Page 22 - IAGC The Voice 2017

The IAGC and 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
could dilute the strength and legal defensibility of the analysis and divert
NATIONAL SECURITY it from its core assessments related to national defense. The Associations
INVESTIGATION OF IMPORTS cautioned the Department not to equate U.S. imports of steel, whether
for the oil and natural gas industry or other uses in the U.S. economy, as
OF ALUMINUM AND IMPORTS inherently negative.

OF STEEL
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. Additionally, they request 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 Bureau of Land Management's
(BLM) State Historic Preservation Office (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
WYOMING BLM/SHPO recognition of survey activities as having "limited
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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