Comments
The EnerGeo Alliance provides input via comments and letters to governments around the world on various regulations, policies, guidance and issues impacting the energy geoscience industry.
Treaty Organizations and Conventions
Marine Exploration
24 February 2020
IAGC comments on the United Nations Draft Agreement relating to the Sustainable Use of Marine Biological Diversity of Areas Beyond National Jurisdiction
20 April 2018
IAGC comments on DMAC 12 – Safe Diving Distance from Seismic Surveying Operations
15 February 2017
2nd stakeholder consultation on the CMS Family Guidelines on Environmental Impact Assessments for Marine Noise-generating Activities
Areas Beyond National Jurisdiction
24 February 2020
ABNJ US State Dept Letter
Argentina
12 April 2022
Argentina: Minister Letter RE NGO Challenges
English
Spanish
19 November 2021
EIS Delays – Energy Ministry – English
EIS Delays – Energy Ministry – Spanish
EIS Delays – Environment Ministry – English
EIS Delays – Environment Ministry – Spanish
23 April 2019
Suggestions to the draft Resolution for marine seismic environmental Authorizations
23 April 2019
Suggestions and Comments to the Draft Resolution for Offshore Seismic
Brazil
10 October 2022
ANP Extends Data Confidentiality Terms – English
29 September 2022
Letter to ANP RE Data Confidentially
10 March 2022
ANP Data Regulations – English
ANP Data Regulations – Portuguese
23 July 2021
Letter to MME Brazil – Confidentiality Terms (Portuguese)
18 March 2021
3 February 2021
Announcement of the date of the 17th Round of Bidding and Blocks of Pará-Maranhão
30 April 2020
IAGC comments on Oil and Gas Reference Matrix – Seismic
- IAGC Comments – Portuguese
- IAGC Comments – Google Translation
- Attachment Letter to National Parks and Wildlife Service (NPWS) – Review of Study Addressing Potential Effects of Seismic Surveys on Zooplankton
15 July 2018
IAGC comments on Guide to Monitoring Marine Biota in Maritime Seismic Surveys
Canada
23 August 2021
Comment Letter CNLOPB Draft Data Policy
15 September 2017
IAGC comments on Canada’s Draft Discussion Paper on Environmental and Regulatory Reviews
Mexico
Agreement issuing the criteria for determining the method of recognition and surface exploration to be subject to the regulations on surface occupation
Joint Trades IQA Correction Request Letter to National Oceanic and Atmospheric Administration
Letter to CNH Requesting Extension of Commercialization Period
Second letter to Mexico Secretary of Energy, regarding the requirements that have been made effective with the interpretation given by this Secretary to the Articles 100 – 117 of the Hydrocarbons Law
Letter to Mexico Secretary of Energy, regarding the requirements that have been made effective with the interpretation given by this Secretary to the Articles 100 – 117 of the Hydrocarbons Law.
United States
6 February 2023
Comment Letter on Proposed NFMS ITR Revisions
Supplemental Appendices:
Appendix A
Appendix B
Appendix C
30 November 2022
EnerGeo Alliance North American Right Whale Comment Letter
6 October 2022
EnerGeo Alliance 5 Year Plan OCS Comment Letter
18 August 2022
Alaska Willow Project Letter
9 August 2022
Coalition ESA 10j Rule Letter
28 June 2022
US Wind Offshore Comment – Oregon
US Wind Offshore Comment – Atlantic
23 June 2022
Open letter to President Biden & Cabinet to See American Energy
13 June 2022
Amicus Brief w/ NOIA
5 June 2022
US Trades Letter: Biden 5-year Lease Plan
5 April 2022
Letter to Dr. Rick Spinrad on LOA Issues
18 March 2022
US: House Trades Letter Coast Guard Crewing Bill
1 December 2021
Sen Manchin Ltr – Reconciliation Bill
26 November 2021
WRLC Coalition Letter – 2021 Crit Habitat Rescind
WRLC Coalition Letter – 2021 Habitat Def Rescind
22 November 2021
U.S. CEQ Phase 1 NEPA Regs Comment Letter
16 August 2021
DOI Leasing Moratorium–API Coalition Complaint
26 July 2021
BOEM GOM Wind Leasing
8 April 2021
Joint letter with AOGA, API, and IAGC on Critical Habitat Designations
8 October 2020
U.S. ESA 4d Comment Letter
16 September 2020
Jones Act Letter
4 September 2020
ESA Habitat comment letter
4 September 2020
Policy letter sent to BOEM on the US GOM Biological Opinion
31 August 2020
Amicus Brief filed with the US Supreme Court on Presidential Abuse of the Antiquities Act
31 July 2020
IAGC letter with AOGA on request for Information by the IARCP for input on the Arctic Research Plan
8 May 2020
IAGC Letter to BOEM RE BiOp & GG Permits
10 March 2020
IAGC comment letter with API and APOL on the Council of Environmental Quality’s NPRM
24 February 2020
