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Letters and Comments

API's comments on EPA's proposal to retain the current National Ambient Air Quality Standards NAAQS

Friday, September 29, 2017

API filed detailed comments on EPA’s proposal to retain the current National Ambient Air Quality Standards (NAAQS) for nitrogen oxides. Nitrogen oxides, a precursor to ground-level ozone formation, are generated by many of our industry operations, which have already spent hundreds of millions of dollars to reduce those emissions.  API’s comments concurred with the conclusion of the EPA Administrator not to change the standards, arguing that “the current body of scientific evidence and the results of quantitative analyses support the degree of public health protection provided by the current 1-hour and annual primary NO2 standards.”  API further stated that, “… the Administrator could consider whether relaxing them would be appropriate.”  EPA is expected to finalize the standards, as proposed, in 2018. 

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API Comments to the BLM on the 2015 Hydraulic Fracturing Rule

Monday, September 25, 2017

API submitted its comments to the BLM on the rescission/revocation of the agency’s 2015 hydraulic fracturing rule. The letter, and the accompanying re-submittal of the 2013 cost study that ARI performed for API, are attached.

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Catarino-Wissman letter to House Committee on HB 113

Monday, September 11, 2017

As the Pa. House’s ERE committee is scheduled to consider HB 113, that would impose a 3.5 percent natural gas severance tax on top of the impact tax, API-PA sent a letter to the House detailing natural gas industry opposition to the tax that will ultimately raise costs on consumers.

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Hurricane Experts Press Call Transcript

Friday, September 8, 2017

The call was led by API’s President and CEO, Jack Gerard. He was joined by a leading energy expert, Guy Caruso, who’s a senior and national security advisor at the CSIS, Center for Strategic and International Studies, and Bob McNally with the Rapidan Group, a fellow – and also a fellow at the Columbia University Center on Global Energy Policy, and former international and domestic energy advisor in the Bush Administration.

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State Coalition Letter to EPA Regarding NAAQS

Wednesday, September 6, 2017

In a letter to the EPA Administrator Pruitt, 300 associations strongly urged the EPA to expeditiously reconsider the 2015 ozone standards. Representing many businesses, both large and small, that employ millions of Americans, and local governments in which those businesses thrive, the associations wrote with deep concerns about the harmful impact that the Environmental Protection Agency’s (EPA) 2015 rule, to make ozone standards the most stringent ever, could have on the economy. The letter adds that EPA’s current regulations are working, air quality continues to improve, and the United States is leading the world in reducing emissions. Therefore, implementation of the new ozone standards could needlessly and significantly damage the economy by imposing unachievable emissions limits and reduction targets on almost every part of our country, including rural and undeveloped areas.

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API Comments on Proposed Rule for RFS for 2018 and Biomass-based Diesel Volume for 2019

Thursday, August 31, 2017

API provides these comments in addition to comments submitted separately to the docket that were developed jointly with the American Fuel & Petrochemical Manufacturers (AFPM). This separate submittal to the docket contains additional information that reflects views of API and our members on issues that were not addressed in the comments submitted jointly with AFPM.

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API-IAGC Comments on NMFS Regulatory Review

Monday, August 28, 2017

This letter provides the comments of the American Petroleum Institute (“API”) and the International Association of Geophysical Contractors (“IAGC”) (the “Associations”) in response to the National Oceanic and Atmospheric Administration’s (“NOAA”) request for public input on actions the National Marine Fisheries Service (“NMFS”) and the National Ocean Service (“NOS”) should take to streamline their regulatory processes and reduce burdens on the regulated community.

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Comments in Response to the U.S. Army Corp of Engineers (Corps) Proposed Rule Titled “Use of U.S. Army Corps of Engineers Reservoir Projects for Domestic, Municipal and Industrial Water Supply”

Friday, August 18, 2017

API and the National Association of Home Builders (“NAHB”) submitted joint comments on the Department of the Army, U.S. Army Corp of Engineers (Corps) proposed rule titled “Use of U.S. Army Corps of Engineers Reservoir Projects for Domestic, Municipal and Industrial Water Supply” (“proposed rule”). We support cooperation among the States and the Corps to facilitate water supply uses of Corps’ reservoirs consistent with the authorized purposes of those reservoirs. However, a number of states and water management authorities have noted that the proposed rule was developed without following key stakeholder processes - including sufficient state coordination to avoid interference with state primacy in determining allocation or management of state water. We therefore request that the Corps withdraw this proposed rule, conduct the appropriate stakeholder engagement and resubmit a new proposed rule for public comment prior to finalization.

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Coalition Letter to BOEM regarding the 2019-2024 Five-Year Offshore Leasing Program

Thursday, August 17, 2017

Coalition letter to the Bureau of Ocean Energy Management regarding the preparation of the 2019-2024 Five-Year Offshore Leasing Program. It urges a true all-of-the-above energy policy by allowing for more leasing, exploration and development of potential U.S. offshore oil and natural gas resources. If more areas are opened to offshore exploration and development, the resulting economic activity and energy production could benefit the nation.

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Comments on Preparation of 2019-2024 Outer Continental Shelf Oil and Gas Leasing Program

Thursday, August 17, 2017

API submitted its comments to the Department of Interior in response to a request for information on the 2019-2024 Offshore Leasing Program and was joined by the National Ocean Industries Association, Independent Petroleum Association of America, U.S. Oil and Gas Association, American Exploration & Production Council, International Association of Geophysical Contractors, Petroleum Equipment Suppliers Association, and the Alaska Oil and Gas Association.

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