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Letters or Comments

API's Comments on Proposed Implementation of the 2015 NAAQS for Ozone

Monday, February 13, 2017

API filed comments on Monday, February 13, 2017, to EPA’s Proposed Implementation of the 2015 National Ambient Air Quality Standards for Ozone: Nonattainment Area Classifications and State Implementation Plan Requirements (81 Fed. Reg. 81,276 (Nov. 17, 2016)). API’s comments focus on how best EPA can facilitate a less burdensome transition between the 2008 and 2015 standards so states and businesses are not dealing with two sets of requirements and timetables simultaneously. Further, API urges EPA to utilize the full scope of its statutory authority to extend compliance flexibility to areas not presently attaining the 2008 standards. API comments also cover the complexities of attaining the stringent ozone standards given the scope of background ozone and the lack of currently available EPA tools for states to use in crafting successful State Implementation Plans.

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Coalition Letter to President Trump on FERC Quorum

Monday, February 6, 2017

American Petroleum Institute along with the American Gas Association, American Public Gas Association, American Public Power Association, Association of Pipe Lines, Edison Electric Institute, Electric Power Supply Association, Independent Petroleum Association of America, Interstate Natural Gas Association of America, Larger Public Power Council, National Hydropower Association, National Rural Electric Cooperatives Association, Natural Gas Supply Association, and the Nuclear Energy Institute sent a letter to President Trump urging the administration to promptly nominate candidates to fill FERC's three existing vacancies as quickly as possible so a quorum can be reconstituted without undue delay.

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Coalition Letter Supports Use of Congressional Review Act to overturn BLM's Methane Rule

Wednesday, February 1, 2017

Western Energy Alliance, the Colorado Oil & Gas Association, and the Colorado Petroleum Council strongly support the use of the Congressional Review Act to overturn the Bureau of Land Management’s (BLM) Waste Prevention, Production Subject to Royalties, and Resource Conservation Rule, otherwise known as BLM’s methane rule.

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API Supports CRA Disappoval Resolution of the Section 1504 Rule

Tuesday, January 31, 2017

On January 31, 2017, API President and CEO Jack Gerard sent this letter to House leaders Speaker Paul Ryan and Democratic Leader Nancy Pelosi. The American Petroleum Institute (API) strongly supports H.J.Res. 41, providing for congressional disapproval under the Congressional Review Act (CRA) of the Securities and Exchange Commission (SEC) rule relating to “Disclosure of Payments by Resource Extraction Issuers” (Section 1504 rule). API strongly supports transparency. Unfortunately, the Section 1504 rule fails to strike the right balance between its intended disclosure requirement purposes and protecting the competitiveness of U.S.-publicly listed companies, hurting American workers and investors.

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API Supports CRA Disappoval Resolutions of the DOI Methane & Waste Prevention rule

Tuesday, January 31, 2017

On January 31, 2017, API President and CEO Jack Gerard sent this letter to House leaders Speaker Paul Ryan and Democratic Leader Nancy Pelosi. The American Petroleum Institute strongly supports H.J. Res. 36, providing for congressional disapproval under the Congressional Review Act (CRA) of the Department of Interior’s “Methane and Waste Prevention” rule that went into effect in the final days of the Obama administration. This redundant and technically flawed rule will further impede oil and natural gas production on federal land, which already has been declining – down 18 percent from 2010 to 2015. The rule is a step backwards for U.S. energy policy and all Americans who benefit from domestic energy production. As such, it is important that the House support the disapproval resolution so that the United States may harness the increased economic opportunity and enhanced national security that the nation’s abundant federal resources can provide.

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Virginia Petroleum Council Executive Director Miles Morin's letter to FERC

Thursday, December 22, 2016

Virginia Petroleum Council Executive Director Miles Morin called on the Federal Energy Regulatory Commission (FERC) to approve the Mountain Valley Pipeline. In his letter to FERC Secretary Kimberly Bose, Morin explained the benefits that would come to Virginia with an increase in the state’s energy infrastructure.

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API comments in support of Castleton Commodities International

Monday, November 21, 2016

API submits comments in support of Castleton Commodities International LLC’s request for rehearing by the New York State Public Service Commission on their August 1 Order adopting a Clean Energy Standard. API is committed to competitive markets and believes that such markets produce the most economically and socially beneficial outcomes. By subsidizing nuclear generators that would otherwise be uneconomic in competitive markets, the ZEC Program directly interferes with these market signals, potentially deterring or harming more efficient generators.

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Coalition letter urge President to finalize OCS Program without removing additional areas

Thursday, November 3, 2016

As representatives of millions of consumers, businesses, workers, and citizens across the United States, the undersigned groups urge President Obama's administration to finalize a 2017-2022 Outer Continental Shelf (OCS) Oil and Gas Leasing Program without removing any additional areas. We also urge you not to take any actions that would remove areas from consideration under future offshore leasing programs.

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Fact Sheet: Industry Practices and Trends Protecting Water Resources During Hydraulic Fracturing

Wednesday, October 26, 2016

This fact sheet was released last week. Tuesday evening API transmitted to the EPA the Catalyst Environmental Solutions (CES) document titled Industry Practices and Trends Protecting Water Resources During Hydraulic Fracturing: Information for US EPA’s Draft Assessment (October 2016).

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API Comments to EPA on Draft National Pollutant Discharge Elimination System (NPDES) General Permit for Gulf of Mexico

Tuesday, October 18, 2016

API’s comments concerning Draft National Pollutant Discharge Elimination System (NPDES) General Permit for the Eastern Portion of the Outer Continental Shelf (OCS) of the Gulf of Mexico (GEG460000) (81 Fed. Reg. 55,196 (August 18, 2016)). These comments echo and strongly support the Offshore Operators Committee (OOC) comments on the same topic, which are incorporated by reference.

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