Letters & Comments

The Independent Petroleum Association of America (IPAA) requests a 60 day extension on the initial comment period related to the Information Collection Request for Oil and Gas Facilities. IPAA requests this extension because the current comment period is too short for industry professionals to analyze the complexities of an Information Collection Request (ICR) given the simultaneous requirement to develop implementation plans for compliance with Subpart OOOOa that results from its formal promulgation. However, it is also too short for the Agency to address many issues that it needs to consider before initiating the ICR.

The American Petroleum Institute (API), the Offshore Operators Committee (OOC), the National Ocean Industries Association (NOIA), the Independent Petroleum Association of America (IPAA), the International Association of Drilling Contractors (IADC), and the Offshore Marine Services Association (OMSA) submit comments on the Bureau of Ocean Energy Management’s (BOEM), proposed rule Air Quality Control, Reporting and Compliance, 81 Federal Register 19718 (April 5, 2016), Docket Id: BOEM-2013-0081.

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 and Services Association (PESA), and the Alaska Oil and Gas Association (AOGA) (collectively, the Associations) offer the following comments on the Bureau of Ocean Energy Management’s (BOEM) request for comments on the Proposed Outer Continental Shelf (OCS) Oil and Gas Leasing Program 2017-2022 published in the Federal Register on March 18, 2016.

The American Exploration & Production Council (AXPC) and the Independent Petroleum Association of America (IPAA) were pleased to see the publication of the Proposal to Reissue and Modify Nationwide Permits in the federal register on June 1, 2016, (Volume 81, Number 105) and respectfully request a 60-day extension to the comment deadline provided in the notice.

The American Petroleum Institute (API) and Independent Petroleum Association of America (IPAA) appreciate the opportunity to comment on BLM’s proposed Resource Management Planning Rule appearing at 81 Fed. Reg. 9674, February 25, 2016.

The American Petroleum Institute, 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), and the US Oil and Gas Association, urge the Office of Information and Regulatory Affairs (OIRA) to exercise its discretion to review the draft final regulations in the Bureau of Safety and Environmental Enforcement’s (BSEE) rulemaking proposed as “Oil and Gas and Sulphur Operations on the Outer Continental Shelf—Oil and Gas Production Safety Systems,” 78 Fed. Reg. 52,240 (Aug. 22, 2013). This rulemaking would not only make significant changes to the requirements related to offshore oil and gas production safety systems but also, critically, to the regulations related to Best Available and Safety Technology (BAST).

The American Petroleum Institute (API) and the Independent Petroleum Association of America (IPAA) submit these comments on the revisions to the proposed regulations for petitions for listing species under the Endangered Species Act (ESA).

The American Petroleum Institute (API) and Independent Petroleum Association of America (IPAA) submit these comments on the U.S. Fish and Wildlife Service’s proposed revisions to its Mitigation Policy (Draft Policy).

The American Petroleum Institute (API), National Ocean Industries Association (NOIA), Independent Petroleum Association of America (IPAA), U.S. Oil and Gas Association (USOGA), International Association Of Geophysical Contractors (IAGC), Alaska Oil and Gas Association (AOGA) (collectively, the Associations) offer the following on the Bureau of Ocean Energy Management’s (BOEM’s) Draft Programmatic Environmental Impact Statement (DPEIS) on the Outer Continental Shelf (OCS) Oil and Gas Leasing Program: 2017 – 2022 released March 18, 2016.

The Independent Petroleum Association of America (IPAA), the Western Energy Alliance (Alliance), the American Exploration and Production Council (AXPC), and the US Oil and Gas Association (USOGA) (collectively “the Associations”) submit the following comments on the Bureau of Land Management’s (BLM) proposed Waste Prevention, Production Subject to Royalties, and Resource Conservation Rule.