Letters and Comments
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.
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.
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).
API joint comments on DOE's proposed rulemaking on grid reliability
Monday, October 23, 2017
October 23, 2017 — A diverse group of 12 energy industry associations representing oil, natural gas, wind, solar, efficiency, and other energy technologies today submitted comments to the Federal Energy Regulatory Commission (FERC) in response to the Department of Energy’s (DOE) proposed rulemaking on grid resiliency pricing. In joint comments, this broad group of energy industry associations urged FERC not to adopt DOE’s proposed rule to provide out-of-market financial support to uneconomic coal and nuclear power plants in the wholesale electricity markets overseen by FERC.
API comments to FERC on DOE's Grid Reliability Proposed Rule
Monday, October 23, 2017
October 23, 2017 - API filed comments with the Federal Energy Regulatory Commission on the Department of Energy's notice of proposed rule making on grid reliability and resilience pricing.
API Comments on NODA concerning potential reductions in Volume Requirements under RFS
Thursday, October 19, 2017
API Comments regarding EPA–HQ– OAR–2017–0091 - Notice of Data Availability Concerning Potential Reductions in the Volume Requirements for 2018 Renewable Fuel and 2019 Biomass-Based diesel under the Renewable Fuels Standard Program.
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.
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.
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.
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.