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Letters or Comments

API Comments to the DRBC on its November 30, 2017 Proposed Rulemaking on Special Regulations Regarding Natural Gas Development Activities

Friday, March 30, 2018

Comment letter and Appendix A submitted on March 30, 2018 by the American Petroleum Institute (API) on the Delaware River Basin Commission’s (DRBC’s ) notice of proposed rulemaking on Amendments to the Administrative Manual and Special Regulations Regarding Natural Gas Development Activities. These comments were submitted electronically, via the DRBC website.

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Stephanie Catarino Wissman DRBC Testimony

Tuesday, February 27, 2018

Stephanie Catarino Wissman, Executive Director, Associated Petroleum Industries of PA delivers comments during a February 22 Public Meeting of the Delaware River Basin Commission (DRBC) in Schnecksville, Pennsylvania.

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API Letter to EPA Re. RFS - Requests for Waivers and Exemptions

Tuesday, February 13, 2018

The best available remedy is for EPA to use its waiver authority to establish annual volumes that are reasonable, achievable, and fair for all RFS stakeholders. Granting individual requests for relief creates a distortion in the marketplace and threatens the integrity of the RFS program. API welcomes the opportunity to work with EPA to develop regulatory solutions to meet these goals.

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Joint Trades (API OOC NOIA) Comments - BSEE Production Safety Systems Revisions - 1014-AA37 - Docket No BSEE-2017-0008

Monday, January 29, 2018

US OCS production is vitally important to our nation’s energy security and our nation’s economy. Safety in OCS operations is a core value of the energy industry, and a value that our members put into practice each day. Therefore, the Production Safety Rule is significant because it forms the foundation by which oil and natural gas are safely and efficiently produced from the OCS.

The comments contained in this submittal are provided as recommendations to improve the proposed Production Safety Systems Rule as well as inform BSEE of potential obstacles and impacts from the revisions to the rule. The Joint Trades comments are offered without prejudice to any of our members who may have differing or opposing views.

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Joint Trades support letter for House NR offshore/onshore bill

Thursday, December 14, 2017

Joint trades letter of support for H.R. 4239, the Strengthening the Economy with Critical Untapped Resources to Expand American Energy Act (SECURE Act). API, IADC, NOIA, PESA, IPAA, AXPC, IAGC and USOGA signed onto the letter.

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Comments on the notices of data availability in support of EPA’s New Source Performance Standards (“NSPS”) 40 C.F.R. Part 60 Subpart OOOOa

Tuesday, December 12, 2017

The American Petroleum Institute submitted comments on December 8, 2017, regarding the notices of data availability in support of EPA’s 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: Stay of Certain Requirements” 82 Fed. Reg. 51,788 and 82 Fed. Reg. 51,794 (both dated November 8, 2017).

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API-IPAA Comments to BLM NOI to Amend Land Use Plans Regarding Greater Sage-Grouse Conservation

Friday, December 1, 2017

API and IPAA are pleased to submit the accompanying letter dated December 1, 2017 providing our organizations' comments to the BLM's Notice of Intent to Amend Land Use Plans Regarding Greater Sage-Grouse Conservation and Prepare Associated Environmental Impact Statements or Environmental Assessments, 82 Fed. Reg. 47248 (October 11, 2017). Thank you for considering these comments as the agency undertakes its public scoping process.

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Letter to DOI regarding BLM Regulatory Reform Measurement Rules

Friday, November 17, 2017

Letter from API for the regulatory reform docket recommending modifications to the BLM rules adopted for Site Security, Measurement of Oil and Measurement of Gas.

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API Comment on BLM Suspension of 2016 Waste Prevention Rule

Monday, November 6, 2017

BLM has the authority to delay or suspend provisions of the 2016 Rule, and BLM may take this action pursuant to notice-and-comment rulemaking procedures under the APA and principles of administrative law. Because the 2016 Rule promulgates an air emissions control regime that is beyond the BLM’s authority under the MLA, impermissibly alters longstanding principles defining the concepts of waste and avoidable loss, and is based on a fundamentally flawed evaluation of the 2016 Rule’s costs and benefits, BLM’s proposed delay and suspension of the rule is appropriate so that the agency can determine whether revisions are necessary, as well as to avoid imposing compliance costs on both industry and BLM during that review for requirements that may be substantially revised or eliminated.

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API Comments on Electronically Controlled Pneumatic Braking

Wednesday, November 1, 2017

The American Petroleum Institute submitted the following comments to the Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Federal Railroad Administration (FRA) on their update of the original regulatory impact analysis (RIA) associated with the electronically controlled pneumatic (ECP) brake provision of PHMSA's May 8, 2015, Final Rule titled “Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains” (Final Rule).

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