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Letters or Comments

API-IPAA comments for USFS oil and gas regulations ANPRM

Friday, October 12, 2018

The American Petroleum Institute (“API”) and the Independent Petroleum Association of America (“IPAA) – hereafter, “the Associations” - are pleased to provide these comments in response to the United States Forest Service’s (“USFS”) Advance Notice of Proposed Rulemaking (“ANPRM”) to revise the contents of its Oil and Gas Resources regulations, published in the Federal Register September 13, 2018.

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Bloomberg Environment Inquiry on EPA's Clean Air Act Permitting

Monday, October 8, 2018

The Associations included below respectfully submit the attached comments on the Environmental Protection Agency’s (EPA’s) draft guidance, “Interpreting ‘Adjacent’ for New Source Review and Title V Source Determinations in All Industries Other Than Oil and Gas.” (“draft guidance”). We support EPA’s efforts to restore the major NSR regulations and other air regulations to their proper scope, and greatly appreciate the opportunity to provide comment on the draft guidance before EPA issues a final version. We believe upfront engagement can improve the final product.

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API and AFPM E15 letter to POTUS

Wednesday, September 26, 2018

API writes to express our opposition to an extension of the one-pound Reid Vapor Pressure (RVP) waiver to E15 fuel.

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ESA Cross-Industry Coalition on ESA Proposals

Tuesday, September 25, 2018

The Coalition endorses, and is encouraged by, the Services’ efforts to clarify and improve their ESA regulations, and to reduce duplication and inefficiency, so that the Services, the regulated communities, and the public can focus their limited resources on actions that truly improve environmental outcomes. We support many of the Services’ proposed modifications, which are consistent with the Act, its legislative history, and the case law, and reflect concerns the Coalition expressed in prior comments and litigation. There are a number of areas, however, where changes to the proposals are warranted to ensure consistency with the statute and settled precedent and to improve implementation of the Act, these areas are detailed in the submitted comments.

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API CEO NOPEC Letter

Wednesday, August 22, 2018

On August 22, 2018, the American Petroleum Institute (API) sent a letter to the Chairman and Ranking Members of the House and Senate Judiciary Committees opposing House and Senate NOPEC legislation (H.R. 5904 and S. 3214), No Oil Producing and Exporting Cartels (NOPEC) Acts of 2018, currently under consideration by these committees. Industry sees these bills as creating significant detrimental exposure to US diplomatic, military and business interests while having limited impact on the market concerns driving the legislation.

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API comments: EPA proposed 2019 RVOs

Friday, August 17, 2018

As the EPA prepares its final volumes for 2019 under the Renewable Fuel Standard (RFS) mandate, API reminds policymakers that this mandate is broken and should be repealed or significantly reformed. In the meantime, we urge the EPA to keep RFS volumes at a low enough level to avoid a potential breach of the blend wall. Read API’s full comments to the EPA.

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API press conference: 2019 EPA proposed RVOs under the Renewable Fuel Standard

Thursday, August 16, 2018

Good morning and thank you for joining our call. 

As the EPA prepares the final volumes for 2019 under the RFS mandate, we remind policymakers that this mandate is broken and should be repealed or significantly reformed. In the meantime, API urges the EPA to keep RFS volumes at a low enough level to avoid a potential breach of the blend wall …

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API Comments on Proposed Rule: Strengthening Transparency in Regulatory Science

Thursday, August 16, 2018

API supports the use of sound science as a critical component in public policy. Data and analyses used in establishing and evaluating environmental, health, welfare and economic impacts should be transparent and reproducible and available as early as possible in the rulemaking process, to the extent possible and consistent with the protection of other compelling interests. Transparency and reproducibility should also apply to underlying data and information, such as environmental and economic impact data and models that are utilized to predict costs, benefits, market impacts and/or environmental and health effects of specific regulatory interventions.

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API Comments on Proposed Determination of Action Pursuant to Section 301

Tuesday, August 14, 2018

August 13, 2018 – API letter to U.S. Trade Representative (USTR) Lighthizer commenting on Proposed Determination of Action Pursuant to Section 301: China's Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation; Docket No. USTR-2018-0026

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Comment on the U.S. Environmental Protection Agency’s Advanced Notice of Proposed Rulemaking on “Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process” (83 Fed. Reg. 27,524 (June 13, 2018)

Tuesday, August 14, 2018

Responsible public policy should rely on a more rational prioritization of resources that is informed by a meaningful weighing of compliance burdens against the risks in full consideration of the uncertainty associated with those risks. In our attached comments, API supports EPA’s interest in improving the consistency and transparency of its calculation and consideration of regulatory costs and benefits. These economic considerations, which are required in numerous statutes and executive orders, were mandated precisely for the purpose of improving the efficacy of environmental regulation and the allocation of both industry and Agency resources. Efforts to improve the consistency and transparency of these analyses should not, therefore, be viewed as an effort to abandon the Agency’s pursuit of improved environmental outcomes – nor has API ever advocated for such a result. This ANPRM is a critical step toward improved regulatory processes.

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