Federal Issues


To: The US Department of the Interior

From: Jason Modglin, President, Texas Alliance of Energy Producers

Re: Oil and Gas Production on Federal Lands and Waters


Comments submitted to: energyreview@ios.doi.gov.

Click here to view comments presented to the Dept of Interior on April 15, 2021


The Texas Alliance of Energy Producers (the Alliance) and our members appreciate the opportunity to provide comment on the management of oil and gas leasing and production on federal lands and waters. The Alliance represents approximately 2,600 member companies and individuals, primarily in the upstream (exploration and production) segment of the oil and gas industry. While there is relatively little in the way of federal oil and gas production in Texas, we remain concerned about a potential permanent moratorium on future federal oil and gas leasing.
First, even though Texas oil and gas production accounts for very little of total US production from federal lands and waters, the state stands to suffer significant damage by such a moratorium in terms of employment loss and state revenue. This is because a number of the companies who engage in production on federal lands are headquartered in Texas, have a substantial employment presence in Texas, and/or produce on federal lands in neighboring states. Further, Texas supplies a significant portion of labor and other resources for federal offshore production in the Gulf of Mexico.

(click link above to see complete comments by the Texas Alliance of Energy Producers)

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The Alliance is proud to support the culmination of work on HB 2771 from the 86th Texas Legislature seeking delegated authority to the TCEQ of the National Pollutant Discharge Elimination System (NPDES) Program Authorization for Oil and Gas Discharges.

Click here to download Alliance NPDES comments.

A link to the full docket can be found here: https://www.regulations.gov/document?D=EPA-R06-OW-2020-0608-0001

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Docket PHMSA-2019-0131; Pipeline Safety: Farm Taps Frequently Asked Questions

The following comments are submitted by the Independent Petroleum Association of America (“IPAA”), with the input and support of the Independent Oil and Gas Association of West Virginia (“IOGAWV”), the Kansas Independent Oil & Gas Association (“KIOGA”), Kentucky Oil & Gas Association (“KOGA”), Michigan Oil and Gas Association (“MOGA”), The Ohio Oil & Gas Association (“OOGA”), the Pennsylvania Independent Oil & Gas Association (“PIOGA”), and the Texas Alliance of Energy Producers (“Texas Alliance”), in response to the April 20, 2020, Federal Register notice, Pipeline Safety: Farm Taps Frequently Asked Questions (“FAQs”).

Click here to view comments