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The Interstate Oil and Gas Compact Commission, or (IOGCC), is a quasi-governmental organization based in Oklahoma City located on property adjacent to the Governor's Mansion and on Oklahoma state property.<ref>[http://www.desmogblog.com/2015/10/08/iogcc-cops-climate-change "Congress-backed Interstate Oil Commission Call Cops When Reporter Arrives To Ask About Climate"], Steve Horn, DeSmogBlog.com, October 9, 2015, accessed April 2016.</ref> The IOGCC is focused on oil and gas regulations, these days mostly centering around the issue of [[hydraulic fracturing]], and is made up of appointees selected by the governors of the 38 oil and gas producing states, plus eight Canadian provinces and three countries as international affiliates.<ref>[http://iogcc.publishpath.com/member-states "Member States"], Interstate Oil and Gas Compact Commission, accessed February 2016</ref> Governors generally appoint high-level regulators to participate.

In 1991 at the dawn of the [[fracking]] boom, the commission changed its name from the Interstate Oil Compact Commission (IOCC) to the Interstate Oil and Gas Compact Commission (IOGCC). It was founded as the Interstate Compact to Conserve Oil and Gas, named such because it was over-producing and therefore wasting oil and gas product.<ref>[http://iogcc.ok.gov/history-and-accomplishments "80 Years of History and Accomplishments"] Interstate Oil and Gas Compact Commission, accessed Februrary 2016.</ref>

As commonly advertised, IOGCC’s membership base generally consists of top-ranking officials at state-level regulatory agencies. In reality, IOGCC’s membership roster<ref>[https://www.documentcloud.org/documents/2798326-IOGCC-2015-Member-Directory.html "IOGCC 2015 Member Directory"]</ref> is dominated in the majority by lobbyists and executives, and these members are appointed by the Governors of member states. Some of those appointees are even lobbyists and/or industry attorneys.<ref>[http://www.propublica.org/article/some-appointees-to-oil-and-gas-commission-are-industry-execs-lobbyists "Some appointees to Oil and Gas Commission are Industry Execs"], Marie Baca, Propublica.org, December 9, 2010, accessed April 2016.</ref>

Today, IOGCC is best known for running the voluntary FracFocus database for disclosure of chemicals injected into the ground during fracking, doing so alongside the fellow Oklahoma City-based Groundwater Protection Council (GWPC). FracFocus – which IOGCC admitted in a presentation can serve as important public relations tool for the oil and gas industry – has come under fire by media<ref>[http://www.bloomberg.com/news/articles/2012-11-30/frack-secrets-by-thousands-keep-u-s-clueless-on-wells “Fracking Secrets by Thousands Keep U.S. Clueless on Wells”], Ben Elgin, Benjamin Haas and Phil Kuntz; Bloomberg, November 12, 2012</ref> and academia<ref>[http://news.harvard.edu/gazette/story/2015/12/disclosures-on-fracking-lacking-study-finds/ “Disclosures on fracking lacking, study finds”], Liz Mineo, Harvard Gazette, December 15, 2015</ref> for its actual lack of transparency. FracFocus is linked to industry public relations firm Brothers and Company<ref>[http://www.nd.gov/ndic/ogrp/meet1008/resp-022-a.pdf “Hydraulic Fracturing e‐reference”], North Dakota Industrial Commission, accessed April 2016</ref> which registered the website<ref>[http://www.networksolutions.com/whois/results.jsp?domain=fracfocus.org “Networked Solutions WhoIs Search for FracFocus.org”], NetworkedSolutions.com, accessed April 2016</ref> and lists IOGCC as one of its clients alongside [[Chesapeake Energy]], America’s Natural Gas Alliance and [[Devon Energy]].<ref>[http://www.nd.gov/ndic/ogrp/meet1008/resp-022-a.pdf “Hydraulic Fracturing e‐reference”], North Dakota Industrial Commission, accessed April 2016</ref>

==IOGCC Staff==

'''[[Carl Michael Smith]]''' - Executive Director 

'''[[Gerry Baker]]''' - Associate Director 

'''Carol Booth''' - Communications Director

==Prominent Members==

'''Ron Ness''' - Head of North Dakota Petroleum Council, Public Outreach Committee
	
'''[[Harold Hamm]]''' – Continental Resources CEO and Founder, Legal and Regulatory Affairs Committee

'''Ryan Bernstein''' – Legal Counsel and Chief-of-Staff for U.S. Sen. and former IOGCC chairman [[John Hoeven]] (R-ND); Legal and Regulatory Affairs Committee
	
'''Tom Price''' – Former senior vice president of corporate development and government relations of [[Chesapeake Energy]], Public Outreach Committee

'''Nancy Johnson''' – U.S. Department of Energy, Director of Environmental Science and Policy Analysis

'''Roger Kelley''' – [[Continental Resources]], Legal and Regulatory Affairs Committee

'''Evan Olson''' – Legal counsel for [[ExxonMobil]], Legal and Regulatory Affairs Committee

'''Lindsey Dingmore''' – [[XTO Energy]], Legal and Regulatory Affairs Committee

'''Scott Anderson''' – [[Environmental Defense Fund]], Legal and Regulatory Affairs Committee

'''Ronald C.Schultz,Jr.''' – [[ConocoPhillips]], Legal and Regulatory Affairs Committee

'''Santana Gonzalez, Jr.''' - Now-retired lobbyist for [[Chevron]] in Texas, Environmental and Safety Committee

'''Marc Bond''' – Former legal counsel for [[Chevron]], now legal counsel with Hillcorp<ref>[https://www.documentcloud.org/documents/2798326-IOGCC-2015-Member-Directory.html "IOGCC 2015 Member Directory"]</ref>

==Recent IOGCC Chairs==

'''2016''' - Oklahoma Gov. Mary Fallin

'''2015''' - Utah Gov. Gary Herbert

'''2014''' - Mississippi Gov. Phil Bryant

'''2013''' - Alabama Gov. Robert Bentley

'''2012''' - Alaska Gov. Sean Parnell

'''2011''' - Oklahoma Gov. Mary Fallin
 
'''2010''' - Texas Gov. Rick Perry

'''2009''' - Oklahoma Gov. Brad Henry 

'''2008''' - Alaska Gov. Sarah Palin

'''2007''' - North Dakota Gov. John Hoeven

'''2006''' - Wyoming Gov. Dave Freudenthal

'''2005''' - Alaska Gov. Frank Murkowski

'''2004''' - New Mexico Gov. Bill Richardson

'''2003''' - North Dakota Gov. John Hoeven

'''2002''' - Arkansas Gov. Mike Huckabee

'''2001''' - Alaska Gov. Tony Knowles

'''2000''' - Alaska Gov. Tony Knowles

'''1999''' - Kansas Gov. Bill Graves

'''1998''' - Wyoming Gov. Jim Geringer

'''1997''' - Oklahoma Gov. Frank Keating<ref>[http://iogcc.publishpath.com/officers IOGCC Officers], accessed April 2016</ref>

