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Letters or Comments

API comments filed on March 18, 2019 re: the U.S. Environmental Protection Agency’s Proposed Amendments to the Standards of Performance for Greenhouse Gas Emissions from New, Modified, and Reconstructed Stationary Sources: Electric Utility Generating Units

Tuesday, March 19, 2019

Although EPA is not proposing changes to the current NSPS for natural gas-fired electric utility generating units (“EGUs”), API believes it is important to provide these comments to describe the vital role of natural gas in power generation and to ensure that the administrative record reflects that natural gas is reliable, abundant, affordable, and environmentally beneficial. API also wants to ensure that the NSPS recognizes the importance of combined heat and power (“CHP”) units and simple cycle combustion turbines. We believe these units should be excluded from the applicability of the NSPS based on their importance to energy efficiency, the expansion of renewable energy, and reliability.

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AOGA and API Comments on Coastal Plain DEIS

Wednesday, March 13, 2019

On March 13, 2019, API and AOGA submitted the following joint comment letter to the Bureau of Land Management on the BLM DEIS for the ANWR Coastal Plain.

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API-Minnesota Supports Enbridge Line 3 in Comments to US Army Corps of Engineers

Friday, February 22, 2019

API submits comments to U.S. Army Corps of Engineers urging support for Enbridge Line 3 permit.

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API opposes the No Oil Producing and Exporting Cartels (NOPEC) Act

Tuesday, February 5, 2019

API sent a letter to members of the House and Senate Judiciary Committees laying out why H.R. 948 could create detrimental exposure to U.S. diplomatic, military and business interests.

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API urges the Minnesota Public Utilities Commission to issue the permit for Enbridge line 3

Tuesday, January 29, 2019

Enbridge Line 3 Replacement Project and predictability of Minnesota’s regulatory processes.

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API-IPAA-Alliance and PAW Comments Submitted to USFS re Land Management Plan Amendments for Sage-Grouse Conservation

Thursday, January 3, 2019

API-IPAA-Alliance and PAW submitted the accompanying comment letter and exhibits to the US Forest Service in response to the agency’s October 5 notice of availability of a DEIS and NOI to amend the agency’s Land Management Plan Amendments for the conservation of the Greater Sage-Grouse in Colorado, Idaho, Nevada, Wyoming, and Utah.

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API Comments on the United States-Mexico-Canada-Agreement (USMCA): Likely Impact on the US Economy and on Specific Industry Sectors

Thursday, December 20, 2018

The American Petroleum Institute submitted written comments to the U.S. ITC on the US-Mexico-Canada Agreement (USMCA)’s likely impact on the U.S. economy, and provided recommendations regarding methodology and how to capture accurately the provisions of the USMCA that are most relevant to the energy sector of the US economy.

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API Comments re: EPA’s “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Reconsideration; Proposed Rule”; 83 Fed. Reg. 52056 (October 15, 2018)

Tuesday, December 18, 2018

The American Petroleum Institute submitted the attached comments regarding EPA’s reconsideration of the New Source Performance Standards (“NSPS”) 40 C.F.R. Part 60 Subpart OOOOa, “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources; Proposed Rule” at 83 Fed. Reg. 52056 (October 15, 2018) on Monday, December 17, 2018.

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