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Letters & Comments

Letters and Comments Jan 31, 2022
Dear Administrator Regan:Please accept the comments of the following oil and natural gas associations and associations that support the industry on EPA’s proposal regarding New Source Performance Standards for the Oil and Natural Gas source sector:  Independent Petroleum Association of America (IPAA), Arkansas Independent Producers and Royalty Owners (AIPRO), Domestic Energy Producers Alliance (DEPA), Eastern Kansas Oil & Gas Association (EKOGA), Gas & Oil Association of West Virginia (GO-WV), Illinois Oil & Gas Association (IOGA), Independent Petroleum Association of New Mexico (IPANM), Indiana Oil and Gas Association (INOGA), International Association of Drilling Contractors (IADC), Kansas Independent Oil & Gas Association (KIOGA), Kentucky Oil & Gas Association (KOGA), Michigan Oil and Gas Association (MOGA), National Stripper Well Association (NSWA), North Dakota Petroleum Council (NDPC), Ohio Oil and Gas Association (OOGA), The Petroleum Alliance of Oklahoma (The Alliance), Petroleum Association of Wyoming (PAW), Pennsylvania Independent Oil & Gas Association (PIOGA), Texas Alliance of Energy Producers (Texas Alliance), Texas Independent Producers & Royalty Owners Association (TIPRO), and Western Energy Alliance (Alliance) – collectively, the Producer Associations.  The Producer Associations look forward to working with the EPA to improve the proposed regulatory actions.

Letters and Comments Jan 28, 2022

Today, IPAA and a coalition of trade associations from across the country wrote to Senators Sherrod Brown and Patrick Toomey, Chairman and Ranking Member of the Senate Committee on Banking, Housing, and Urban Affairs opposing the nomination of Sarah Bloom Raskin as Vice Chair for Supervision at the Federal Reserve. 

From the letter:

“We strongly oppose President Biden’s nomination of Sarah Bloom Raskin as Vice Chairwoman for Supervision at the Federal Reserve, the government’s most influential overseer of the American banking system. She is a strong advocate for debanking the very industry that powers America. Her multiple public statements indicate an agenda at odds with the President’s goal of providing Americans with reliable, affordable energy.

“Department of Energy projections show national and global oil and natural gas consumption increasing out to 2050, which belies Ms. Bloom Raskin’s public statements that our industry is a “dying one” that does not deserve access to the financial system…”

Letters and Comments Jan 24, 2022

Dear Chairman Manchin and Ranking Member Barrasso:

Thank you for the sensible debate and deliberations on the Build Back Better Act, the House version of which, for countless reasons, would be devastating to the economy and the future viability of the entire energy edifice of the country. We are grateful for your collective leadership in recent months to infuse balance into the conversation in order to craft more judicious legislation.

While we appreciate that recent language from your committee is not as extreme as the House version, it would still be a major blow to federal onshore oil and natural gas, which provides just under a tenth of American production, a valuable contribution that sustains rural communities and states across the West. In fact while many of the worst provisions envisioned by the House have been removed with respect to coal, hard rock mining, and the electrical grid, the target remains squarely on federal onshore oil and natural gas development. The timing of these provisions could not be worse, as the United States continues to struggle to return to levels of production achieved just a few years ago and as energy prices remain too high for the American people.

Letters and Comments Dec 15, 2021

Dear President Biden:

In furtherance of your efforts to unleash the full potential of the nation’s economy and address the impact of rising prices on the American people, and in recognition of your acknowledgement of the essential role that the ocean plays in our economy and livelihoods, the undersigned groups representing workers, communities, and businesses from across the economy and country urge your support for using science-based and transparent processes when considering actions to manage the ocean for current and future generations.

We have become increasingly concerned by calls for the administration to establish “fully and highly protected areas” in 30% of the U.S. ocean by 2030, including through marine monuments designated under the Antiquities Act. Concerns have been further heightened by recent decisions to restore a commercial fishing prohibition in the Northeast Canyons and Seamounts Marine National Monument and join the High Level Panel for a Sustainable Ocean Economy, which commits the United States to actions that could lead to further prohibitions.

