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Letters & Comments

Letters and Comments Jun 21, 2022

Dear Secretary Granholm,

On behalf of a coalition of energy trade associations representing the full spectrum of the American energy industry, we request the opportunity to meet with you to discuss ways our companies can partner with you to lower energy costs for Americans, strengthen our domestic energy security, and assist our allies by solidifying their energy security as well.

Our coalition’s member companies work together to produce 90% of American natural gas and 83% of American oil. We represent over 770,000 energy workers who work all over the United States to produce this energy and the equipment to do so. We represent all aspects of the oil and natural gas industry, from small service and technology providers, to onshore and offshore independent producers of all sizes.

While our companies are responsible for a vast majority of domestic energy production, the effects of market and policy changes on our businesses are often magnified. Large international operators with a diverse portfolio can weather major policy changes and economic downturns, but our individual companies feel disproportionate impacts of these policy and market shifts. …

Letters and Comments Jun 14, 2022

Dear Senators,

As the backbone of the American oil and natural gas industry, our respective organizations express our firm opposition to a methane emissions tax currently being considered in Congress as part of a potential budget reconciliation package.

Since 2012, the Environmental Protection Agency (EPA) has regulated methane emissions via the Clean Air Act (CAA) New Source Performance Standards (NSPS) OOOO and OOOOa, primarily through storage tank vapor capture, pneumatic controllers, and leak detection and repair. The focus is to prevent emissions from new facilities, identify leaks as early as possible, quickly fix them, and remove the emissions from the atmosphere.

Last year, EPA released proposed revisions to its NSPS rules that would further tighten emission standards for all new sources and update guidelines for existing sources. These revisions are likely to be finalized within the next year. Because EPA tightly regulates methane, any new fee is unlikely to have a large-scale impact on overall emission levels and would merely be punitive in nature. Furthermore, the extreme impracticability of a proposed tax leads us to believe that the true intent, combined with other proposals from Congress and the Administration, is not to protect the environment but to regulate American oil and natural gas production out of existence. …

Letters and Comments Jun 13, 2022

IPAA’s comments describe how the oil and natural gas production industry is uniquely affected by the SEC climate reporting proposal, and ultimately conclude that the SEC should withdraw its proposal:

“The SEC is stepping far too aggressively into a rapidly evolving arena too soon. Information on companies’ actions to address their ESG responsibilities is growing rapidly each year. At the same time the lack of a consistent framework for presenting information inhibits the value. Time is needed to allow these diverse processes to settle into a more straightforward format.

The SEC proposal does not enhance the process. It merely creates still another burden. Moreover, by adding the materials as part of an SEC filing, it creates inappropriate liability for essentially speculative information.”

…

In addition to these comments, IPAA supports comments filed by the Chamber of Commerce, the National Association of Manufacturers, the American Petroleum Institute, the Western Energy Alliance and the American Exploration and Production Council.

Letters and Comments Jun 5, 2022

IPAA, NOIA, API, LMOGA, the U.S. Chamber of Commerce, the Consumer Energy Alliance, and 81 other groups wrote to President Biden and called on the administration to release the next Five Year Program for offshore oil and gas leasing as quickly as possible. The diverse group of trades represent energy producers and service companies, manufacturers, retailers, and small businesses. The trades write:

For the U.S. to continue to be an energy leader into the future, smart and effective energy policies are needed today. However, your administration’s policies have often hindered domestic producers’ ability to deliver on this growing demand. Oil and natural gas leasing on Federal lands and waters has essentially stopped, despite court orders, and while DOI has taken steps to complete and implement the next 5-year Program, there will be an unprecedented gap between the current and next 5-year Program.

Letters and Comments May 27, 2022

As emphasized in the 2017 NWPs rulemaking, “[t]he utility line activities authorized by NWP 12 will continue to be needed by society, including the goods and services transported by those utility lines.”2   This remains true in 2022 with NWP 12‐ authorized activities remaining essential to the construction, operation, and maintenance of efficient oil and gas facilities which in turn help meet the energy needs of the nation.3   NWP 12 serves as a strong motivator for the regulated industry to design projects In a way that reduces environmental impacts.  The regulatory certainty provided by the orderly cycle of NWP issuance allows private companies to secure the investments that make private operation of this important public infrastructure system reliable.

To assure regulatory certainty, we urge the USACE to not reopen NWP 12 at this time, and instead allow NWP 12 to continue to be authorized and reissued as part of the current cycle of the NWPS set to expire on March 14, 2026.

We strenuously object to any “potential off‐ramps” that go beyond the statutory requirements and the underlying intent of NWPs to lessen administrative burdens.  We object to any additional triggers mandating individual reviews of permits.