=Overview=

==History==

The Interstate Oil and Gas Compact Commission was created by an act of Congress in 1935 as a constitutionally-ordained compact via Article 1, Section 10 of the U.S. Constitution.<ref>[https://www.congress.gov/bill/97th-congress/senate-joint-resolution/111/all-info?resultIndex=1 "S.J.Res.111 - A joint resolution consenting to an extension and renewal of the interstate compact to conserve oil and gas" ], Congress.gov, accessed April 2016.</ref> U.S. Congressman and Oklahoma Governor, E.W. Marland is considered IOGCC's founder.<ref>[http://iogcc.publishpath.com/history "Interstate Oil and Gas Compact Commission History"], Interstate Oil and Gas Compact, accessed April 2016</ref> Marland, who owned several oil companies in his lifetime, also founded the US Oil and Gas Association, then called the Mid-Continent Association. The US Oil and Gas Association is a lobbying group that spent $204,000 lobbying the federal government on behalf of the oil and gas industry in 2015.<ref>[http://www.opensecrets.org/lobby/clientsum.php?id=D000058082&year=2015 "US Oil & Gas Association"], OpenSecrets.org. accessed April 2016</ref>

Though IOGCC is a compact, it often claims to be a government agency and is listed as such both on its own website, serves on several federal bodies as a government agency and is listed as an agency on the website of the Oklahoma government. 

Despite this, IOGCC claims an exemption from both state- and federal-level open records law requests.<ref>[http://www.desmogblog.com/2015/10/08/iogcc-cops-climate-change "Congress-backed Interstate Oil Commission Call Cops When Reporter Arrives To Ask About Climate"], Steve Horn, DeSmogBlog.com, October 9, 2015, accessed April 2016.</ref> Though the 1997<ref>[https://www.documentcloud.org/documents/1354698-iogcc-charter-and-bylaws.html#document/p10/a187274 "IOGCC 1997 By-Laws"]</ref> and 2005<ref>[https://www.documentcloud.org/documents/2798308-IOGCC-by-Laws-2005.html#document/p5/a288247 "2005 IOGCC By-Laws"]</ref> versions of IOGCC’s bylaws had a provision saying that the public is entitled to records of IOGCC proceedings, the current leadership of IOGCC does not respond to such requests.<ref>[http://www.desmogblog.com/2015/10/08/iogcc-cops-climate-change "Congress-backed Interstate Oil Commission Call Cops When Reporter Arrives To Ask About Climate"], Steve Horn, DeSmogBlog.com, October 9, 2015, accessed April 2016.</ref> Additionally, the current set of by-laws show that the IOGCC no longer lists an open records provision at all<ref>[https://www.documentcloud.org/documents/2798313-Screen-Shot-2016-04-09-at-11-51-22-PM.html#document/p1/a288248 "IOGCC 2015 By-Laws"]</ref>, meaning that according to its by-laws, two-thirds of IOGCC's membership would've had to have voted to strike that provision. IOGCC has claimed this exemption and altered its by-laws despite being located on property owned by the State of Oklahoma and transferred via a land deed by the State, situated on a parcel of land carved out for IOGCC next to the Governor’s Mansion.<ref>[http://www.desmogblog.com/2015/10/08/iogcc-cops-climate-change "Congress-backed Interstate Oil Commission Call Cops When Reporter Arrives To Ask About Climate"], Steve Horn, DeSmogBlog.com, October 9, 2015, accessed April 2016.</ref> 

==Funding==

The IOGCC is funded, in part, through an excise tax<ref>[http://oklegal.onenet.net/oklegal-cgi/get_statute?99/Title.68/68-1103.html The Interstate Oil Compact Fund of Oklahoma], accessed April 2016</ref> on petroleum and by contributions from various member states. Therefore, IOGCC funding increases with increased oil and gas production. Because the IOGCC does not report any information on its funding or budget, no one besides IOGCC itself knows how much of the Commission’s activities are funded directly by the oil and gas industry. A copy of the 2013 budget obtained through open records law from an IOGCC member state, though, reveals that a significant portion of the IOGCC’s budget comes from corporate donations to its biannual meetings.<ref>[https://www.documentcloud.org/documents/1659628-iogcc-finance-committee-report-2013.html IOGCC 2013 Finance Committee Report]</ref>

IOGCC conferences and meetings are funded through sponsorships by the oil and gas industry. The 2015 annual conference that took place in Oklahoma City, Oklahoma was sponsored by some of the largest [[fracking]] companies, including [[Marathon Oil]], the Canadian government, [[Schlumberger]], Sandridge Energy, [[ConocoPhillips]], [[Chevron]], [[BP]] and [[XTO Energy]].<ref>[http://www.desmogblog.com/sites/beta.desmogblog.com/files/IOGCC%20OKC%20Corporate%20Sponsors.pdf IOGCC 2015 Annual Conference: Oklahoma City, OK], DeSmogBlog.com, accessed April 2016.</ref> Further, the prominent funders of its Columbus, Ohio 2014 annual meeting included the likes of [[Marathon Oil]], [[ExxonMobil]] subsidiary [[XTO Energy]], [[Devon Energy]], [[Enbridge]], [[ConocoPhillips]], [[BP]].<ref>[https://www.documentcloud.org/documents/2798386-IOGCC-2014-Annual-Meeting-Sponsors.html IOGCC 2014 Annual Meeting Sponsors]</ref>

==Model Resolutions==

IOGCC also its own [[IOGCC Model Resolutions]] and distributes them to member states, Congress, and executive agencies. Each model resolution, as an IOGCC general practice, has an accompanying "Action Plan"<ref>[https://fs.ogm.utah.gov/bbooks/2010/12_Dec/Briefing/Briefing5_IOGCCMemo.ResolutionsApprovedAt2010AnnualMeeting.pdf 2010 Interstate Oil and Gas Compact Commission Model Resolutions], Utah Division of Oil, Gas and Mining OGM File Services, accessed April 2016.</ref> for what to do with the model in the public policy sphere. The model resolutions center around issue areas such as preventing and preempting federal regulations, anti-federal public lands advocacy, oil and gas wastes and waste injection, among other topics.

Like the [[American Legislative Exchange Council]] (ALEC), the organization's membership base – in some cases actual industry representative members – proposes and passes [[IOGCC Model Resolutions]] on the most pressing oil and gas-related regulatory issues of the day. These have run the gamut on policy areas ranging from public lands issues, safe and clean drinking water regulations, climate change issues, offshore drilling, and others.

The IOGCC attaches “action plans” to its model resolutions,<ref>[https://www.documentcloud.org/documents/2798525-IOGCC-2010-Model-Resolutions-With-Action-Plans.html IOGCC 2010 Model Resolutions], Utah Division of Oil, Gas and Mining</ref> though it does not place those plans online for the rest of the world to see on its website. These documents outline strategic plans to use the resolutions as a lobbying tool to influence regulators and legislators at both the state- and federal-level. A document obtained via open records law shows that IOGCC says that these plans “must” accompany the introduction of all model resolutions.

