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Letters and Comments

API Comments on the Colorado Greenhouse Gas Pollution Reduction Roadmap

Friday, November 13, 2020

The American Petroleum Institute Colorado (API CO) submitted comments on the September 30, 2020 Public Review Draft of the Colorado Greenhouse Gas Pollution Reduction Roadmap (GHG Roadmap). API CO appreciates the work put into the draft proposal by the Colorado Energy Office (CEO) and the Air Pollution Control Division (APCD) and looks forward to working with staff to support the achievement of the state’s Greenhouse Gas (GHG) reduction targets.

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Letter From API To Commerce and Energy Secretaries and USTR On Energy Trade With China

Thursday, April 23, 2020

The letter commends federal officials for strong leadership to relieve stresses on industry during the COVID-19 crisis and encourages the administration to look to the Phase 1 trade agreement with China – under which the Chinese pledged to buy U.S. energy – as one way to help address the domestic oversupply of oil.

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Letter from API to President Trump regarding the COVID-19 response

Friday, March 20, 2020

The letter outlines the need to establish critical infrastructure personnel designations as well as temporarily waiving non-essential compliance discretion (record-keeping, non-safety critical requirements, etc.) in order to ensure compliance with CDC guidance for the health and safety of our workers.

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API Comments on NEPA Modernization

Tuesday, March 10, 2020

API submitted the following comments in support of reforming the broken NEPA process, a critical step toward meeting growing demand for cleaner energy and unlocking job-creating projects. Endless and repetitive reviews for infrastructure, renewable energy, natural gas and oil projects have been misused to delay and prevent development and undermine job creation, tax revenues and investments in communities across the country.

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API 2020 RFS Supplemental Notice Comments

Monday, December 2, 2019

API comments submitted to the EPA in response to the supplemental notice of proposed rulemaking seeking additional comment on the proposed rule to establish renewable fuel volumes for 2020 and the biomass-based diesel volume for 2021 under the Renewable Fuel Standard.

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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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