Letters and Comments
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.
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.
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.
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.
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.
Friday, February 22, 2019
API submits comments to U.S. Army Corps of Engineers urging support for Enbridge Line 3 permit.
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.
Tuesday, January 29, 2019
Enbridge Line 3 Replacement Project and predictability of Minnesota’s regulatory processes.
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.
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.