“The Action Plan, which must accompany the resolution unless the action to be taken is clear on the face of the resolution, sets forth the steps to be followed to implement the resolution,” the document reads. “As you consider why the IOGCC should pass a resolution on your issue, also consider what the IOGCC can do to influence the subject matter of the resolution. With whom should the IOGCC communicate the resolution, how should it be communicated and by whom, what other investigation or research is needed and what other organizations might be joined in the effort, are all issues to consider in drafting the action plan.”<ref>[https://www.documentcloud.org/documents/2798261-How-to-Draft-an-IOGCC-Resolution.html "Drafting an IOGCC Resolution and Action Plan"], Interstate Oil and Gas Compact Commission, accessed April 2016</ref>

==Public Relations==

According to its website, IOGCC “advocates for environmentally-sound ways to increase the supply of American energy.”<ref>[http://iogcc.publishpath.com/about-us "About Us], Interstate Oil and Gas Compact Commission, accessed April 2016</ref> The IOGCC website also offers a “Tips for effective activism” section,<ref>[http://iogcc.publishpath.com/Websites/iogcc/docs/ActionFigures.pdf "Tips for Effective Activism"], Interstate Oil and Gas Compact Commission, accessed April 2016</ref> in which it instructs state regulators to be the “voice” of the IOGCC in public hearings and community meetings. “We’re your voice to Congress. Be ours in your state,” the sub-headline of that document reads.<ref>[http://iogcc.publishpath.com/Websites/iogcc/docs/ActionFigures.pdf "Tips for Effective Activism"], Interstate Oil and Gas Compact Commission, accessed April 2016</ref> 

IOGCC’s “voice” is shaped by oil and gas public relations firms like Brothers and Company, which give seminars to IOGCC’s member state regulators on messaging and how to deal with media.<ref>[https://www.documentcloud.org/documents/1308790-foia-doe-iogcc-comms.html#document/p29/a180389 Document obtained from the U.S. Department of Energy]</ref> At the same time, PR firms like Brothers run advertising campaigns on behalf of the oil and gas industry.<ref>[http://www.nd.gov/ndic/ogrp/meet1008/resp-022-a.pdf “Hydraulic Fracturing e‐reference”], North Dakota Industrial Commission, accessed April 2016</ref> 

That “voice” is also honed by IOGCC’s deputy director, [[Gerry Baker]]. Baker began his career as managing editor and state capitol bureau chief for the Oklahoma Business News Company, leaving in 1979 to do public relations work for the next 12 years for oil company Kerr-McGee Corporation. Anadarko Petroleum purchased Kerr-McGee as a wholly-owned subsidiary in 2006.<ref>[https://www.documentcloud.org/documents/2798197-Gerry-Baker-Aspen-Bio-Corporate-Consulting-Inc.html Gerry Baker Biography]</ref>  

Thereafter, Baker “launched an independent consultancy – Corporate Consulting, Inc. – specializing in strategic communication planning and implementation for high profile clients,” reads his biography up on the Aspen Institute website. “In addition, he specialized in crisis communication management [and] Baker continues to provide these services for select clients.”<ref>[https://www.documentcloud.org/documents/2798197-Gerry-Baker-Aspen-Bio-Corporate-Consulting-Inc.html Gerry Baker Biography]</ref>

At the 1998 IOGCC annual meeting, Baker – while with Corporate Consulting, Inc. – gave a media training seminar.<ref>[https://www.documentcloud.org/documents/2798415-Gerry-Baker-1998-IOGCC-Media-Training-Seminar.html IOGCC 1998 Annual Meeting], Interstate Oil and Gas Compact Commission</ref> Corporate Consulting, Inc. was incorporated in Oklahoma in 1991<ref>[https://www.documentcloud.org/documents/2798206-Gerry-Baker-Incorporation-Form.html Oklahoma Department of State Incorporation Form: Corporate Consulting, Inc.]</ref> and got its most recent Certificate of Good Standing in July 2015.<ref>[https://www.documentcloud.org/documents/2798208-Gerry-Baker-Cert-of-Good-Standing.html Oklahoma Department of State Certificate of Good Standing: Corporate Consulting, Inc.]</ref> Baker began working for IOGCC in 2002 while the organization was pushing hard for the [[Halliburton]] Loophole's insertion into first the Energy Policy Act of 2003, then the [[Energy Policy Act of 2005]]. In 2011, Baker gave a talk at IOGCC’s annual meeting in on how to deal with the public's fear of [[fracking]].

“When people do not get all of the information, or information is too technical, they begin to fill in the holes with what they can imagine,” he said in one of the early presentation slides. “The perceived risk, even if it isn’t a reality, makes hydraulic fracturing an emotional issue.”<ref>[https://www.documentcloud.org/documents/2798411-Gerry-Baker-on-Fracking-and-PR.html#document/p3/a288273 "Reaching Out to a Broad Audience"], Interstate Oil and Gas Compact Commission and FracFocus, October 17, 2011, accessed April 2016</ref>

The IOGCC, furthermore, has a tight-knit relationship with the industry-funded front group, public relations tool and lobbying group, [[Consumer Energy Alliance]] (CEA). CEA is an important part of the IOGCC’s 2013-launched [[States First Initiative]], where they are listed as the only “ally.”<ref>[http://www.statesfirstinitiative.org/#!allies/czie States First Initiative "Allies"], accessed April 2016</ref> An August 2014 version of the website has an "allies" section but no colleagues listed.<ref>[http://web.archive.org/web/20140829010000/http://www.statesfirstinitiative.org/#!allies/czie States First Initiative "Allies"], Way Back Machine, accessed April 2016</ref> CEA also wrote a “letter of support” for States First in March 2014.<ref>[https://www.documentcloud.org/documents/2798420-States-First-Governors-Letter.html States First Initiative Governors' Letter]</ref>

In 2005, per a vote from its Public Outreach Committee, IOGCC published an107-page "Communications Resource Guide."<ref>[https://www.documentcloud.org/documents/2798412-IOGCC-Communications-Resource-Guide.html#document/p2/a288274 IOGCC "Communications Resource Guide"]</ref>

"The development and dissemination of data and knowledge is essential to cultivating an understanding and appreciation of the energy challenges facing our states and nations," reads the Guide. "Today, many groups nationwide cite public image as a major barrier inhibiting the responsible recovery of American oil and natural gas resources. We have a rare opportunity to re-position ourselves from the largely defensive posture of the past quarter century, into a positive, proactive, forward-looking force."<ref>[https://www.documentcloud.org/documents/2798412-IOGCC-Communications-Resource-Guide.html#document/p2/a288274 IOGCC "Communications Resource Guide"]</ref>

At its May 2016 business meeting in Denver, Colorado, IOGCC has two separate three-hour sessions slated for [[crisis communications]] trainings.<ref>[https://www.documentcloud.org/documents/2798900-2016-IOGCC-Business-Meeeting-Agenda.html 2016 IOGCC Annual Business Meeting], Interstate Oil and Gas Compact Commission, accessed April 2016</ref> Both of those sessions will be led by former journalists turned industry PR professionals: Todd Hartman, communications director for the Colorado Department of Conservation<ref>[https://www.documentcloud.org/documents/2798900-2016-IOGCC-Business-Meeeting-Agenda.html#document/p1/a288330 2016 IOGCC Annual Business Meeting], Interstate Oil and Gas Compact Commission, accessed April 2016</ref> and Karen Crummy, communications director for [[fracking]] front groups Protect Colorado and Coloradans for Responsible Energy Development (CRED).<ref>[https://www.documentcloud.org/documents/2798900-2016-IOGCC-Business-Meeeting-Agenda.html#document/p2/a288331 2016 IOGCC Annual Business Meeting], Interstate Oil and Gas Compact Commission, accessed April 2016</ref> Hartman formerly reported for the Rocky Mountain News, The Gazette of Colorado Springs, The Miami Herald, while Crummy was a political and then investigative reporter for The Denver Post.<ref>[https://www.documentcloud.org/documents/2798954-Todd-Hartman-LinkedIn.html Todd Hartman, LinkedIn] accessed April 2016</ref><ref>[https://www.documentcloud.org/documents/2798955-Karen-Crummy-LinkedIn.html Karen Crummy, LinkedIn], accessed April 2016</ref>

