Rules Coordinator

Railroad Commission of Texas

Submitted via email

RE: Proposed amendments to 16 TAC §3.70 and various rules in Chapter 8

The Permian Basin Petroleum Association “PBPA” greatly appreciates the opportunity to provide feedback on these proposed rules as thanks the Commissioners and staff for their work throughout this important process. As you know, our membership includes the smallest exploration, service and support companies as well as some of the largest oil and natural gas companies with worldwide operations. We firmly believe that Texas, the United States, and our allies benefit from a vibrant and diverse oil and gas sector and are committed to continuing the development of these resources for generations to come.

With regard to the proposed amendments within Chapter 3, PBPA has solicited and received the following member feedback for the Commission to consider. Broadly, our membership generally supports the rule which incorporates recent federal rulemakings by the Pipeline and Hazardous Materials Safety Administration...

Rules Coordinator

Railroad Commission of Texas

Submitted via email

RE: Proposed Amendments to 16 TAC §3.8 and various other rules in Chapter 3 and proposed new rules and amendments in 16 TAC Chapter 4

The Permian Basin Petroleum Association (“PBPA”) greatly appreciates the opportunity to provide feedback on these proposed rules and thanks the Commissioners and staff for their work throughout this important process. As you know, our membership includes the smallest exploration, service and support companies as well as some of the largest oil and natural gas companies with world-wide operations. We firmly believe that Texas, the United States, and our allies benefit from a vibrant and diverse oil and gas sector. To maintain these benefits, we are committed to continuing the development of these resources for generations to come.

Regarding this proposed rule our members recognize the importance of modernizing certain provisions of Chapter 3, Rule 8 (“Rule 8”) as well as complying with legislative mandates in order to establish efficient,...

Secretary James C. Kenney

New Mexico Environment Department

1190 St. Frances Drive, Suite N4050

Santa Fe, New Mexico 87505

RE: EIB 24-12 (R) - AQB Permit and Construction Fees

Secretary Kenney,

Thank you for allowing our members the opportunity to comment publicly on the proposed revisions by the Air Quality Bureau within the Environmental Protection Division of the New Mexico Environment Department, pursuant to 20.1.1 NMAC – Rulemaking Procedures, petitions the EIB in the matter of the proposed repeal and replacement of 20.2.71 NMAC – Operating Permit Emissions Fees and 20.2.75 NMAC – Construction Permit Fees.

As you know the Permian Basin Petroleum Association (PBPA) is the largest regional trade organization in the United States and we represent oil and gas operators in the Permian Basin as well as the communities they call home. We advocate on behalf of these operators, large and small, to ensure the safe and responsible development of natural resources can thrive in the Permian Basin. While we appreciate the opportunity to better...

Chairman Thomas J. Gleeson

Public Utility Commission of Texas

1701 North Congress Avenue, 7th Floor

Austin, Texas 78711

RE: Project Number 55718, Reliability plan for the Periman Basin under PURA §39.167

Thank you for the opportunity to express our support for the Permian Basin Reliability Plan, established in House Bill 5066 by Representative Charlie Geren and Senator Charles Schwertner. This plan seeks to address extending transmission service to areas where mineral resources are located, increasing available capacity to meet forecasted load, and provide infrastructure to reduce interconnection time in areas without access to transmission service.

The undersigned represent the industry that generates great economic opportunity for Texans—the Texas oil and natural gas industry which paid $26.3 billion in state and local taxes and state royalties in fiscal year (FY) 2023 – the highest in Texas history. The Permian Basin produces approximately 50% of all crude oil and 23% of natural gas in the United States. To continue to produce these...

Dear Administrator Regan:

The Permian Basin Petroleum Association (“PBPA”) is the largest regional oil and gas association in the United States. We represent the men and women who work in the oil and gas industry in the Permian Basin of West Texas and southeastern New Mexico. The Permian Basin is the largest inland oil and gas reservoir and the largest oil and gas producing region in the world. PBPA consists of the largest producers as well as the smallest operators in the Permian Basin. Part of PBPA’s mission is to promote environmentally conscious operations and sustainable economic profitability among all our members, large and small. Because PBPA’s members will be directly impacted by this Proposed Rule, if finalized, we are submitting these comments to convey our concerns and needed revisions.

