API-IAGC Comments on NMFS Regulatory Review
This letter provides the comments of the American Petroleum Institute (“API”) and the International Association of Geophysical Contractors (“IAGC”) (the “Associations”) in response to the National Oceanic and Atmospheric Administration’s (“NOAA”) request for public input on actions the National Marine Fisheries Service (“NMFS”) and the National Ocean Service (“NOS”) should take to streamline their regulatory processes and reduce burdens on the regulated community.1 See 82 Fed. Reg. 31,576 (July 7, 2017). This timely review, as mandated by executive order, is essential to fixing certain regulatory processes under NMFS’s and NOS’s jurisdictions that are presently inefficient, burdensome, and, in some cases, contrary to applicable law.
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