Letters or Comments
Tuesday, August 14, 2018
August 13, 2018 – API letter to U.S. Trade Representative (USTR) Lighthizer commenting on Proposed Determination of Action Pursuant to Section 301: China's Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation; Docket No. USTR-2018-0026
Comment on the U.S. Environmental Protection Agency’s Advanced Notice of Proposed Rulemaking on “Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process” (83 Fed. Reg. 27,524 (June 13, 2018)
Tuesday, August 14, 2018
Responsible public policy should rely on a more rational prioritization of resources that is informed by a meaningful weighing of compliance burdens against the risks in full consideration of the uncertainty associated with those risks. In our attached comments, API supports EPA’s interest in improving the consistency and transparency of its calculation and consideration of regulatory costs and benefits. These economic considerations, which are required in numerous statutes and executive orders, were mandated precisely for the purpose of improving the efficacy of environmental regulation and the allocation of both industry and Agency resources. Efforts to improve the consistency and transparency of these analyses should not, therefore, be viewed as an effort to abandon the Agency’s pursuit of improved environmental outcomes – nor has API ever advocated for such a result. This ANPRM is a critical step toward improved regulatory processes.
Monday, August 13, 2018
API filed the attached comments supporting the WOTUS recodification, in response to the supplemental proposal published in July 2018. Our comments were filed jointly with IPAA, the New Mexico Oil and Gas Association (NMOGA), and the Ohio Oil and Gas Association (OOGA).
Tuesday, August 7, 2018
The American Petroleum Institute (API), the International Association of Drilling Contractors (IADC), the Independent Petroleum Association of America (IPAA), the National Ocean Industries Association (NOIA), the Offshore Operators Committee (OOC), the Petroleum Equipment & Services Association (PESA), and the US Oil and Gas Association respectfully submit the following comments on the proposed regulatory revisions to Blowout Preventer Systems and Well Control requirements in 30 C.F.R. part 250. The Bureau of Safety and Environmental Enforcement (BSEE) published these proposed changes on May 11, 2018, in a notice of proposed rulemaking entitled, ‘‘Oil and Gas and Sulphur Operations in the Outer Continental Shelf—Blowout Preventer Systems and Well Control Revisions.’’
Monday, August 6, 2018
The American Petroleum Institute and its members are committed to the continued development of U.S. oil and natural gas resources and in working with the U.S. Department of the Interior to produce the energy Americans rely upon every day from federally managed lands. We appreciate and support efforts to modernize and reorganize the Department in order to improve governance, streamline permitting and approvals, and improve coordination of government services so that unnecessary barriers to oil and natural gas development are minimized and eliminated.
Wednesday, June 27, 2018
The American Petroleum Institute signed an association letter in support of Senator Corker’s legislation to add congressional oversight on harmful tariffs on the basis on national security concerns.
Tuesday, June 26, 2018
Letter to the Governors on Zero Emission Vehicles (ZEV) Incentives
Friday, June 22, 2018
The industry strongly believes that Treasury regulations for the BEAT should be written to ensure the net operating loss add back required under the BEAT is determined based on the base erosion percentage in the year the NOL arose, and the BEAT add back for pre-TJCA losses carried into a post-TCJA year should be zero, and finally the use of a pre-2018 NOLs going forward should not be treated as a BEAT payment and are distinguishable from pre-2018 interest deductions deferred under section 163(j).
Friday, May 18, 2018
API along with other trade associations submitted comments to the docket in response to the Interim Final Rule (IFR) on relief for the oil and natural gas industry from tariffs and quotas on steel imports.
Monday, May 7, 2018
(Washington, D.C.) – An unusual coalition representing natural gas, power, renewable energy and energy efficiency industry associations submitted a legal analysis to the Department of Energy (DOE) late Monday opposing federal use of emergency authority to provide a long-term subsidy for aging and uneconomic power plants that would otherwise retire. Such federal action is under consideration following a request from FirstEnergy Solutions (FES), an owner of power plants now in bankruptcy proceedings.