Letters & Comments

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 appreciate the opportunity on March 21, 2016, to meet with representatives from OIRA and other federal agencies regarding the proposed rule from the Bureau of Safety and Environmental Enforcement (BSEE) addressing offshore Blowout Preventer Systems and Well Control. We felt that the discussion was productive, and we hope that the government representatives in attendance found the information useful in their work to improve this important rule.

Pursuant to 49 C.F.R. § 190.319, the American Gas Association, the American Petroleum Institute, the American Public Gas Association, the Gas Processors Association, the Interstate Natural Gas Association of America, and the Independent Petroleum Association of America are writing to request a 60 day extension of the comment deadline included in the above-referenced docket.

The following comments to the proposed Greenhouse Gas (GHG) Reporting Rule (Subpart W) changes released by the Environmental Protection Agency (EPA) on January 29, 2016, are submitted on behalf of Western Energy Alliance, the Independent Petroleum Association of America, and the American Exploration and Production Council. We appreciate the opportunity to provide EPA with comments on its proposed rule, and wish to express several concerns with EPA’s proposal. The timing of EPA’s proposal is troubling, given that industry cannot fully evaluate its impacts until EPA’s New Source Performance Standards (NSPS) Subpart OOOOa is finalized. This problem is compounded by the Bureau of Land Management’s (BLM) recently proposed rule addressing venting and flaring, as there is potential for significant overlap in leak detection and repair (LDAR) protocols. Should EPA decide to move ahead with its proposed changes despite these concerns, we have several suggested revisions that will increase the accuracy and flexibility of the proposed rule.

The Independent Petroleum Association of America (IPAA), the Western Energy Alliance (Alliance), and the American Exploration and Production Council (AXPC) (collectively “the Associations”) appreciate the opportunity to comment to the Office of Management and Budget (OMB) in relation to the information collection requirements that would be imposed by the Bureau of Land Management’s (BLM) proposed Waste Prevention, Production Subject to Royalties, and Resource Conservation Rule. The proposed information collection requirements would result, contrary to the requirements of the Paperwork Reduction Act (44 USC §§ 3501-3521), in unnecessary new costs and burdens, without compensating benefits, to domestic oil and natural gas producers, the vast majority of which are small, independent businesses.

Dear Representative Jenkins: We strongly support your introduction of legislation to remove the net income limitation on percentage depletion for oil and natural gas produced from marginal properties. This important relief is critical to preserving the production of oil and natural gas from the most marginal oil and natural gas prospects. We appreciate your sponsorship of this legislation and plan to work to urge other Representatives to support your efforts for this important legislation that will protect jobs, strengthen America’s energy security, and enhance the climate for small businesses in America.

The American Exploration & Production Council (AXPC) and the Independent Petroleum Association of America (IPAA) appreciate the opportunity to provide comments on the Occupational Safety and Health Administration’s (OSHA) Safety and Health Program Management Guidelines. AXPC and IPAA fully support OSHA’s efforts to revise the Safety and Health Program Management Guidelines (first published in 1989) to reflect modern technology and practices.

The American Petroleum Institute and the Independent Petroleum Association of America submitted comments on the Draft Methodology for prioritizing status reviews and accompanying 12-month findings on petitions for listing species under the Endangered Species Act. API and IPAA appreciate that the Draft Methodology recognizes that the Service can only make decisions under the ESA based on the best available scientific and commercial data. By giving a higher priority to species for which there is ample data currently available, the Service can correctly ensure that it does not base its ESA decisions on speculative, incomplete, or unreliable information. The comments strongly encourage the Service to use sound science as a fundamental tool when assigning a priority level to any species, including any decision that a species warrants the highest priority level.

This letter provides the comments of the American Petroleum Institute (API) and the Independent Petroleum Association of America (IPAA) (the “Associations”) in response to the U.S. Fish and Wildlife Service’s proposed rule and associated draft environmental impact statement (DEIS) addressing the management of non-federal oil and gas rights on National Wildlife Refuge System (NWRS) lands and waters. See 80 Fed. Reg. 77,200 (Dec. 11, 2015). The Associations appreciate the Service’s consideration of these comments.

On behalf of the Center for Liquefied Natural Gas, the Natural Gas Supply Association and the Independent Petroleum Association of America, we write to applaud the Senate Energy and Natural Resources Committee for the hard work you have done moving S. 2012 – The Energy Policy Modernization Act (EPMA) – through Committee in July of 2015 and bringing it to Senate floor. Specifically, we are encouraged to see the inclusion of Section 1306 (Vehicle Research and Development), Section 1308 (Commercial and Transit Vehicles), Section 2201 (Action on applications to export liquefied natural gas), Section 2202 (Public disclosure of liquefied natural gas export destinations) and Section 3102 (Study on the economic impacts of liquefied natural gas exports) in the bipartisan legislative proposal. We strongly believe the passage of this legislation will help to accelerate the creation of a thriving domestic liquefied natural gas (LNG) industry.

Joint Letter with the American Stewards of Liberty, the Texas Public Policy Foundation, and Dr. Steven Carothers notifying the U.S. Fish and Wildlife Service that petitioners intended to file a civil suit against the agency in 60 days, following the Service’s failure to announce its 90-day finding on the petition to delist the American burying beetle.