US NOAA IQA Letter
17 January 2020
IAGC comment letter on the Bureau of Land Management’s (BLM) proposed renewal of an ICR
8 January 2020
Consent Motion for Approval of the Fourth Stipulated Amendment of Settlement Agreement
Order granting the Consent Motion, that the Fourth Stipulation is approved and adopted
24 December 2019
IAGC comments on BOEM’s proposed ICR with API
25 April 2019
IAGC comments on Procedural Changes to Coastal Zone Management Act Federal Consistency Process
14 December 2018
IAGC comments on Wyoming BLM/SHPO Protocol Appendices C and L
8 November 2018
IAGC comments on User Manual and associated optional User Spreadsheet Tool for the NOAA 2018 Revised Technical Guidance
15 October 2018
IAGC letter to RDML Timothy Gallaudet, re: Marine Mammal Incidental Take Authorization Concerns
27 August 2018
IAGC comments on Science and Technology for America’s Oceans: A Decadal Vision
21 August 2018
IAGC comments on proposed Marine Mammal Incidental Take Regulations for Geophysical Surveys in the Gulf of Mexico
9 March 2018
IAGC comments on the 2019–2024 Draft Proposed National Oil and Gas Leasing Program
and Notice of Intent to Prepare a Programmatic Environmental Impact Statement
22 January 2018
IAGC comments on the U.S. Fish and Wildlife Service’s Candidate Conservation Agreements with Assurances (CCAAs) Policy
22 January 2018
IAGC comments on the U.S. Fish and Wildlife Service’s Candidate Conservation Agreements with Assurances (CCAAs) Regulations
5 January 2018
IAGC comments on the U.S. Fish and Wildlife Service Endangered Species Act Compensatory Mitigation Policy
Letter to NMFS and BOEM addressing public comments in response to NMFS issuance of proposed IHAs for seismic surveys in the Atlantic OCS
Letter to BOEM and NMFS on a recent study addressing potential effects of seismic surveys on Zooplankton
Letter to the U.S. House Committee on Natural Resources in support of the Strengthening the Economy with Critical Untapped Resources to Expand American Energy Act (SECURE Act)
Letter to NMFS requesting “Applicant Status” regarding the Endangered Species Act (“ESA”) Section 7 Consultation for Incidental Take Regulations Governing Geophysical Surveys in the Gulf of Mexico
Letter to BOEM and NOAA Fisheries on the Modeling Analysis for the Final PEIS Geological & Geophysical Activities on GOM Outer Continental Shelf
Letter to Secretary Zinke on the Final PEIS for Geological & Geophysical Activities on GOM Outer Continental Shelf
21 August 2017
IAGC Encouraging NMFS to Streamline Regulatory Processes and Reduce Regulatory Burden
17 August 2017
IAGC comments on the preparation of the 2019-2024 Outer Continental Shelf (OCS) Oil and Gas Leasing Program
Letter to BOEM in support of a more open 2019-2024 Five-Year Offshore Leasing Program
26 July 2017
IAGC comments on NOAA’s designations and expansion of National Marine Sanctuaries and Marine National Monuments
Letter to Secretary Zinke in support of the New OCS 5-Year Leasing Program
21 July 2017
IAGC comments on Wyoming BLM/SHPO Protocol Appendices
17 July 2017
IAGC comments on NOAA-NMFS 2016 Level A Acoustic Guidance
23 June 2017
IAGC comments on Section 232 National Security Investigation of Imports of Aluminum
31 May 2017
IAGC comments on Section 232 National Security Investigation of Imports of Steel
18 April 2017
IAGC comments on US Customs and Border Protection Jones Act Modification
6 February 2017
IAGC comments on NMFS Petition to List Byrde’s Whale as Endangered
2 February 2017
Applications for MMPA Incidental Harassment Authorizations for Geophysical Surveys in the Atlantic Ocean
23 January 2017
IAGC comments on Revised Application for Marine Mammal Incidental Take Regulations for Geophysical Surveys in the Gulf of Mexico
Letters to Secretary Jewell and Pritzker Regarding Seismic
Testimonies
IAGC President Nikki Martin’s Congressional Testimony July 2017
18 January 2018
Ryan Steen’s Written Testimony on The Marine Mammal Protection Act “Deficiencies in the Permitting Process for Offshore Seismic Research”
18 July 2017
IAGC President Nikki Martin’s Testimony on “Examining Impacts of Federal Natural Resources Laws Gone Astray, Part II”
Norway
27 January 2023
Norway Consultation – Marine Minerals Impact Assessment
United Kingdom
1 March 2023
Carbon Storage Data Disclosure Consultation
28 October 2022
Republic of Ireland Energy Security Consultation Letter
28 September 2022
HPMA Consultation Response
28 June 2022
UK Legislation – Profits Levy (Tax) Letter
27 May 2022
Offshore Strategic EA 4 – Letter
27 May 2022