A month after Crummy began working at CRED, the [[Noble Energy]] and [[Anadarko Petroleum]] funded [[front group]] paid for a sponsored content full "energy and environment" section that ran both online and in the print edition of The Denver Post, which its energy reporter pointed to as being "faux" on Twitter and which one anonymous former Denver Post reporter told the publication [[ThinkProgress]] “If I weren’t a journalist, I’m not sure I could tell the difference here...“I go back to the way in which non-editorial material used to be identified in printed pages of the newspaper — that was different type fonts, different look, everything different so that you know that it’s advertising. Clearly, that’s not done here.””<ref>[http://thinkprogress.org/climate/2014/04/16/3425969/denver-post-sponsored-content/ "The Denver Post’s ‘Energy And Environment’ Section Is Produced By The Oil And Gas Industry"], Katie Valentine, ThinkProgress, April 16, 2014</ref>

==Baker Calls 911 on Reporter==

In October 2015, IOGCC deputy director [[Gerry Baker]] called the Oklahoma City Police Department 911 line when DeSmogBlog.com reporter Steve Horn visited IOGCC's office to ask about for its stance on climate change. Horn had attended its annual meeting just days earlier and had told IOGCC he would be swinging by the office to ask about the issue.

IOGCC executive director [[Carl Michael Smith]] was in the office at the time, as was communications director Carol Booth. Neither of them answered the door and instead Baker reported Horn's activities as "suspicious" to the police. No arrests arose from the incident, which was recorded and the 911 call audio, as well as the incident report, were published online by DeSmogBlog.com.<ref>[http://www.desmogblog.com/2015/10/08/iogcc-cops-climate-change "Congress-backed Interstate Oil Commission Call Cops When Reporter Arrives To Ask About Climate"] Steve Horn, DeSmogBlog.com, October 8, 2016, accessed April 2016</ref>

=IOGCC's Impacts=

==[[Halliburton]] Loophole or IOGCC Loophole?==

===Fracking and Groundwater Contamination===
The IOGCC has been influential in downplaying safety concerns regarding hydraulic fracturing and groundwater contamination. The IOGCC released a survey of [[fracking]] wells in 2002 that found that there has been nearly 1 million wells had used [[fracking]] "with no documented harm to groundwater." This survey has been cited repeatedly since then and played a central role in the debate over the [[Energy Policy Act of 2005]] in the years leading up to its passage. It has since been discovered that the IOGCC missed or looked the other way at real-life incidents of groundwater contamination due to the fracking process.<ref>[http://www.nytimes.com/2011/08/04/us/04natgas.html?pagewanted=all&_r=0 "A Tainted Well and Concern There May Be More"], Ian Urbina. The New York Times. August 3, 2011</ref>

IOGCC commented on and exhibited the 2002 survey in a comment it made for the EPA’s proposed fracking of coalbed methane rules that came out in 2004. EPA whistleblower Wes Wilson spoke out about the EPA report being politicized and bad science.<ref>[http://www.foodandwaterwatch.org/sites/default/files/epa-wilson-weston-letter.pdf EPA Wes Wilson Letter], Wes Wilson, U.S. Environmental Protection Agency, October 18, 2004, accessed April 2016</ref>

IOGCC understood the political importance of the 2004 EPA [[fracking]] report’s release, issuing a press statement on it in July 2004.

“We are pleased with EPA’s conclusion supporting the states’ position that the state programs have been effective in protecting groundwater sources,” said Christine Hansen , then-IOGCC executive director, in the release. “Environmental protection is an important goal of state oil and gas regulation, and the IOGCC is committed to ensuring this goal is met at all times in the exploration and production process.”<ref>[https://www.documentcloud.org/documents/2798247-Hydraulic-Fracturing-EPA-IOGCC-2004.html "Hydraulic Fracturing Poses No Threat to USDWs, U.S. EPA Verifies"], Alesha Riggle, Interstate Oil and Gas Compact Commission, July 2, 2004, accessed April 2016</ref>

===Loophole Lobbying===

In reality, IOGCC has situated itself at the center of the issue of fracking's Safe Drinking Water Act (SDWA) of 1974 exemption since the first years after the bill passed in Congress and was proposed by President Richard Nixon and signed into law by President Gerald Ford. 

In 1976, IOGCC submitted comments to the EPA on its proposed regulations for underground injection control (UIC), doing so as one of the “interested parties” alongside the [[American Petroleum Institute]].<ref>[https://www.documentcloud.org/documents/2798423-EPA-UIC-Draft-Report.html#document/p7/a288275 "Draft Environmental Impact Statement: Underground Injection Control"], Office of Water Supply, U.S. Environmental Protection Agency, 1976</ref> Its advocacy paid off: the 1980 Safe Drinking Water Act amendments delegated regulatory authority of the SDWA to the states. That same year at its annual meeting, it played host to a panel on what the organization should do to fend off the Safe Drinking Water Act's application to drilling.<ref>[https://www.documentcloud.org/documents/2798425-IOGCC-1976-Meeting-SDWA.html "Comments on Underground Injection Control Provisions of Safe Drinking Water Act"], Interstate Oil Compact Commission Committee Bulletin; Volume XVIII, Number 2; December 1976</ref>

"It is hoped that the EPA considers the comments which have been made and that the rules as finally promulgated be such that they will not interfere or impede with the production of oil and gas," reads the speech transcript from that meeting, which was given by Sam Shakely, then the manager of pollution abatement for the Oklahoma Corporation Commission.<ref>[https://www.documentcloud.org/documents/2798425-IOGCC-1976-Meeting-SDWA.html "Comments on Underground Injection Control Provisions of Safe Drinking Water Act"], Interstate Oil Compact Commission Committee Bulletin; Volume XVIII, Number 2; December 1976</ref>

IOGCC also spearheaded an advocacy campaign on the ''Legal Environmental Assistance Foundation (LEAF) v. EPA'' case that wove its way up to the U.S. Court of Appeals for the 11th Circuit. The 1997 U.S. Appeals Court ruling for that case said fracking was a form of underground injection and thus should be regulated by the EPA under the SDWA. IOGCC decried this decision in a press release, passed a resolution pertaining to it<ref>[https://www.documentcloud.org/documents/2798475-RESOLUTION-97-901-LEAF-v-EPA.html IOGCC LEAF v. EPA Model Resolution]</ref>, had a subcommittee workgroup dealing with the LEAF case,<ref>[https://www.documentcloud.org/documents/1354693-iogcc-halliburton-loophole.html#document/p3/a288276 IOGCC "Compact Comments"], September 2005</ref> and devoted an entire portion of its website to the case and its advocacy efforts around it.<ref>[https://www.documentcloud.org/documents/2798456-IOGCC-LEAF-v-EPA-Website-Section.html IOGCC LEAF v. EPA Website Section]</ref> 