Using the Antiquities Act to prohibit access to and economic activity in vast amounts of the U.S. ocean would needlessly harm jobs and economic activity and raise prices for Americans on everything from food and energy to beyond…

Letters and Comments Dec 2, 2021

IPAA is please to provide comments to the U.S. Fish and Wildlife Service’s Advanced Notice of Proposed Rulemaking to prepare a National Environmental Policy Act (NEPA) document with regards to governing the Migratory Bird Treaty Act (MBTA) , especially where it comes to the issue of incidental take. …

…While IPAA remains strongly opposed the rescission of the January 7 final rule, we hope to work with the Service as you develop a NEPA plan for the MBTA. It is not industry’s intent to circumvent our responsibilities of avoiding impacts to and protecting migratory birds and their nests. However, the January 7 final rule provided the necessary clarifying language to protect independent producers from criminal prosecution for unintended and incidental bird takes. 

Letters and Comments Dec 1, 2021

Dear Chairman Manchin,

…

The reconciliation text that passed the House of Representatives includes provisions of significant concern. These provisions would serve to place millions of dollars annually in new fees on energy companies that require financial flexibility to continue to produce domestic energy. Moreover, such impacts on domestic production threaten to result in greater reliance on foreign production from nations with weaker environmental standards as compared to production from U.S. federal waters and comparable regions onshore, thus contributing to carbon leakage and damaging U.S. competitiveness Measures such as these could serve to stifle U.S. production and result in further inflationary pressures on those U.S. citizens that can least afford it. These harmful provisions include but are not limited to:

  1. New per-barrel tax on domestic energy production (Sec. 70804(o))
  2. New per-acre lease fees on onshore and offshore leases (Sec. 70804(i) and (l))
  3. Royalties on extracted methane used or consumed (Sec. 70804(r))
  4. Creation of new annual pipeline fees of at least $10,000 per mile in deepwater and $1,000 per mile in shallower water (Sec. 70804(q))
  5. Increasing minimum offshore and onshore royalty rates (Sec. 70804(c))
  6. Ban on Eastern Gulf, Atlantic and Pacific leasing; (Sec. 70804(b))
  7. New and increased offshore inspection fees (Sec. 70804(m) and (n))
  8. Shortened onshore lease term lengths (Sec. 70804(h))
  9. New idled well fees (Sec. 70804(p))
  10. Repealing royalty relief authority (Sec. 70804(s))
  11. Unrestrained authority for the Secretary to withdraw lands without due process or any public input (Section 70709)
  12. Imprecisely drafted provisions to update bonding requirements and duplicative bonding provisions for idle wells (Section 71409)
  13. Multiple, duplicative per acre fees for onshore leases (71407, 71411-71414) …

Letters and Comments Nov 30, 2021

Dear Assistant Administrator Fox and Acting Assistant Secretary Pinkham:

The undersigned organizations respectfully request that you implement a virtual national roundtable to roll up regional roundtable comments and offer broader stakeholder engagement to respond to your recent request, set forth in your recent Notification of Regional Roundtable Discussions, regarding virtual regional roundtables designed to engage diverse stakeholders concerning the definition of “Waters of the United States.” We represent a diverse stakeholder community comprising agriculture, development, industrial, and state and local government organizations with a strong interest in seeing robust, transparent stakeholder engagement. Our organizations should be represented in any national slate of stakeholders and should be individually included, as is feasible using virtual platforms, in any virtual national roundtable discussion.

Objectives

A virtual national roundtable will meet the following key objectives:

  • Enabling more participation and more voices in the process to ensure the agencies receive the best ideas and account for additional, differing perspectives. The flexibility of the virtual environment enables simple inclusion of more participants.
  • Providing a ready-made event to receive direct feedback from regional slates that are not selected, thereby reducing possible criticism related to inclusivity.
  • Affording the agencies with a capstone opportunity to build transparency and report back to the broad stakeholder communities at one time on the regional differences, outcomes, experiences, and discussion points from the regional meetings.

