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Letters and Comments

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.

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API Comments re: EPA’s “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Reconsideration; Proposed Rule”; 83 Fed. Reg. 52056 (October 15, 2018)

Tuesday, December 18, 2018

The American Petroleum Institute submitted the attached comments regarding EPA’s reconsideration of the New Source Performance Standards (“NSPS”) 40 C.F.R. Part 60 Subpart OOOOa, “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources; Proposed Rule” at 83 Fed. Reg. 52056 (October 15, 2018) on Monday, December 17, 2018.

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API Statement at Public Hearing for EPA NSPS OOOOa

Wednesday, November 14, 2018

Senior Policy Advisor at the American Petroleum Institute Matthew Todd delivered oral comments during EPA’s public hearing on Proposed Amendments to NSPS OOOOa in Denver on November 14, 2018.

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API Comments to the Draft Resource Management Plan and Draft Environmental Impact Statement for the BLM Carlsbad Field Office, New Mexico

Monday, November 5, 2018

API has consistently supported access to natural gas and oil resources under Federal administration in a manner that allows environmentally responsible development and appropriate management and protection of habitat, wildlife and other resources. We believe this balance is achievable on the public lands that the Bureau of Land Management (BLM) administers in the CFO planning area where crude oil and natural gas resources of national and strategic significance are located.

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API comments on Affordable Clean Energy rule

Thursday, November 1, 2018

The American Petroleum Institute (“API”) provides these comments on the U.S. Environmental Protection Agency’s (“EPA’s” or “the Agency’s”) Proposed Emission Guidelines for Greenhouse Gas Emissions From Existing Electric Utility Generating Units; Proposed Revisions to Emission Guideline Implementing Regulations; and Proposed Revisions to the New Source Review Program (“Proposed ACE Rule”). API represents over 625 oil and natural gas companies. These companies are leaders of a technology-driven industry that supplies most of America’s energy, supports more than 10.3 million jobs and nearly 8 percent of the U.S. economy, and, since 2000, has invested more than $3 trillion in U.S. capital projects to advance all forms of energy, including alternatives.

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API-IPAA comments for USFS oil and gas regulations ANPRM

Friday, October 12, 2018

The American Petroleum Institute (“API”) and the Independent Petroleum Association of America (“IPAA) – hereafter, “the Associations” - are pleased to provide these comments in response to the United States Forest Service’s (“USFS”) Advance Notice of Proposed Rulemaking (“ANPRM”) to revise the contents of its Oil and Gas Resources regulations, published in the Federal Register September 13, 2018.

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API's stance on EPA draft guidance clarifying what facilities should be considered adjacent for Clean Air Act permitting purposes

Monday, October 8, 2018

The Associations included below respectfully submit the attached comments on the Environmental Protection Agency’s (EPA’s) draft guidance, “Interpreting ‘Adjacent’ for New Source Review and Title V Source Determinations in All Industries Other Than Oil and Gas.” (“draft guidance”). We support EPA’s efforts to restore the major NSR regulations and other air regulations to their proper scope, and greatly appreciate the opportunity to provide comment on the draft guidance before EPA issues a final version. We believe upfront engagement can improve the final product.

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ESA Cross-Industry Coalition on ESA Proposals

Tuesday, September 25, 2018

The Coalition endorses, and is encouraged by, the Services’ efforts to clarify and improve their ESA regulations, and to reduce duplication and inefficiency, so that the Services, the regulated communities, and the public can focus their limited resources on actions that truly improve environmental outcomes. We support many of the Services’ proposed modifications, which are consistent with the Act, its legislative history, and the case law, and reflect concerns the Coalition expressed in prior comments and litigation. There are a number of areas, however, where changes to the proposals are warranted to ensure consistency with the statute and settled precedent and to improve implementation of the Act, these areas are detailed in the submitted comments.

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