In a subsequent U.S. Appeals Court case decided in 2001, IOGCC served as a legal intervenor alongside [[American Petroleum Institute]], [[Halliburton]] and others.<ref>[https://www.documentcloud.org/documents/2798122-LEAF-v-EPA-IOGCC-Docs.html ''LEAF v. EPA'' Court Documents], U.S. Court of Appeals for the 11th Circuit</ref> A document housed at Greenpeace USA’s anti-environmental archives shows that during this era, IOGCC was an API dues-paying member.<ref>[http://www.documentcloud.org/documents/1680989-americanpetroleum-lnst00975.html American Petroleum Institute Dues-Paying Members in September 1998]</ref> IOGCC also advocated for S. 724 of 1999 in a model resolution, which called for the SDWA enforcement exemption as applied to fracking.<ref>[https://www.documentcloud.org/documents/2798476-S-724-IOGCC-Model-Resolution.html "Resolution 99.603: Urging Congress to Enact S.724 to Correctly Characterize Hydraulic Fracturing for Purposes of the Safe Drinking Water Act"], Interstate Oil and Gas Compact Commission</ref>  

IOGCC’s second D.C. lobbyist Kevin Bliss – who maintained an office in D.C.<ref>[https://www.documentcloud.org/documents/2798318-IOGCC-DC-Office.html Former IOGCC Washington D.C. Office Address], Kevin Bliss, Interstate Oil and Gas Compact Commission</ref> – is credited in a September 2005 newsletter with helping to get industry exemption now known as the [[Halliburton]] Loophole inserted into the [[Energy Policy Act of 2005]].<ref>[https://www.documentcloud.org/documents/1354693-iogcc-halliburton-loophole.html IOGCC "Compact Comments"], September 2005</ref> Bliss has gone on the record to say<ref>[https://www.documentcloud.org/documents/2798244-Kevin-Bliss-on-Fracking-Water-Contamination.html#document/p1/a288278 "Testimony of Kevin Bliss Representing the Interstate Oil and Gas Compact Commission Before the National Drinking Water Advisory Council"], Kevin Bliss, December 12, 2002</ref> like former IOGCC executive director Christine Hansen, that there is no link between fracking and groundwater contamination.<ref>[https://www.documentcloud.org/documents/2798125-Comment-for-67-FR-55249-From-Christine-Hansen.html#document/p1/a288277 Comment to the EPA from Christine Hansen, Executive Director of IOGCC], U.S. Environmental Protection Agency, 2002</ref>

So too is Bill Cooper, then a staffer for U.S. Rep. [[Joe Barton]] (R-TX), who at the time served as counsel for the U.S. House Committee on Energy and Commerce and who “became an advocate for the IOGCC’s original legislative solution.”<ref>[https://www.documentcloud.org/documents/1354693-iogcc-halliburton-loophole.html IOGCC "Compact Comments"], Interstate Oil and Gas Compact Commission, September 2005</ref> Cooper attended IOGCC’s 2004 meeting in Oklahoma City while working for Barton and IOGCC paid his way, according to congressional travel disclosure records.<ref>[https://www.documentcloud.org/documents/2798234-Bill-Cooper-2004-IOGCC-Meeting.html Employee Travel Disclosure Form: Bill Cooper], U.S. House of Representatives</ref> Sponsors of that meeting included BP, Chesapeake Energy, Devon Energy, Dominion Energy, Kerr-McGee (now [[Anadarko Petroleum]]), [[Williams Energy]] and others.<ref>[https://www.documentcloud.org/documents/2798235-IOGCC-OKC-2004.html IOGCC 2004 Oklahoma City Annual Meeting], Interstate Oil and Gas Compact Commission</ref> Cooper would eventually leave for a job as head lobbyist at the [[American Petroleum Institute]]-created Center for Liquefied Natural Gas<ref>[http://www.desmogblog.com/natural-gas-exports-washington-s-revolving-door-fuels-climate-threat-conclusion "Natural Gas Exports: Washington's Revolving Door Fuels Climate Threat"] Steve Horn and Lee Fang, DeSmogBlog and Republic Report, November 2014</ref>, created under seemingly specifically for him after he had been registering to lobby for API on LNG issues,<ref>[http://disclosures.house.gov/ld/pdfform.aspx?id=100016020 Bill Cooper Lobbying Report], February 2006, accessed April 2016</ref> doing so to work again as Staff Director for the U.S. House Subcommittee on Energy and Mineral Resources and Senior Policy Advisor for the U.S. House Committee on Natural Resources.<ref>[https://www.linkedin.com/in/bill-cooper-56991a6 Bill Cooper LinkedIn Profile], accessed April 2016</ref>
	
After the bill passed, IOGCC declared victory in a press release, too, saying that the “waiting game is over” in its headline.<ref>[https://www.documentcloud.org/documents/2798236-The-Waiting-Game-Is-Over.html "The Waiting Game Is Over"], Alesha Leemaster, Interstate Oil and Gas Compact Commission, July 29, 2005</ref>
 
"With strict, top-of-the-line state policies already in place, IOGCC member states stand ready to deliver these much-needed resources to consumers, with the utmost respect for our environment," Christine Hansen, then-IOGCC executive director, declared in the release.<ref>[https://www.documentcloud.org/documents/2798236-The-Waiting-Game-Is-Over.html "The Waiting Game Is Over"], Alesha Leemaster, Interstate Oil and Gas Compact Commission, July 29, 2005</ref>

IOGCC had earlier issued a laudatory press release when the bill passed the Senate, too.

===[[FRAC Act of 2009]] Fight-Back===

In the years thereafter, IOGCC created a model resolution in 2009 to protect the [[fracking]] exemption from the SDWA in the aftermath of citizen and advocacy group concern over the drilling technique’s potential groundwater impacts, as well as introduction of the [[FRAC Act of 2009]], which would have reversed the IOGCC-created loophole. 

