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Letters and Comments

API Comments on Proposed 2020 RFS Standards

Tuesday, September 3, 2019

API provided the following comments and policy brief in response to the EPA's proposed 2020 biofuel obligations under the Renewable Fuel Standard. 

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API MSC PIOGA Letter to Governor Wolf

Friday, July 26, 2019

Our industry is deeply committed to protecting the health, safety and environment of our communities and our workforce. We support Governor Wolf’s efforts for further, objective scientific research. Health and safety are priorities of this industry. We are committed to protecting the safety and health of our employees, our contractors and the people of the communities in which we operate.

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API Comments to OSHA for July 2019 United Nations GHS Sub-Committee Meeting

Wednesday, June 19, 2019

On June 19, 2019, API submitted the attached comments to OSHA on various papers and correspondence groups which will be discussed/meet at the July 2019 United Nations GHS Sub-Committee meeting, including:

  • Next steps on development of a global list of chemicals classified in accordance with the GHS;
  • The use of non-animal test methods for classification of health hazards (e.g., eye irritation); and
  • Consideration of opportunities that digitalization may bring to convey hazard information.

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API Submits Comments on Proposed Revision to Obama-Era MATS rule

Friday, May 3, 2019

API led a coalition effort to submit comments on April 17 on the EPA proposal to scrap its cost-benefit finding that justified the Obama-era Mercury and Air Toxics Standards (MATS) for Power Plants final rule. The agency is planning to reverse its designation of the power plant air toxics standards as “appropriate and necessary” by discounting the rule’s “co-benefits” of reducing fine particulate matter (PM) pollution.  Those PM co-benefits were estimated to be responsible for the bulk of the rule’s environmental gains, even though the rule does not directly regulate PM.  The approach to calculate the benefits in this revised rule may set precedent as to how EPA will count the “co-benefits” of reducing pollutants in future rulemakings affecting other industries.

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API Letter to DOI on Financial Assurance

Thursday, April 25, 2019

API submitted a letter to the DOI regulatory reform docket regarding BOEM’s approach to contingent liability for decommissioning. As the Department of the Interior (DOI) revises its Bonding and Financial Assurance regulations pursuant to Executive Order 13785 and DOI Secretarial Order 3350, its main goals should be to adopt regulations and implement policies that keep people safe, protect the environment, and ensure that U.S. taxpayers are not left with any OCS decommissioning obligations. A predictable process that requires financial security from the current lease owner, based upon a fair assessment of capacity and risk, provides the financial assurance needed to protect the taxpayer, while also holding current lease owners accountable to fulfill their obligations.

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Comments of the API, IPAA, the AEPC and AOPL in Response to the Environmental Protection Agency’s and the Army Corps of Engineers’ Proposed Rule to Define “Waters of the United States.”

Tuesday, April 16, 2019

We believe that the Proposed WOTUS Rule reflects careful consideration of the Agencies’ prior interpretations, the broad guideposts provided by the United States Supreme Court (“Supreme Court” or the “Court”), and a genuine interest in developing an interpretation of WOTUS that is clear, protective of the environment and human health, administrable, and legally sound.  Our comments include a detailed executive summary - with our discussion points and requests outlined in a “table of contents” format.  Additionally, we are pleased to share a recent study commissioned from ERM NC, Inc. (“ERM”) that demonstrates that the benefits of the Proposed WOTUS Rule will exceed its costs under any reasonably foreseeable scenario.

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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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