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.
Asia Pacific
Global Regulations
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
- IAGC Technical Comments Table for CMS Guidelines and Technical Support Document
- 19 October 2017 Letter to the United Kingdom on CMS Family Guidelines
Areas Beyond National Jurisdiction
24 February 2020
ABNJ US State Dept Letter
Americas
Argentina
12 April 2022
Argentina: Minister Letter RE NGO Challenges
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 and Comments to the Draft Resolution for Offshore Seismic
Uruguay
7 November 2024
Uruguay – Geoscience & Comm Fishery Interactions
15 July 2024
Uruguay – ANCAP Letter RE Fisheries | Spanish
Brazil
29 July 2024
MME Letter RE Environmental Permitting
27 June 2024
Brazil – Letter RE ANP Budget
26 June 2024
Brazil – MME/ANP Letter RE Suspension of Cycles
19 December 2023
Brazil: Letter to ANP RE Permanent Offer Rounds
16 May 2023
Letter to President of IBAMA on Foz do Amazonas – English | POR
21 March 2023
Letter to Brazil ANP/SEP on Multi Client Data | POR
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
ANP Data Extension Letter | POR
3 February 2021
ICMBio Letter | POR
13 October 2020
Announcement of the date of the 17th Round of Bidding and Blocks of Pará-Maranhão | POR
30 April 2020
IAGC comments on Oil and Gas Reference Matrix – Seismic
- 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
26 March 2020
Agreement issuing the criteria for determining the method of recognition and surface exploration to be subject to the regulations on surface occupation | SPA
20 February 2020
Joint Trades IQA Correction Request Letter to National Oceanic and Atmospheric Administration
17 October 2019
Letter to CNH Requesting Extension of Commercialization Period
15 October 2018
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
26 June 2018
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
5 May 2025
US – House Committee on Natural Resources Reconciliation Provisions
3 March 2025
US – Trades Letter RE USCG Matter
26 February 2025
House Letter, HNR WWF Sub Cmte – MMPA/ESA Hearing
30 January 2025
US – GOM BiOp Applicant Status Letter (3rd Request)
27 January 2025
US – Trades Letter Lease Sale DPEIS Comment Letter
30 October 2024
U.S. – Trades FWS BiOp Applicant Status Letter
17 June 2024
2024 NMFS Acoustic Guidance Trades Letter
17 May 2024
U.S. GOM BIOP Applicant Status Letter – Follow Up Letter
4 April 2024
US GOM BIOP Applicant Status Letter
20 March 2024
U.S. House – Sub. Cmte. Hearing Energy – Dryer Testimony
1 November 2023
Industry Comments on 2024-2029 GOM Multi Sale PEIS NOI
1 November 2023
Industry Comments on 2024-2029 GOM Multi Sale Call for Information
25 October 2023
EnerGeo Testimony – Grave Rice’s Whale Bill
October 2023
Synopsis of GOM RW Call Differences
29 September 2023
NEPA Phase II Comment Letter
6 October 2023
Rice’s Whale Critical Habitat Comment Letter
Economic Analysis of GOM Vessel Transit Restrictions
4 August 2023
NOPC Letter Requesting Extension for Comments
1 August 2023
5-year Lease Plan Comment Letter with Joint Trades
6 July 2023
NOPC Rice’s Whale Petition Comment Letter
27 June 2023
Letter supporting Louisiana State Primacy to Regulate CCS
17 May 2023
Letter to Governor of New Jersey on Offshore Wind Surveys
1 May 2023
BOEM Proposed Modification of “Renewables” Rule
24 April 2023
US – Congressional, Crewing & Manning Provision
7 April 2023
Trade Organizations Applaud U.S. House for Passage of HR1
29 March 2023
Letter of Support for Lower Energy Costs Act – HR1
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
16 July 2020
IAGC letter with industry trades NOIA, IADC, LMOGA, IPAA, API, Consumer Energy Alliance, LOGA, and Global Energy Institute to Chairman McGovern and Ranking Member Cole in opposition to Amendment 151
8 May 2020
IAGC Letter to BOEM RE BiOp & GG Permits
25 March 2020
IAGC letter with industry trades API, IADC and PESA to the U.S. Department of State on the current Global Level 4 Health Advisory and the ramifications for global oil and natural gas operations
10 March 2020
IAGC comment letter with API and APOL on the Council of Environmental Quality’s NPRM
- NOPC comment letter on the Update to the Regulations Implementing the Procedural Provisions of the National Environmental Policy Act
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
1 May 2019
IAGC comments on the proposed rule for the incidental take of marine mammals during oil and gas activities in the Cook Inlet in Alaska
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
30 October 2018
Letter to Timothy Gallaudet, Ph.D., USN Ret., Assistant Secretary of Commerce for Oceans and Atmosphere, to provide additional context following a meeting on 9 October about the Endangered Species Act (ESA) Section 7 consultation regarding the issuance of Marine Mammal Protection Act incidental take regulations applicable to exploration activities in the Gulf of Mexico (ITR).