That resolution was picked up by the [[American Legislative Exchange Council]] (ALEC) and adopted as one of its model bills, while passing in nine different states across the U.S.<ref>[https://www.documentcloud.org/documents/2129210-iogcc-alec-and-state-resolutions-on-sdwa.html IOGCC, ALEC, and State Resolutions on Safe Drinking Water Act]</ref><ref>[https://www.alec.org/model-policy/resolution-to-retain-state-authority-over-hydraulic-fracturing/ "Resolution to Retain State Authority Over Hydraulic Fracturing"], American Legislative Exchange Council, accessed April 2016</ref> Akin to a lobbying firm, a document shows that IOGCC actually tracked the passage of the resolutions in those states.<ref>[http://groundwork.iogcc.ok.gov/topics-index/hydraulic-fracturing/legislation/individual-state-resolutions "Individual State Resolutions"], Interstate Oil and Gas Compact Commission Groundwork, accessed April 2015</ref> A close look at the language reveals word for word similarity between the nine state resolutions and the original IOGCC model.<ref>[https://www.documentcloud.org/documents/2129210-iogcc-alec-and-state-resolutions-on-sdwa.html IOGCC, ALEC, and State Resolutions on Safe Drinking Water Act]</ref> 

In a February 26, 2009 hearing on the Utah version of the model resolution appearing as a “member of the public,” (starting at 33:25) Utah’s IOGCC representative John Baza cited the IOGCC as the progenitor of the bill and said the Utah version and the IOGCC version “pretty much mirror each other,”<ref>[http://utahlegislature.granicus.com/MediaPlayer.php?view_id=2&clip_id=13777&meta_id=507263 House Natural Resources, Agriculture, and Environment Standing Committee Meeting], Utah State Legislature, February 26, 2009</ref> also saying there was no evidence of groundwater contamination from fracking. He spoke similarly as a member of the “public” at a February 13 hearing (starting at 4:50) in support of the bill's passage, saying the two resolutions are “essentially mirrors” and fracking can be done without “harm to groundwater situations.”<ref>[http://utahlegislature.granicus.com/MediaPlayer.php?view_id=2&clip_id=13882&meta_id=506976 Senate Natural Resources, Agriculture, and Environment Standing Committee Meeting], Utah State Legislature, February 13, 2009</ref>

By the middle of that year, it appears IOGCC was working in close coordination with the Independent Petroleum Association of America (IPAA), creator of [[fracking]] front group [[Energy in Depth]]. EID got off the ground in June 2009 by publishing a document titled, “Hydraulic Fracturing Under Attack.” IOGCC is cited as a key vehicle for fighting back in the memo.<ref>[http://desmogblog.com/sites/beta.desmogblog.com/files/HFUnderFire.pdf "Hydraulic Fracturing Under Attack"], Independent Petroleum Association of America, June 5, 2009, accessed April 2016</ref>

Five days after IPAA published “Hydraulic Fracturing Under Attack,” IOGCC unveiled its own press release with a similar tenor on June 10, titling it “States Challenge Attempted Federal Power Grab in Hydraulic Fracturing Issue” in reaction to the introduction of the FRAC Act.<ref>[https://www.documentcloud.org/documents/2798752-IOGCC-States-Challenge-Attempted-Federal-Power.html "States Challenge Attempted Federal Power Grab in Hydraulic Fracturing Issue"], Erica Carr, Interstate Oil and Gas Compact Commission June 10, 2005</ref> [[Energy in Depth]] cross-posted the press release on its website the next day.<ref>[https://www.documentcloud.org/documents/2798751-EID-States-Challenge-Attempted-Federal-Power.html "States Challenge Attempted Federal Power Grab in Hydraulic Fracturing Issue"] Shannon Brushe, Energy in Depth, June 11, 2005</ref>

“The response comes on the heels of a bill introduced in the House and the Senate yesterday calling for the repeal of the exemption of hydraulic fracturing from the Safe Drinking Water Act (SDWA), which would ultimately give the federal government jurisdiction over the regulation of the technology,” reads the press release.<ref>[https://www.documentcloud.org/documents/2798752-IOGCC-States-Challenge-Attempted-Federal-Power.html "States Challenge Attempted Federal Power Grab in Hydraulic Fracturing Issue"], Erica Carr, Interstate Oil and Gas Compact Commission June 10, 2005</ref>  

IOGCC’s then and current executive director [[Carl Michael Smith]] also commented on the introduction of the FRAC Act in the June 10 IOGCC press release.<ref>[https://www.documentcloud.org/documents/2798752-IOGCC-States-Challenge-Attempted-Federal-Power.html "States Challenge Attempted Federal Power Grab in Hydraulic Fracturing Issue"], Erica Carr, Interstate Oil and Gas Compact Commission June 10, 2005</ref> 

"The states do a superb job of protecting human health and the environment through sound regulation," said Smith, IOGCC’s then and current executive director. "An unnecessary shift to federal regulation of hydraulic fracturing could greatly inhibit the production of much-needed oil and natural gas resources at a time when our nation's energy security is critical."<ref>[https://www.documentcloud.org/documents/2798752-IOGCC-States-Challenge-Attempted-Federal-Power.html "States Challenge Attempted Federal Power Grab in Hydraulic Fracturing Issue"], Erica Carr, Interstate Oil and Gas Compact Commission June 10, 2005</ref> 

Just eight days later,<ref>[https://www.documentcloud.org/documents/2798314-IOGCC-State-Reps-No-Fracking-Water-Contamination.html#document/p1/a288249 "Regulatory Statements on Hydraulic Fracturing Submitted by the States,"] Interstate Oil and Gas Compact Commission, June 18, 2009, accessed April 2016</ref> IOGCC published a document on its website<ref>[https://www.documentcloud.org/documents/2798760-IOGCC-Statements-on-Fracking-Water-Impacts-from.html  "Regulatory Statements on Hydraulic Fracturing Submitted by the States,"] Interstate Oil and Gas Compact Commission, June 18, 2009, accessed April 2016</ref> with statements from 12 of its state representatives, all of them saying there is no documented link between fracking and groundwater contamination.<ref>[https://www.documentcloud.org/documents/2798759-2009-State-Regulatory-Statements-on-Hydraulic.html "Regulatory Statements on Hydraulic Fracturing Submitted by the States,"] Interstate Oil and Gas Compact Commission, June 18, 2009, accessed April 2016</ref>

===FracFocus===

The IOGCC operates the [[FracFocus]] website alongside the [[Groundwater Protection Council]]. The website, funded by government grants and the oil and gas industry, is a self-disclosure site that companies use to report the types of chemicals and operations they employ during their fracking operations. It is seen by the industry as an alternative disclosure mechanism to what existed prior to that under the [[Halliburton]] Loophole.

It has come under fire by media<ref>[http://www.bloomberg.com/news/articles/2012-11-30/frack-secrets-by-thousands-keep-u-s-clueless-on-wells “Fracking Secrets by Thousands Keep U.S. Clueless on Wells”], Ben Elgin, Benjamin Haas and Phil Kuntz; Bloomberg, November 12, 2012</ref> and academia<ref>[http://news.harvard.edu/gazette/story/2015/12/disclosures-on-fracking-lacking-study-finds/ “Disclosures on fracking lacking, study finds”], Liz Mineo, Harvard Gazette, December 15, 2015</ref> for its actual lack of transparency. FracFocus is linked to industry public relations firm Brothers and Company<ref>[http://www.nd.gov/ndic/ogrp/meet1008/resp-022-a.pdf “Hydraulic Fracturing e‐reference”], North Dakota Industrial Commission, accessed April 2016</ref> which registered the website<ref>[http://www.networksolutions.com/whois/results.jsp?domain=fracfocus.org “Networked Solutions WhoIs Search for FracFocus.org”], NetworkedSolutions.com, accessed April 2016</ref> and lists IOGCC as one of its clients alongside [[Chesapeake Energy]], America’s Natural Gas Alliance and [[Devon Energy]].<ref>[http://www.nd.gov/ndic/ogrp/meet1008/resp-022-a.pdf “Hydraulic Fracturing e‐reference”], North Dakota Industrial Commission, accessed April 2016</ref>

