Letters and Comments
API and IPAA Statement for the Record to BLM's Planning 2.0 Initiative (June 21, 2016)
Wednesday, June 22, 2016
API and IPAA issued the joint letter to note our concern that a process redesigned by the Proposed Planning Rule would disfavor multiple use interests, including the development of oil and natural gas resources on public lands, by potentially subjecting each step in the process to a new round of objections by parties committed to opposition of resource development. The overhauled resource management planning process that the Proposed Planning Rule envisions would lead to regulatory and legal uncertainty, delays, and costs.
API-IPAA Letter to BLM regarding proposed public lands rule (May 25, 2016)
Wednesday, May 25, 2016
The American Petroleum Institute (API) and Independent Petroleum Association of America (IPAA) appreciate the opportunity to comment on BLM’s proposed Resource Management Planning Rule appearing at 81 Fed. Reg. 9674, February 25, 2016 (hereafter, the “Proposed Planning Rule”).
Jack Gerard letter to House regarding H.R. 4909 (May 18, 2016)
Wednesday, May 18, 2016
The American Petroleum Institute (API) strongly supports Section 1090 of H.R. 4909, the Fiscal Year 2017 National Defense Authorization Act, which will streamline the Department of Energy regulatory process to consider liquefied natural gas (LNG) export permits.
Industry comments on the DPEIS Oil and Gas Leasing Program: 2017 – 2022, submitted May 2, 2016
Wednesday, May 4, 2016
The American Petroleum Institute (API), National Ocean Industries Association (NOIA), Independent Petroleum Association of America (IPAA), U.S. Oil and Gas Association (USOGA), International Association Of Geophysical Contractors (IAGC), Alaska Oil and Gas Association (AOGA) (collectively, the Associations) offer the following on the Bureau of Ocean Energy Management’s (BOEM’s) Draft Programmatic Environmental Impact Statement (DPEIS) on the Outer Continental Shelf (OCS) Oil and Gas Leasing Program: 2017 – 2022 released March 18, 2016.
API Comments to FERC re Docket No. EL16-49-000 (April 11, 2016)
Monday, April 11, 2016
Motion to Intervene and comments of American Petroleum Institute. Pursuant to Rules 212 and 214 of the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) Rules of Practice and Procedure,1 American Petroleum Institute (“API”) hereby moves to intervene and submit comments in support of the complaint filed in the above-referenced docket on March 21, 2016 (the “Complaint”) and urges the Commission to grant it.
Joint Industry Letter to Administrator Shelanski on BSEE Blowout Preventer Systems and Well Control Rule (April 8, 2016)
Friday, April 8, 2016
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 appreciate the opportunity on March 21, 2016, to meet with representatives from OIRA and other federal agencies regarding the proposed rule from the Bureau of Safety and Environmental Enforcement (BSEE) addressing offshore Blowout Preventer Systems and Well Control.
API Comments to FERC re Docket No. RM16-5-000 (April 4, 2016)
Monday, April 4, 2016
Pursuant to the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) January 21, 2016 Notice of Proposed Rulemaking (“NOPR”) in the subject docket, the American Petroleum Institute (“API”) hereby submits comments regarding offer caps in markets operated by Regional Transmission Organizations (“RTOs”) and Independent System Operators (“ISOs”). API responds here to selected topics from the NOPR but reserves the right to comment on remaining issues as relevant in this docket. Though API references a few RTOs/ISOs as examples, these comments are meant to apply generally to all RTOs and ISOs under FERC jurisdiction.
Amy Farrell Letter to Burgess re Draft Supplemental Environmental Impact Statement (March 31, 2016)
Thursday, March 31, 2016
The American Petroleum Institute (API) appreciates this opportunity to comment on the Draft Supplemental Environmental Impact Statement (DSEIS) in the aforementioned cases and would like to submit the following respecting the discussions on natural gas and fuel diversity.
Marty Durbin Letter to Rob Klee re DEEP-BETP RFP for natural gas capacity (March 29, 2016)
Tuesday, March 29, 2016
The American Petroleum Institute (API) appreciates this opportunity to comment on the Department of Energy and Environmental Protection’s (DEEP) RFP for natural gas capacity, liquefied natural gas (LNG), and natural gas storage procurement. While API has no comment on the specific terms of the RFP, we would like to express our support for the use of the types of agreements envisioned by the RFP to support development of necessary pipeline infrastructure as and ensure reliable gas delivery for power generation.
Marty Durbin Letter to Mark Marini re DPU 16-05 (March 10, 2016)
Thursday, March 10, 2016
The American Petroleum Institute (API) appreciates this opportunity to comment on National Grid’s natural gas transportation agreement with Algonquin Gas Transmission Company for firm transportation and storage capacity on their Access Northeast project (“ANE project”). While API has no comment on the specific terms of the agreement, we would like to express our support for the use of these types of agreements to support the development of necessary pipeline infrastructure as a mechanism for ensuring reliable gas delivery for power generation.