Erik Milito letter to DOE regarding Oil and Gas; Hydraulic Fracturing on Federal and Indian Lands (August 23, 2013)
The American Petroleum Institute (“API”) appreciates the opportunity to comment on the supplemental notice published by the Bureau of Land Management (“BLM”) on May 24, 2013, regarding a revised proposed rule to regulate hydraulic fracturing on federal and Indian lands. These comments address technical and legal deficiencies with the proposed rule, as well as its significant potential implications for the U.S. economy through its attempt to apply unjustified new regulations to an already effectively regulated activity. While the revised proposed rule makes several improvements upon the May 2012 original proposed rule, many shortcomings remain and the BLM should not finalize the rule as currently proposed.Downloads
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