Reaffirm That the OHWM Has No Relevance to the Relatively Permanent Standard

 

Letters and Comments, Offshore Nov 1, 2023

The American Petroleum Institute (API), Energeo Alliance (Energeo), Independent Petroleum Association of America (IPAA), Louisiana Mid-Continent Oil & Gas Association (LMOGA), National Ocean Industries Association (NOIA), and Offshore Operators Committee (OOC) (collectively, the Associations) offer the following comments on the Bureau of Ocean Energy Management’s (BOEM) Notice of Intent (NOI) to prepare another Programmatic Environmental Impact Statement (PEIS) for a “representative oil and gas lease sale” in the Gulf of Mexico (GOM) Eastern, Central and Western Planning Areas scheduled as part of the 2024-2029 Five-Year Outer Continental Shelf (OCS) Leasing Program. 88 Fed. Reg. at 67,803. For many years, the Associations and our members have worked collaboratively with the Department of the Interior (DOI) and its agencies (including BOEM) in support of the continued safety of industry workers and protection of the environment both offshore and onshore. At the same time, our members rely heavily on Congress’ statutory mandates (repeatedly recognized by the courts) that DOI make the OCS available for leasing and expeditious development. Many of our members are involved in exploring for and developing oil and natural gas resources in the GOM and we support BOEM holding all lease sales as scheduled in the 2024-2029 Proposed Final Program and offering all unleased acreage not subject to moratorium in those lease sales. Accordingly, BOEM should pursue Alternative B in the NOI.

Letters and Comments, Offshore Nov 1, 2023

The American Petroleum Institute (API), Energeo Alliance (Energeo), Independent Petroleum Association of America (IPAA), and Louisiana Mid-Continent Oil & Gas Association (LMOGA) (collectively, the Associations) offer the following comments on the Bureau of Ocean Energy Management’s (BOEM) call for information and nominations (Call) for lease sales in the Gulf of Mexico (GOM) Eastern, Central and Western Planning Areas scheduled as part of the 2024-2029 Five-Year Outer Continental Shelf (OCS) Leasing Program. Many of our members operate on the OCS and on federal lands onshore. For many years, the Associations and our members have worked collaboratively with the Department of the Interior (DOI) and its agencies (including BOEM) in support of the continued safety of industry workers and protection of the environment. At the same time, our members rely heavily on Congress’ statutory mandates (repeatedly recognized by the courts) that DOI make the OCS available for leasing and expeditious development. Our members are involved in exploring for and developing oil and natural gas resources in the GOM and we support holding all lease sales as scheduled in the 2024-2029 Proposed Final Program and offering all unleased acreage not subject to moratorium in those lease sales. …

The Associations reiterate their request that BOEM duly finalize its Five-Year Leasing Program, hold all GOM lease sales as scheduled during the 2024-2029 timeframe, and in those lease sales offer on a Region-wide basis all unleased acreage not subject to moratorium.

Letters and Comments, Regulations Oct 31, 2023

IPAA joined with over 70 other trade groups representing diverse businesses across the economy in urging the Biden administration to maintain the existing National Ambient Air Quality Standards (NAAQS) for fine particulate matter (PM2.5). In a letter to White House Chief of Staff Jeff Zients, the organizations warned that moving forward with the Environmental Protection Agency’s (EPA) proposed revisions would jeopardize American jobs and risk substantial economic harm.

The proposed revisions to the standard “would risk jobs and livelihoods by making it even more difficult to obtain permits for new factories, facilities, and infrastructure to power economic growth,” the groups wrote. “This proposal would also threaten successful implementation of the Infrastructure Investment and Jobs Act, the CHIPS and Science Act, and the important clean energy provisions of the Inflation Reduction Act. Our members have innovated and worked with regulators to significantly lower PM2.5 emissions and further progress is being made as part of the energy transition investments.”

Endangered Species, Letters and Comments, Offshore Oct 6, 2023

“… National Marine Fisheries Service (NMFS) must withdraw the Proposed Rule and reissue a critical habitat proposal that identifies for designation only those “specific areas within” areas of the Gulf of Mexico (GOMx) actually occupied by Rice’s whales that qualify as habitat and on which are “found” the “essential features” of Rice’s whale habitat that require special management. NMFS must consider the material economic, national security, and other relevant impacts of such a designation, including from “adverse modification” findings, as well as the revenue implications for the federal and state governments. Should NMFS move forward with designation of Rice’s whale critical habitat, it should exclude from such designation the central and northwestern GOMx where the impact of a designation would far outweigh any potential benefits to Rice’s whales.”

Endangered Species, Letters and Comments Oct 2, 2023
IPAA submitted comments to the record for the Fish and Wildlife Service’s proposed listing of the Dunes Sagebrush Lizard, whose habitat is primarily the Permian basin. Teaming up with the U.S. Chamber of Commerce, the comments focus heavily on F&WS’s lack of consideration for voluntary conservation measures as well as F&WS’s failure to demonstrate why a listing decision is warranted.
 IPAA is committed to reasonable species conservation but many of the recent listing decision by the Biden Administration are a politically motivated shot directly at the oil and natural gas industry.

Letters and Comments, Methane Oct 2, 2023

Re: Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; Docket No. EPA-HQ-OAR-2023-0234

The American Petroleum Institute, the American Exploration & Production Council, Independent Petroleum Association of America, The Petroleum Alliance of Oklahoma, and the American Fuel and Petrochemical Manufacturers (collectively “Industry Trades”) appreciate the opportunity to offer comments to the U.S. Environmental Protection Agency (EPA) on the proposed “Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems” (proposed on August 1, 2023). For perspectives of offshore operators, the Industry Trades encourage EPA to also review the Offshore Operators Committee (OOC) letter and incorporate them by reference herein. With this submittal, the Industry Trades seek to continue our participation in the rulemaking process as a collaborative stakeholder by providing meaningful solutions to simultaneously address EPA’s goals while addressing the burden of data collection (and identifying potential unintended consequences) that could result if the rulemaking is finalized as proposed.

The oil and natural gas industry has participated as key collaborative stakeholders, advancing the EPA Greenhouse Gas Reporting Program (GHGRP) since its inception by contributing expertise and proposing alternatives that reflect the reality of the industry and its evolving day-to-day operating practices. The Industry Trades have focused on providing information that will help inform decision makers and the public about various challenges to data collection and reporting required by the rule, which includes safety, accuracy, and feasibility concerns, as well as the need to protect sensitive information and to ensure that reporting requirements are placed on the correct reporters.

These comments on EPA’s proposed revisions to Subpart W reflect our continued interest in the evolution of the GHGRP to provide an accurate accounting of greenhouse gas (GHG) emissions from facilities across the full value chain of the oil and natural gas industry. Our comments cover concerns and recommendations in the wide range of sectors that relate to the operations of our collective members.

IPAA is the industry's strongest presence in the nation's capital and these are important times. The entire oil and gas industry remains under fire from anti-development groups; but with these challenges arise unique opportunities that IPAA is seizing for our members.