==Oil and Gas Wastes Exemption==

===Relationship with [[Groundwater Protection Council]] Formed===

===STRONGER===

==Anti-Federal Lands Advocacy==

==Offshore Drilling Advocacy==

==Frackquakes==

==Ties to Royalty Crisis==

==Climate Denial==

=Influence Peddling=

==Lobbying Organ or Compact?==

IOGCC’s current posture allows it to act as a lobbying-like intermediary between regulators and industry with little oversight. It also, in essence, turns the regulators into lobbyists on behalf of the industry’s bottom-line. In many instances, IOGCC’s non-industry leadership has referred to itself as part of the “industry,” including most recently at its fall 2014 meeting.<ref>[http://www.desmogblog.com/2014/11/25/why-mississippi-governor-phil-bryant-wants-high-oil-prices-fracking "'I Hate That Oil's Dropping': Why Mississippi Governor Phil Bryant Wants High Oil Prices for Fracking"], Steve Horn, DeSmogBlog.com, November 25, 2014, accessed April 2016</ref>

Previously, IOGCC maintained a Washington, DC-presence too, calling the person tasked to work there its “Washington Consultant” or “Washington Representative.” Its first ever person to serve in that capacity from 1995-1998 was Carl E. Schmid, who described what he did in that position on his resumé as something akin to lobbying.

“Monitored and analyzed federal oil and gas legislation, regulation and policies for organization of governors and state regulators,” it reads. “Advocated positions before Congress and Executive agencies. Provide political strategy, general government affairs support, and Washington presence for organization.”<ref>[https://www.documentcloud.org/documents/2798319-Carl-Schmid-IOGCC-DC-Lobbyist.html#document/p2/a288288 Carl E. Schmid II CV]</ref>

Though largely tucked away in the dustbin of history, the U.S. Department of Justice called IOGCC's activities akin to lobbying in the late-1970's and early-1980's, saying the organization had strayed from its initial mission in 1935 of halting wasteful oil production practices. DOJ's Assistant Attorney General at the time, Robert A. McConnell, concluded in a 1982 letter penned to U.S. Rep. Phil Sharp (R-IN) that IOGCC should no longer receive congressional approval to exist as a compact because it had essentially become an industry lobbying organ.<ref>[https://www.documentcloud.org/documents/2798892-1982-DOJ-IOGCC-Letter.html#document/p5/a288297 1982 Letter to U.S. Rep. Phil Sharp (R-IN) from Assistant Attorney General Robert A. McConnell]</ref> 

DOJ came to a similar conclusion in a 1978 report it published, cited in McConnell letter, which is also the case in related congressional testimony in 1978.

In the 1978 report DOJ stated that it "continues to believe that it is inappropriate for an organization which is so largely engaged in essentially lobbying functions to have a special cachet accorded by periodic congressional approval," continuing to write that "The useful work which he IOCC undertakes can as well be done by a non-congresionally approved association of State regulatory agencies."<ref>[https://www.documentcloud.org/documents/2798886-1978-IOGCC-DOJ-Report.html#document/p68/a288309 "Report of the Attorney General: Pursuant to Section 2(a) of the Joint resolution of October 14, 1976, Conseting to an Interstate Compact to Conserve Oil and Gas"], Joseph A. Mullin, Leonard M. Berke, Robert Fabrikant, Et Al; U.S. Department of Justice, October 14, 1978</ref> 

DOJ utilized similar verbiage in the 1978 congressional testimony made by Donald Flexner, now a founding partner and namesake of the powerful law firm, Boies, Schiller & Flexner.

"[A] large part of the actual work that the IOCC performs at its meetings is now devoted to the generation of pronouncements in the form of resolutions or statements of policy, followed by the active promotion of these policy positions before Congress and Federal agencies," Flexner wrote. 

"The use of the IOCC as a platform for largely 'political' activity appears to go well beyond the original purpose of the Compact..."Under the circumstances outlined above, there no longer seems to be a need to continue this organization as an interstate compact. If so much of its activity should continue to be taken up with what is essentially lobbying work, it would seem inappropriate for it to have the special cachet of Congressional approval."<ref>[https://www.documentcloud.org/documents/2129981-1978-iogcc-reauthorization-hearing.html#document/p16/a225069 "The Role of the Interstate Compact in a Changed Environment: Its Past Activities and Future Plans; And to Consider the Question of Whether or Not to Renew the Compact's Authorization"], Hearing Before the Subcommittee on Energy and Power of the Committee on Interstate and Foreign Commerce, U.S. House of Representatives, July 21, 1978.</ref>

IOGCC's legal counsel at the time, Richard C. Byrd, was grilled at that hearing by U.S. Rep. [[John Dingell]] (D-MI), who asked him blunt questions about whether or not it lobbied and also pointed to IOGCC's industry-heavy membership list in raising them.<ref>[https://www.documentcloud.org/documents/2129981-1978-iogcc-reauthorization-hearing.html#document/p16/a225069"The Role of the Interstate Compact in a Changed Environment: Its Past Activities and Future Plans; And to Consider the Question of Whether or Not to Renew the Compact's Authorization"], Hearing Before the Subcommittee on Energy and Power of the Committee on Interstate and Foreign Commerce, U.S. House of Representatives, July 21, 1978.</ref> Letters show that internally, IOGCC's call to testify in front of Congress and the subpoena of its documents by Dingell<ref>[https://www.documentcloud.org/documents/2798904-IOGCC-Internal-Letters-About-78-DOJ-Hearing.html IOGCC Letters, Dingell Letter, 1978 Hearing]</ref> raised ire within the organization.<ref>[https://www.documentcloud.org/documents/2798904-IOGCC-Internal-Letters-About-78-DOJ-Hearing.html IOGCC Letters, Dingell Letter, 1978 Hearing]</ref>

U.S. Sen. Henry Bellmon, in a letter addressed to former IOGCC chairman and then-Oklahoma Democratic Governor David Boren, reassured the IOGCC that telling them he will do "all I possibly can to see the Commission's charter is extended."</ref> raised ire within the organization.<ref>[https://www.documentcloud.org/documents/2798904-IOGCC-Internal-Letters-About-78-DOJ-Hearing.html#document/p6/a288318 IOGCC Letters, Dingell Letter, 1978 Hearing]</ref>

Though the DOJ said IOGCC should not receive congressional reauthorization, it did not say it should not exist at all and did not call for its demise. IOGCC, therefore, has not been reauthorized by Congress since the 1970’s but it also has never registered to lobby, nor has it registered as a non-profit organization, and so its actual legal status remains nebulous. 

Internal IOGCC documents show the organization maintained a vigorous debate about what to do about its legal situation, including forming a subcommittee that consisted of seven members, three who which were oil and gas industry attorneys at one of its 1979 meetings held in Lexington, Kentucky.<ref>[https://www.documentcloud.org/documents/2798893-Legal-Basis-of-IOCC-Subcommittee.html#document/p3/a288313 IOCC Annual Bulletin, 1979], Interstate Oil Compact Commission</ref> At the IOGCC legal committee hearing on "The Legal Bases of IOCC" that created this subcommittee, the panel seems to have had a robust conversation that only raised more questions at the time rather than answers. 

