Letters and Comments
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.
API CEO NOPEC Letter
Wednesday, August 22, 2018
On August 22, 2018, the American Petroleum Institute (API) sent a letter to the Chairman and Ranking Members of the House and Senate Judiciary Committees opposing House and Senate NOPEC legislation (H.R. 5904 and S. 3214), No Oil Producing and Exporting Cartels (NOPEC) Acts of 2018, currently under consideration by these committees. Industry sees these bills as creating significant detrimental exposure to US diplomatic, military and business interests while having limited impact on the market concerns driving the legislation.
API comments: EPA proposed 2019 RVOs
Friday, August 17, 2018
As the EPA prepares its final volumes for 2019 under the Renewable Fuel Standard (RFS) mandate, API reminds policymakers that this mandate is broken and should be repealed or significantly reformed. In the meantime, we urge the EPA to keep RFS volumes at a low enough level to avoid a potential breach of the blend wall. Read API’s full comments to the EPA.
API press conference: 2019 EPA proposed RVOs under the Renewable Fuel Standard
Thursday, August 16, 2018
Good morning and thank you for joining our call.
As the EPA prepares the final volumes for 2019 under the RFS mandate, we remind policymakers that this mandate is broken and should be repealed or significantly reformed. In the meantime, API urges the EPA to keep RFS volumes at a low enough level to avoid a potential breach of the blend wall …
API Comments on Proposed Rule: Strengthening Transparency in Regulatory Science
Thursday, August 16, 2018
API supports the use of sound science as a critical component in public policy. Data and analyses used in establishing and evaluating environmental, health, welfare and economic impacts should be transparent and reproducible and available as early as possible in the rulemaking process, to the extent possible and consistent with the protection of other compelling interests. Transparency and reproducibility should also apply to underlying data and information, such as environmental and economic impact data and models that are utilized to predict costs, benefits, market impacts and/or environmental and health effects of specific regulatory interventions.
API Comments on Proposed Determination of Action Pursuant to Section 301
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.
API Comments Supporting The WOTUS Recodification
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).
Comments on the proposed changes to the BSEE Well Control Rule
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.’’
API Letter to DOI Secretary Zinke on DOI Reorganization
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.