Page 22 - The Voice 2017

The IAGC and other six other trade associations representing the
breadth of the oil and gas industry in the U.S., across exploration and
production ("upstream"), transportation ("midstream") and
manufacturing/refining ("downstream") urged the Department of
Commerce to define "national security" narrowly as it assesses whether
U.S. imports of aluminum impair national security, per Section 232 of
the Trade Expansion Act of 1962.

In separate comments on the imports of steel, the trades cautioned the
Department to strictly limit reliance on any "relevant" factor, which
NATIONAL SECURITY could dilute the strength and legal defensibility of the analysis and divert
INVESTIGATION OF IMPORTS it from its core assessments related to national defense. The Associations
cautioned the Department not to equate U.S. imports of steel, whether
OF ALUMINUM AND IMPORTS for the oil and natural gas industry or other uses in the U.S. economy, as

OF STEEL inherently negative.
The comments also requested that any recommendations be targeted to
address specific actions by specific foreign governments with respect to
specific aluminum and steel products that are not already addressed by
existing U.S. trade remedies and that consideration be given to the
potential negative effects of U.S. tariffs, quotas or other measures that
would raise the cost of aluminum and steel inputs for the oil and natural
gas industry, which may impact affordable energy for consumers,
including the U.S. government and U.S. military.

The IAGC, API and OOC opposed NMFS' finding
that the Gulf of Mexico (GOM) Bryde's whale is a
NMFS PETITION TO taxonomical subspecies of the Bryde's whale and
LIST BRYDE'S WHALE meets the definition of an endangered species under
the Endangered Species Act (ESA). The Trades
AS ENDANGERED asserted that the scientific evidence does not support
designating Bryde's whales in the GOM as a separate
subspecies of the Bryde's whale. The best available
evidence demonstrates that listing is not warranted.

In July 2017, the IAGC submitted comments
requesting exemption from certain requirements
of the Wyoming BLM/SHPO Protocol
Appendices. The basis of the exemption request
focuses on the unique characteristics of
geophysical operations which cover vast areas
but directly affect very few acres and the BLM
recognition of survey activities as having "limited
WYOMING BLM/SHPO impact" and being "transient" in nature.
PROTOCOL APPENDICES Unlike construction activities such as pipelines,
powerlines, well pads, and wind farms,
geophysical operations can be modified to
relocate the source of their minimal disturbance
away from other important resources and should
therefore not be subjected to procedures
administered by the BLM/SHPO Protocol.
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