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Letters and Comments

API Letter: Response to RFA Request to Investigate RIN Markets

Friday, August 19, 2016

API Downstream Group Director Frank Macchiarola's letter to Commodity Futures Trading Commission Chairman Timothy Massad and Environmental Protection Agency Administrator Gina McCarthy responding to the Renewable Fuels Association's request to investigate Renewable Identification Number (RIN) markets.

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API Letter to Administrator McCarthy on SAB Review Report

Friday, August 12, 2016

API President and CEO Jack Gerard letter to EPA Administrator Gina McCarthy regarding the EPA’s Scientific Advisory Board response report requesting additional data to support EPA’s five-year, multi-million dollar study confirming that hydraulic fracturing is safe.

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Comments concerning Preliminary 2016 Effluent Guidelines Program Plan

Wednesday, July 27, 2016

The American Petroleum Institute (API) appreciates the opportunity to provide comments on the Environmental Protection Agency’s (EPA’s) preliminary 2016 effluent guidelines plan.

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API-IAGC Comments on the Draft Ocean Noise Strategy Roadmap (July 18, 2016)

Tuesday, July 19, 2016

We write on behalf of the American Petroleum Institute (“API”) and the International Association of Geophysical Contractors (“IAGC”) (together, the “Associations”) to provide our collective comments on the recently circulated draft Ocean Noise Strategy Roadmap (“ONS Roadmap”).

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API Comments to EPA on Renewable Fuel Standard Program: Standards for 2017 and Biomass-Based Diesel Volume for 2018 (July 11, 2016)

Tuesday, July 12, 2016

API appreciates the opportunity to comment on the proposed rulemaking for the 2017 Renewable Fuels Standard (RFS). As refiners and importers of transportation fuels, our member companies are obligated parties under the RFS program and subject to its requirements. The RFS mandate is unworkable, and API leads a chorus of diverse interests call on Congress to repeal it.

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Comments of API on Notice of Proposed Rulemaking: Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines (Submitted on July 7, 2016)

Friday, July 8, 2016

The American Petroleum Institute (API) appreciates the opportunity to submit comments in response to the Notice of Proposed Rulemaking (NPRM) issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA or Agency) on April 8, 2016, in the above-referenced proceeding. API members are dedicated to a risk-based approach to pipeline safety—one that strives for continuous improvement through addressing known, quantifiable issues. Significantly, that is the same approach that Congress has used over the decades in its directives to the Department of Transportation (DOT) and PHMSA for regulating pipeline safety. API acknowledges PHMSA for issuing this NPRM and responding to outstanding congressional mandates and National Transportation Safety Board (NTSB) and U.S. Government Accountability Office (GAO) recommendations.

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API Comments to FWS for Revisions to Regulations for Eagle Take Permits (July 5, 2016)

Tuesday, July 5, 2016

The American Petroleum Institute (API) submits these comments on the U.S. Fish and Wildlife Service’s (FWS or “the Service”) proposed revisions to its Regulations for Eagle Incidental Take and Take of Eagle Nests (81 FR 27933, May 6, 2016).

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Trade Associations Support Energy and Conservation Act of 2016 (June 30, 2016)

Thursday, June 30, 2016

On behalf of the oil and natural gas industry and the diverse companies both small and large that support the industry, we write to express our support for the American Energy and Conservation Act of 2016, which will enhance and secure revenue sharing programs for states that host energy production activities within their borders, off their shores, or both.  We commend your efforts to put forward this important legislation and respectfully ask that your fellow Senators join you in support of this bill.

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API and IPAA Statement for the Record to BLM's Planning 2.0 Initiative (June 21, 2016)

Wednesday, June 22, 2016

API and IPAA issued the joint letter to note our concern that a process redesigned by the Proposed Planning Rule would disfavor multiple use interests, including the development of oil and natural gas resources on public lands, by potentially subjecting each step in the process to a new round of objections by parties committed to opposition of resource development. The overhauled resource management planning process that the Proposed Planning Rule envisions would lead to regulatory and legal uncertainty, delays, and costs.

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API-IPAA Letter to BLM regarding proposed public lands rule (May 25, 2016)

Wednesday, May 25, 2016

The American Petroleum Institute (API) and Independent Petroleum Association of America (IPAA) appreciate the opportunity to comment on BLM’s proposed Resource Management Planning Rule appearing at 81 Fed. Reg. 9674, February 25, 2016 (hereafter, the “Proposed Planning Rule”).

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