Letters and Comments Nov 23, 2021

The Independent Petroleum Association of America (IPAA) appreciates the opportunity to comment on the U.S. Fish and Wildlife proposal to rescind the final rule titled “Endangered and Threatened Wildlife and Plants; Regulations for Designating Critical Habitat” that published on December 18, 2020, and became effective January 19, 2021 (“the Final Rule”). IPAA does not support the rescission and is supportive of the Service’s previous efforts to clarify language and return the Endangered Species Act (ESA) back to the original intent of the law. Unfortunately, the ESA has been used all too frequently as a tool for litigation and a vehicle to stall important development projects for years and even decades. IPAA supported the Service’s previous rule as it led to safeguard species conservation while also clarifying criteria for consistent critical habitat designation.

Letters and Comments Nov 22, 2021

Our organizations represent a diverse set of economic sectors that form the backbone of the American economy—agriculture, energy, construction, forestry, manufacturing, transportation, and other sectors. Through the passage of the Infrastructure Investment and Jobs Act, the United States has made the most significant investment in infrastructure since the New Deal. The Act will promote projects that will enable the movement of people, goods, information, and energy to support the American economy. To ensure that the Act succeeds, further efforts are needed. In order to realize this investment, the Administration should ensure an efficient and transparent NEPA review process.

We fully support the fundamental goals of NEPA to better inform agency decisions and the public’s understanding of the potential environmental impacts of federal actions. A federal permitting system that is focused and aligned with these goals is needed for timely investment to address the digital divide in rural and large urban areas, to facilitate construction of public transit to connect communities to job centers, and to build out the energy infrastructure that is essential to our economic recovery and to progress on the climate challenge, to name a few key priorities. Recognizing the importance of an effective and efficient federal permitting system—and with a show of broad bipartisan support—Congress codified the One Federal Decision policy in the Infrastructure Investment and Jobs Act, providing clarity to the regulated community concerning agency coordination of environmental reviews.2 CEQ now has a similar opportunity with this rulemaking. …

The 2020 Rule strengthened the role of NEPA in the federal decision-making process by building on decades of experience and case law to tailor implementation to the goals of the law and to foster a process that provides meaningful information to decision-makers and to the public. Indeed, the 2020 Rule made changes that codified existing case law and agency best practices or clarified requirements that had often been misinterpreted and had given rise to litigation. We urge CEQ to retain the 2020 Rule provisions, which will support increased infrastructure investment, expanded project development, and improved infrastructure permitting and leasing decisions in a manner that strengthens our economy and enhances environmental stewardship. Furthermore, retaining the current rule language will provide much needed stability in contrast to the uncertainty and expense caused by shifts between Administrations.

Letters and Comments Nov 9, 2021

Dear Chairman Manchin and Ranking Member Barrasso,

We are grateful for your collective leadership in recent months to bring balance to the policy debate on energy policy. As the backbone of the American oil and natural gas industry, our respective organizations are writing to express our grave concerns with virtually every one of the provisions included in the House Committee on Natural Resources title of the Build Back Better Act. We request that the Senate strike the House language from the bill and wait for the Biden Administration’s leasing moratorium report to be released before undertaking any revision to the current federal oil and gas onshore and offshore programs.

The House language is unworkable in many ways. It is bad policy and has generated a long list of concerns which we are happy to discuss in detail with you. In short, if implemented it will:

1. Drive all but a few large industry players off federal lands and waters as it renders federal leases completely uncompetitive compared to adjacent private or state lands

2. Decrease funding significantly for conservation of federal lands, which are financed exclusively by federal oil, natural gas, and coal

3. Reduce competition as well as innovation in both the onshore and offshore industry

4. Widen the income gap between urban and rural communities

5. Fail in its overly optimistic revenue projections, adding billions to the deficit.

…

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.