Letter to House RE Marine Mammals
28 February 2022
BEIS Climate Compatibility Consultation Response
29 November 2021
UK Marine Strategy III Comment Letter
14 June 2021
UK Dolphin and Porpoise Conservation Strategy – Consultation Response
11 June 2021
OGA response letter to the Supplemental Guidance on the Disclosure of Certain Geophysical Survey Data
7 May 2021
UK SEA Consultation Letter
30 April 2021
OGA Response Letter to on Urging Supplemental Guidance
30 March 2021
Letter to OGA Urging Supplemental Guidance
17 November 2020
Consultation on the UK Marine Strategy Part 2
30 October 2020
JNCC MMO Survey Response
8 October 2020
OGA Data Consultation Letter
23 July 2020
Letter to OGA on the proposal to revise UK Maximizing Economic Recovery Strategy
27 February 2020
Letter to Offshore Petroleum Regulator for Environment & Decommissioning on SNCB underwater noise guidance for harbour porpoise SACs
7 February 2020
NDR User Agreement
20 September 2019
Letter to the OGA concerning the Consultation on the Regulatory Disclosure of Geophysical Data
14 December 2018
IAGC & OGA Discussions and Consultation on Exploration License Geophysical Data Release – Meeting Request
25 August 2017
IAGC comments on UK OGA Consultation for the Proposed Regulations for the Retention and Disclosure of Information and Samples
9 January 2017
IAGC Comments on the JNCC Guidelines for Minimizing the Risk of Injury & Disturbance to Marine Mammals from Seismic Surveys
Ireland
28 October 2022
Ireland Energy Security Consultation Response
9 April 2021
Letter to Prime Minister Regarding Exploration Ban
24 February 2021
Letter to Minister for the Environment Eamon Ryan on the Exploration Ban
25 August 2020
Letter to Department of Taoiseach regarding the Exploration Ban
Africa
25 January 2022
SAGE – South Africa
11 March 2022
Letter to President of South Africa Cyril Ramaphosa Regarding Seismic Surveys in South African Waters
25 January 2022
EnerGeo Alliance & African Energy Chamber Response to SAGE Advisory on Seismic Surveys
Middle East
1 May 2019
IAGC received the opportunity to provide comments as part of the public consultation on the Draft Strategic Environmental Assessment for the Exploration and Production Activities Offshore Lebanon.
Australia
12 March 2023
NOPSEMA Environment Plan Consultation Guidance
14 June 2022
EnerGeo Alliance welcomes Shadow Minister for Resource and Northern Australia
Response from Senator Susan McDonald
EnerGeo Alliance welcomes Minister for Resource and Northern Australia
Response from The Honorable Madeleine King MP
30 August 2021
Letter in response to Blue Whale Guidance on Terms
26 March 2021
Letter to Australian Authorities on Stagnation of Exploration
20 September 2020
Letter to Alan Smart regarding Australia Data Regulations Review
4 September 2020
Letters sent to Australian officials regarding fisheries outreach
Comment submission on the Australia Government Productivity Commission Draft Report into Resources Sector Regulation
16 December 2019
IAGC Submission to the “Impact of seismic testing on fisheries and the marine environment” Australian Senate Inquiry
Letter to Minister Canavan, Australia, regarding the potential threat to our industry should a draft ruling be issued by the Australian Taxation Office (ATO) that proposes to change the tax treatment of costs incurred by geophysical companies when producing multi-client seismic data.
21 June 2018
IAGC comments on Offshore Exploration Policy Reforms – Proposed Acreage Release Optimisation
9 February 2018
IAGC comments on the Australian Taxation Office (ATO) Draft Taxation Ruling TR 2017/D11 Income tax: capital allowances: expenditure incurred by a service provider in collecting and processing multi-client seismic data
22 September 2017
IAGC comments on Australia Tax Office (ATO) Proposed Draft Determination on Multi-Client Seismic Data
New Zealand
Letter to the New Zealand Ministry of Business, Innovation & Employment on the Review of the Crown Minerals Act 1991
Letter to the New Zealand Department of Conservation (DOC), regarding DOC) and Fisheries New Zealand Consultation on the Hector’s and Māui Dolphin Threat Management Plan (TMP) Review
IAGC Submission to the New Zealand Parliament – Committee Secretariat on the Crown Minerals (Petroleum) Amendment Bill
Letter to Minister Ardern, New Zealand, regarding New Zealand Government’s announcement that it will end oil and gas exploration.
Letter to Minister of Conservation, New Zealand, regarding recent media comments by the New Zealand Government about seismic surveys