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Letters and Comments

API Coalition Comments to DOE on Coal and Nuclear Plant Bailouts

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.

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Submittal of API Comments to BLM Waste Prevention Rule RIN 1004-AE53

Monday, April 23, 2018

With this comment letter, submitted on April 23, 2018, API supports the Proposed Rule, which would significantly improve upon BLM’s 2016 effort to regulate venting and flaring of gas from BLM and Indian lands (“2016 Rule”), and more properly reflect the principles of the previously-applicable 1979 Notice to Lessees and Operators of Onshore Federal and Indian Oil and Gas Leases, Royalty or Compensation for Oil and Gas Lost (“NTL-4A”). The Proposed Rule also properly reflects that the MLA authorizes venting and flaring restrictions for the sole purpose of preventing “undue waste” of federal mineral resources. See 30 U.S.C. §§ 187 & 225. The Proposed Rule would incorporate into regulation the lease-specific concept of “waste” as intended by Congress when enacting the MLA, and incorporated by the Department into its oil and gas leases and regulations from the inception of its oil and gas leasing program.

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API Comments on EPA's Proposed Withdrawal of CTGs for Oil and Gas Sector

Monday, April 23, 2018

API submitted the attached comments to the docket ( on the EPA’s Notice of Proposed Withdrawal of the Control Techniques Guidelines for the Oil and Natural Gas Industry, published at 83 FR 10478 on March 9, 2018.

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API letter to President Trump on use of DOE's emergency authority to keep FirstEnergy's coal and nuclear plants open

Friday, April 13, 2018

API letter to President Trump on use of DOE's emergency authority to keep FirstEnergy's coal and nuclear plants open.

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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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