15 October 2018
IAGC letter to RDML Timothy Gallaudet, re: Marine Mammal Incidental Take Authorization Concerns
15 October 2018
Letter to Timothy Gallaudet, Ph.D., USN Ret., Assistant Secretary of Commerce for Oceans and Atmosphere, to provide additional context following a meeting on 9 October about the long-pending incidental harassment authorization (IHA) applications for seismic surveys on the Atlantic Outer Continental Shelf (OCS).
14 September 2018
IAGC comments on the Bureau of Land Management’s (BLM) proposed renewal of an information collection request (ICR) for geological and geophysical (G&G) explorations on federal lands
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
20 June 2018
IAGC comments on the Bureau of Ocean Energy Management’s (BOEM) proposed renewal of an information collection request (ICR) for geological and geophysical (G&G) explorations of the Outer Continental Shelf.
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
- Trade Association Joint Comments
- IAGC Comments
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
4 January 2018
Letter to NMFS and BOEM addressing public comments in response to NMFS issuance of proposed IHAs for seismic surveys in the Atlantic OCS
17 November 2017
Letter to BOEM and NMFS on a recent study addressing potential effects of seismic surveys on Zooplankton
6 November 2017
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)
30 October 2017
IAGC comments on the Bureau of Ocean Energy Management’s (BOEM) proposed renewal of an information collection request (ICR) for geological & geophysical (G&G) explorations of the Outer Continental Shelf (OCS)
2 October 2017
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
- NMFS response letter
25 August 2017
Letter to BOEM and NOAA Fisheries on the Modeling Analysis for the Final PEIS Geological & Geophysical Activities on GOM Outer Continental Shelf
- Modeling Report
25 August 2017
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
17 August 2017
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
26 July 2017
Letter to Secretary Zinke in support of the New OCS 5-Year Leasing Program
21 July 2017
IAGC comments on Proposed Incidental Harassment Authorizations for the Incidental Taking of Marine Mammals During Geophysical Surveys in the Atlantic Ocean
21 July 2017
IAGC comments on Maryland and Delaware’s request to conduct reviews authorized under the CZMA of proposed IHAs to be issued under the MMPA
- NOAA Response to DE
- NOAA Response to MD
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
16 December 2016
Letter to Secretary Pritzker Regarding Seismic
12 December 2016
Letter to Secretary Jewell Regarding Seismic
Testimonies
23 July 2024
U.S. House Testimony – Van Liew – CORE Act
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”
IAGC President Nikki Martin’s Congressional Testimony July 2017
EAME
Africa
27 September 2024
DMRE onshore seismic support letter
22 March 2024
S. Africa – Letter to DMRE RE Geoscience Regulations
December 2023
South Africa Fact Sheet
8 May 2023
South Africa Marine Spatial Planning Consultation
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
Denmark
16 Dec 2019
Letter to the Danish Energy Agency regarding the delay in exploration and production licenses under the 8th licensing round.