Letters and Comments May 27, 2022

Our members have a substantial and direct interest in the NWP-12 review and in smart regulations that protect the environment, create jobs, drive innovation, and ensure a better quality of life for everyone. To accomplish these goals, regulations governing America’s land, water, and infrastructure must be designed and maintained with the utmost care to ensure that regulations are effective in achieving their desired objectives, while simultaneously avoiding unnecessary environmental, social, and economic impacts. A strong, stable, and predictable nationwide permitting program will continue to ensure that the United States can prosper and grow sustainably and responsibly.

The following considerations weigh heavily in favor of maintaining NWP-12 in its current form:

 Contributing to our national and energy security.

 Ensuring utility and energy reliability

 Providing the foundation for decarbonization infrastructure

 Serving customers with affordable energy.

 Providing predictability and regulatory certainty for NWP-12 and other Nationwide Permits

 Maintaining the five-year cycle

Letters and Comments May 23, 2022

IPAA submitted joint industry and allied trade group comments to the Fish and Wildlife Service’s proposed uplisting of the Northern Long-Eared Bat. The Service is proposing an Endangered listing status for the bat, which is found in 37 states and the District of Columbia. By the Services own admission, the dwindling bat numbers are due to a disease infecting the bats known as the white-nose syndrome and not due to industrial activities. The white-nose syndrome has spread across nearly eighty percent of the species entire range since it was listed as threatened in 2015.

IPAA’s joint comments focus on pointing out the flawed argument that industry would be able to reverse the decline in bat population with extreme measures due to the fact that bat population is suffering as a result of disease.

Letters and Comments Apr 26, 2022

IPAA was among 33 trade and industry associations led by the Western Energy Alliance in writing to the Securities and Exchange Commission to “respectfully request that SEC provide a substantial comment period for the climate change disclosure rule given the size, scope, complexity, and ramifications of the rule. The 39 days allotted for comment since the proposed rule was published in the Federal Register are woefully inadequate for the magnitude of this rule, which runs to 506 pages, contains 1,068 footnotes, references 194 dense academic and governmental reports, imposes a $10.235 billion cost on society, and seeks answers to 196 discrete questions. The public requires ample time to consider all the materials SEC has laid out in this rule in order to thoughtfully and thoroughly respond. Likewise, SEC has a statutory obligation to provide the public with a meaningful opportunity to comment. Thirty-nine days does not constitute a meaningful opportunity when there are so many wide- ranging economic and financial impacts from this rule.”

The associations on the letter represent thousands of upstream, midstream, downstream, and service companies in the oil and natural gas industry across the entire country.

Letters and Comments Mar 23, 2022

The Interstate Natural Gas Association of America, The Natural Gas Supply Association, The American Gas Association, and the Independent Petroleum Association of America, on behalf of the people and companies they represent which produce, transport, and deliver domestically produced natural gas, wrote President Joseph R. Biden to support the Administration’s recent actions to hold Russia accountable for its aggression against Ukraine and to propose a meeting with Administration leaders to offer a solution to leverage our domestic natural gas resources to meet current and future energy needs and address the climate challenges faced at home and abroad given the current geopolitical crisis.

“Our industry looks forward to engaging with you and your Administration to examine how we can guarantee sufficient resources are available to deter supply shortages now and into the future. Working together, we believe the natural gas industry will be key to helping this nation and our allies continue on the path to meeting both vital climate goals and critical energy reliability needs during this time of global turmoil.”

“This partnership between the U.S. government and our industry has yielded substantial benefits for the American people and our allies abroad, but significant work remains to achieve your Administration’s goal of ensuring that natural gas supply can keep up with domestic and global demand. In addition to encouraging supply increases to meet today’s challenges, it is also essential to ensure that there is adequate natural gas infrastructure—including Liquefied Natural Gas (LNG) terminals and pipelines—so natural gas supply can reach those who need it the most both at home and abroad.”

Letters and Comments Mar 18, 2022

Dear Mr. President, …

We strongly believe this is a moment in time where we can, and should, come together as one nation to fortify, deepen, and expand our energy capacity and capability.

Indeed, we have heard certain parts of your administration’s call for our industry to step up. In particular, we listened with great interest to the recent remarks of Secretary Granholm at CERAWeek in Houston.

To that end Mr. President, we as representatives of critically important small and midsized energy producers are committed to do what we can at this moment on behalf of the American people. We certainly understand first-hand the impacts higher costs, driven by inflation and related factors, can have on small businesses and their employees.

However, there is a key challenge standing in the way of unity: the words and actions of you and members of your administration. …

Letter signers:

Western Energy Alliance

Permian Basin Petroleum Association

US Oil and Gas Association

Independent Petroleum Association of America

National Stripper Well Association

Mid Continent Oil and Gas Association

New Mexico Oil and Gas Association

North Dakota Petroleum Council

Illinois Oil and Gas Association

Energy Workforce & Technology Council

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.