INTRODUCTION

PBPA membership understands there are Congressional requirements placed on the Environmental Protection Agency (“EPA”) to draft a rule implementing the Inflation Reduction Act (“IRA”) as to, what EPA is now calling, the WEC. However, such an...

The Honorable Jennifer Granholm

Secretary U.S. Department of Energy

Washington, DC 20585

Dear Secretary Granholm,

As trade and member associations representing the United States liquefied natural gas (LNG) value chain, we are deeply concerned the Biden administration is considering burdensome changes to the Department of Energy’s (DOE) permitting process for U.S. LNG exports. Any action to halt U.S. LNG export approvals would be a major mistake that puts American jobs and allies at risk while undermining global climate goals.

The United States is the world leader in natural gas production, meeting record domestic demand and becoming the top exporter of LNG in 2023. 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.

U.S. LNG blunted a potentially disastrous situation in 2022 following Russia’s invasion of Ukraine, and Secretary Blinken...

Re: Comments on EPA’s Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems at 88 Fed. Reg. 50282 (August 1, 2023) (the “Proposed Rule” or “GHGRP”)

Docket ID No. EPA–HQ–OAR–2023–0234; FRL–10246–01–OAR

Submitted via e-filing

Dear Administrator Regan:

The Permian Basin Petroleum Association (“PBPA”) is the largest regional oil and gas association in the United States. We represent the men and women who work in the oil and gas industry in the Permian Basin of West Texas and southeastern New Mexico. The Permian Basin is the largest inland oil and gas reservoir and the largest oil and gas producing region in the world. PBPA consists of the largest producers as well as the smallest operators in the Permian Basin. Part of PBPA’s mission is to promote environmentally conscious operations and sustainable economic profitability among all our members, large and small. Because PBPA’s members will be directly impacted by these proposed revisions, if finalized, we are submitting these comments to convey needed...

Re: FWS–R2–ES–2022–0162

Endangered and Threatened Wildlife and Plants; Endangered Species Status for the Dunes Sagebrush Lizard, 88 Fed. Reg. 42,661 (July 3, 2023)

Dear Director Williams,

The Permian Basin Petroleum Association (“PBPA”), the New Mexico Oil and Gas Association (“NMOGA”) and our collective member companies (referred to herein as the “Associations”) provide the following response to the July 3, 2023 proposed rule and request for comment from the U.S. Fish and Wildlife Service (USFWS or Service) to list the dunes sagebrush lizard (DSL) as endangered under the Endangered Species Act of 1973, as amended (ESA). 88 Fed. Reg. 42,661 (July 3, 2023) (“Proposed Rule”).

The PBPA is the largest regional oil and gas association in the United States. Since 1961, the PBPA has been the voice of the Permian Basin oil and gas industry. The PBPA’s mission is to promote the safe and responsible development of our oil and gas resources while providing legislative, regulatory, and educational support services for the petroleum industry. The PBPA membership...

Re: Comments on BLM’s Proposed Rulemaking on Conservation and Landscape Health, 88 Fed. Reg.

19583 (April 3, 2023); RIN 1004‐AE92

Dear Director Stone‐Manning:

BLM’s proposed rulemaking on Conservation and Landscape Health (Proposed Rule) codifying conservation as a multiple use under the Federal Land and Policy Management Act (FLPMA) unlawfully expands the original intent of FLPMA and revises the priorities and focus of land use management. While FLPMA calls for protection of the environment, water, and cultural resources, it does not identify conservation as a use. Certainly, conservation is a goal and land use action that we as an industry fully support. Our members are committed to environmentally responsible operations, but we are concerned that the Proposed Rule impermissibly exceeds BLM’s directive to manage multiple uses of public lands. The authority to add conservation as a use under FLPMA is reserved for Congress, thereby rendering BLM unable to fully implement the Proposed Rule unless and until such time as FLPMA is amended by Congress. As such, BLM...

Gentlemen and Ladies:

The Permian Basin Petroleum Association (“PBPA”), the Western Energy Alliance, The Petroleum Alliance of Oklahoma, the Petroleum Association of Wyoming, and our collective member companies (together as “we” or the “represented organizations”) provide the following comments to the February 9, 2023 proposed revisions (the “Revisions”) and request for comment from the U.S. Fish and Wildlife Service (“FWS” or “Service”) to regulations concerning the issuance of Enhancement of Survival and Incidental Take Permits under the Endangered Species Act of 1973, as amended (“ESA” or the “Act”)1...

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