European Union
14 June 2024
SA Gas Master Plan comments
12 June 2024
Norway – wages and working conditions
1 May 2024
NOD – letter re: SEG-Y rev2.1 reporting requirements
29 September 2023
France CCUS Consultation
31 August 2023
EU Industrial Carbon Management Call for Evidence
31 March 2023
EU CCS Guidance Consultation
Greece
17 June 2019
Letter to the Prime Minister of the Hellenic Republic on the World Wide Fund for Nature declaration
Ireland
13 January 2023
Ireland: IOSEA6 Consultation Response
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
17 Dec 2019
Letter to Department of Communications, Climate Action and Environment regarding the potential for Ireland to ban oil and gas exploration due to the ‘Climate Emergency Measures Bill’.
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.
- Cover Letter
- IAGC Comments
Netherlands
22 March 2024
Dutch – Letter to EBN RE MC Data
Norway
27 January 2023
Norway Consultation – Marine Minerals Impact Assessment
United Kingdom
16 August 2024
EA/OEUK OPRED Letter RE SNBC Noise Guidance
8 August 2024
Letter to Sec. of State for Energy Security and Net Zero
8 August 2023
U.K. CCS Application Guidance Comment Letter
9 May 2023
Scottish Daft Energy Strategy Consultation
17 April 2023
Scotland Highly Protected Marine Areas
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
30 March 2020
Letter to UK Secretary of State for Business, Energy and Industrial Strategy highlighting the G&E industry concerns related to COVID-19
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
11 July 2019
Letter to the Department for Environment, Food and Rural Affairs on the UK Stakeholder Forum on Underwater Noise Disturbance within UK SACs for harbour porpoise
27 April 2019
IAGC comments on the United Kingdom, Oil and Gas Authority (OGA) proposed [supplemental] guidance on the disclosure of certain geophysical survey data (created or acquired under an exploration licence pre-2018).
27 April 2019
IAGC comments on the United Kingdom, Oil and Gas Authority (OGA) proposed [supplemental] guidance on the disclosure of certain geophysical survey data (created or acquired under an exploration licence post-2017).
14 December 2018
IAGC & OGA Discussions and Consultation on Exploration License Geophysical Data Release – Meeting Request
19 October 2017
Letter to the United Kingdom’s Head of International Species Conservation Team on CMS Family Guidelines on Environmental Impact Assessments for Marine Noise-generating Activities
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
Asia Pacific
Australia
30 April 2025
AUS – DISR – Future Gas Strat Consultation Guidelines
10 April 2025
AUS- NOPSEMA – Consultation Response
12 November 2024
AUS – SE Marine Parks Mgmt Plan Response
8 July 2024
AUS – Response to Australia’s Future Gas Strategy
18 June 2024
NZ Letter to Ministers: Legislation Re-Opening NZ for Exploration
2 May 2024
AP: Indonesia MC Data Regulations
30 March 2024
Australia – Wind Offshore Letter
12 November 2023
AUS Future Gas Strategy — Consultation Letter
11 September 2023
Australia Wind Energy Infrastructure Area Proposal
10 June 2023
DISER Data Regulations Consultation
20 April 2023
Letter of Support for Australia Wind Centre
24 March 2023
Australia Hunter Region Offshore Wind
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
- Minister Keith Pitt
- MP Tim Bull
- MP Peter Walsh
- MP Darren Chester
4 June 2020
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
25 May 2018
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
2 August 2024
Letter to the New Zealand Minister for Energy – CCS Consultations
22 January 2020
Letter to the New Zealand Ministry of Business, Innovation & Employment on the Review of the Crown Minerals Act 1991
19 August 2019
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
11 October 2018
IAGC Submission to the New Zealand Parliament – Committee Secretariat on the Crown Minerals (Petroleum) Amendment Bill
4 June 2018
Letter to Minister Ardern, New Zealand, regarding New Zealand Government’s announcement that it will end oil and gas exploration.
13 December 2017
Letter to Minister of Conservation, New Zealand, regarding recent media comments by the New Zealand Government about seismic surveys
