Offshore wind farms are located in deep
waters and can generate high amounts of
energy, enough to provide the electric
needs of a large city.

Energy Starts Here.™

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

23 January 2022
Best Available Technology (BAT) and Best Environmental Practise (BET) for Mitigating Three Noise Sources: Shipping, Seismic Airgun Surveys, and Pile Driving

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

13 October 2020
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

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

20 February 2020

Letter to CNH Requesting Extension of Commercialization Period

17 October 2019

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

15 October 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.

26 June 2018

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

20 August 2021
Joint Trades Comment Letter – Generic Essential Fish Habitat Amendment for Modifying All Gulf of Mexico Fishery Management Plans (Amendment 5)

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

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

4 January 2018

Letter to BOEM and NMFS on a recent study addressing potential effects of seismic surveys on Zooplankton

17 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)

6 November 2017

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)

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

25 August 2017

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

17 August 2017 – BOEM Letter

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

26 July 2017 – Senate Letter

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

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

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).

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

Greece

17 June 2019
Letter to the Prime Minister of the Hellenic Republic on the World Wide Fund for Nature declaration

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

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’.

Denmark

16 Dec 2019
Letter to the Danish Energy Agency regarding the delay in exploration and production licenses under the 8th licensing round.

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.

Asia Pacific

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

4 June 2020

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.

25 May 2018

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

22 January 2020

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

19 August 2019

IAGC Submission to the New Zealand Parliament – Committee Secretariat on the Crown Minerals (Petroleum) Amendment Bill

11 October 2018

Letter to Minister Ardern, New Zealand, regarding New Zealand Government’s announcement that it will end oil and gas exploration.

4 June 2018

Letter to Minister of Conservation, New Zealand, regarding recent media comments by the New Zealand Government about seismic surveys

13 December 2017