IOGCC outlined those questions in its internal meeting minutes:

"1.) Does the ''[United States Steel Corporation] v. Multistate Tax Commission'' [U.S. Supreme Court ruling] mean that Congressional approval is not necessary? 2.) What effect does this have on IOCC activities? 3.) Would failure to obtain consent remove any self-imposed restraints? 4.) What would reaction of Congress be of any claim of exemption by IOCC or to any broadening of its activities?"<ref>[https://www.documentcloud.org/documents/2798893-Legal-Basis-of-IOCC-Subcommittee.html#document/p3/a288313 IOCC Annual Bulletin, 1979], Interstate Oil Compact Commission</ref>

The answers become self-evident when looking at IOGCC's history from that point forward. It appears the answer to #1 was "yes," #2 and #3 was that it seemingly emboldened the IOGCC in the years that would follow and #4 was "very little." Congress, in so far as accountability goes, has hardly touched IOGCC since 1981. 

The last time it held a hearing on IOGCC was 1981, in which this nebulous legal status was touched upon, but only briefly and with only a single member of the congressional committee asking questions. Many of those questions posed by U.S. Sen. Wendell Ford (D-KY) actually ended up pertaining to how large the [[tar sands]] reserves were sitting underneath his state.<ref>[https://www.documentcloud.org/documents/2798877-1981-IOGCC-Reauthorization-Hearing.html#document/p21/a288302 "Consenting to an Extension and Renewal of the Interstate Compact to Conserve Oil and Gas"] Hearing Before the U.S. Senate Committee on Energy and Natural Resources: A Joint Resolution Consenting to an Extension and Renewal of the Interstate Compact to Conserve Oil and Gas. U.S. Senate, November 12, 1981</ref>

Senator Ford then asked the big question: what the impact of Congress not reauthorizing the IOGCC would be in terms of its future moving forward. IOGCC legal counsel Richard Byrd's response, offering IOGCC Timothy Dowd who was seated next to him: not much of one.

"I think most scholars now agree that probably this compact is the type of compact that would not necessarily under the Constitution require consent of Congress," Byrd told Ford at the testimony. 

Dowd then backed Byrd up immediately, offering his own legal analysis, showing solidarity with the Kentuckian coal state Senator. 

"Senator, just to prove that we really do know about the eastern part of the United States, the Interstate Mining Compact Commission, which is headquartered in Lexington, was patterned after ours in structure," Dowd stated. "They learned from our mistakes and have obtained one congressional approval which goes until Congress should decide to withdraw its consent."<ref>[https://www.documentcloud.org/documents/2798877-1981-IOGCC-Reauthorization-Hearing.html#document/p23/a288321 "Consenting to an Extension and Renewal of the Interstate Compact to Conserve Oil and Gas"] Hearing Before the U.S. Senate Committee on Energy and Natural Resources: A Joint Resolution Consenting to an Extension and Renewal of the Interstate Compact to Conserve Oil and Gas. U.S. Senate, November 12, 1981</ref>

In response, Senator Ford said "I did not doubt that you knew...I suspect most members of the compact would probably be in favor of not having to come up here if it does not benefit the Commission."

After Byrd explained some of the side perks of staying in touch with the federal government, at least not pertaining to oversight matters, Senator Ford wrapped up the hearing. 

"I appreciate your coming," stated Ford. "Keep up the good work and we will try not to do anything to create more problems for you...Thank you gentlemen. We are adjourned."<ref>[https://www.documentcloud.org/documents/2798877-1981-IOGCC-Reauthorization-Hearing.html#document/p23/a288321 "Consenting to an Extension and Renewal of the Interstate Compact to Conserve Oil and Gas"] Hearing Before the U.S. Senate Committee on Energy and Natural Resources: A Joint Resolution Consenting to an Extension and Renewal of the Interstate Compact to Conserve Oil and Gas. U.S. Senate, November 12, 1981</ref>

The resolution in question for that hearing, Senate Joint Resolution, passed in the U.S. Senate by voice vote but not in the U.S. House and to this day IOGCC remains alive and kicking despite not having received a congressional hearing or vote ever since.<ref>[http://thomas.loc.gov/cgi-bin/bdquery/D?d097:67:./temp/~bdTIfQ:@@@X Bill Summary & Status 97th Congress (1981 - 1982) S.J.RES.111 All Congressional Actions], The Library of Congress, THOMAS, accessed April 2016</ref>

=="Staffers to States" Trips==

==The One Time IOGCC Registered==

The one time IOGCC actually did register to lobby, it paid someone other than it Washington representative at the time, Kevin Bliss. 

That is, IOGCC paid a lobbyist named John W. Conrad III<ref>[https://www.documentcloud.org/documents/2798361-IOGCC-Lobbies-For-Coralville-IA-Indoor-Rainforest.html IOGCC U.S. Congressional Lobbying Disclosure Form], August 2005</ref> to fight for federal money going to an indoor rainforest center to set up shop in Coralville, Iowa. Conrad formerly worked as a special assistant for U.S. Sen. [[Charles Grassley]] (R-IA),<ref>[https://www.documentcloud.org/documents/2798524-John-Conrad-Chuck-Grassley.html, John W. Conrad III], Legistorm.com</ref> the Senator who had pushed for the provision's insertion into the bill.<ref>[http://www.wsj.com/articles/SB106911996482915600 "The Grassley Rainforest Act"], The Wall Street Journal, November 18, 2003, accessed April 2016</ref> Further, IOGCC’s then-executive director Christine Hansen, is an Iowa native and formerly served as an Iowa Commerce Commissioner.<ref>[https://www.documentcloud.org/documents/2798356-Christine-Hansen-Biography.html Christine Hansen 2005 IOGCC Biography]</ref>

Many, conservatives and liberals alike, hoisted up the $50 million proposed subsidy as a case study of “pork barrel” spending.<ref>[http://cagw.org/content/pig-book-2004 "2004 Congressional Pig Book Summary"], Citizens Against Government Waste, accessed April 2016</ref> For example, [[State Policy Network]] member [[Public Interest Institute]] called the project "The Iowa Pork Forest" (in an article written by David Hogberg, no pun intended)<ref>[http://www.limitedgovernment.org/publications/pubs/briefs/pdfs/brf11-20.pdf "The Iowa Pork Forest, Part I"] David Hogberg, Public Interest Institute, July 2004, accessed April 2016</ref>, while liberal economist [[Robert Reich]] called the project proposal "Republican Pork."<ref>[http://prospect.org/article/republican-pork "Republican Pork"] Robert Reich, The American Prospect, December 23, 2003, accessed April 2016</ref> The museum – the official project name being the Iowa Child Institute, which mentions that Conrad lobbied on its behalf on its 2003 Internal Revenue Source 990 form<ref>[http://pdfs.citizenaudit.org/2004_08_EO/42-1506245_990_200312.pdf Iowa Child Institute 2003 IRS 990 Form], U.S. Internal Revenue Service, accessed April 2016</ref> – has yet to be built but maintains a web presence and calls itself "Earthpark."<ref>[http://earthpark.net/about/index.php Earthpark], "About Us," accessed April 2016</ref>

===References===
<references/>