Letters and Comments
API Comments re: EPA’s “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Reconsideration; Proposed Rule”; 83 Fed. Reg. 52056 (October 15, 2018)
Tuesday, December 18, 2018
The American Petroleum Institute submitted the attached comments regarding EPA’s reconsideration of the 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; Proposed Rule” at 83 Fed. Reg. 52056 (October 15, 2018) on Monday, December 17, 2018.
API Statement at Public Hearing for EPA NSPS OOOOa
Wednesday, November 14, 2018
Senior Policy Advisor at the American Petroleum Institute Matthew Todd delivered oral comments during EPA’s public hearing on Proposed Amendments to NSPS OOOOa in Denver on November 14, 2018.
API Comments to the Draft Resource Management Plan and Draft Environmental Impact Statement for the BLM Carlsbad Field Office, New Mexico
Monday, November 5, 2018
API has consistently supported access to natural gas and oil resources under Federal administration in a manner that allows environmentally responsible development and appropriate management and protection of habitat, wildlife and other resources. We believe this balance is achievable on the public lands that the Bureau of Land Management (BLM) administers in the CFO planning area where crude oil and natural gas resources of national and strategic significance are located.
API comments on Affordable Clean Energy rule
Thursday, November 1, 2018
The American Petroleum Institute (“API”) provides these comments on the U.S. Environmental Protection Agency’s (“EPA’s” or “the Agency’s”) Proposed Emission Guidelines for Greenhouse Gas Emissions From Existing Electric Utility Generating Units; Proposed Revisions to Emission Guideline Implementing Regulations; and Proposed Revisions to the New Source Review Program (“Proposed ACE Rule”). API represents over 625 oil and natural gas companies. These companies are leaders of a technology-driven industry that supplies most of America’s energy, supports more than 10.3 million jobs and nearly 8 percent of the U.S. economy, and, since 2000, has invested more than $3 trillion in U.S. capital projects to advance all forms of energy, including alternatives.
API-IPAA comments for USFS oil and gas regulations ANPRM
Friday, October 12, 2018
The American Petroleum Institute (“API”) and the Independent Petroleum Association of America (“IPAA) – hereafter, “the Associations” - are pleased to provide these comments in response to the United States Forest Service’s (“USFS”) Advance Notice of Proposed Rulemaking (“ANPRM”) to revise the contents of its Oil and Gas Resources regulations, published in the Federal Register September 13, 2018.
API's stance on EPA draft guidance clarifying what facilities should be considered adjacent for Clean Air Act permitting purposes
Monday, October 8, 2018
The Associations included below respectfully submit the attached comments on the Environmental Protection Agency’s (EPA’s) draft guidance, “Interpreting ‘Adjacent’ for New Source Review and Title V Source Determinations in All Industries Other Than Oil and Gas.” (“draft guidance”). We support EPA’s efforts to restore the major NSR regulations and other air regulations to their proper scope, and greatly appreciate the opportunity to provide comment on the draft guidance before EPA issues a final version. We believe upfront engagement can improve the final product.
ESA Cross-Industry Coalition on ESA Proposals
Tuesday, September 25, 2018
The Coalition endorses, and is encouraged by, the Services’ efforts to clarify and improve their ESA regulations, and to reduce duplication and inefficiency, so that the Services, the regulated communities, and the public can focus their limited resources on actions that truly improve environmental outcomes. We support many of the Services’ proposed modifications, which are consistent with the Act, its legislative history, and the case law, and reflect concerns the Coalition expressed in prior comments and litigation. There are a number of areas, however, where changes to the proposals are warranted to ensure consistency with the statute and settled precedent and to improve implementation of the Act, these areas are detailed in the submitted comments.
API CEO NOPEC Letter
Wednesday, August 22, 2018
On August 22, 2018, the American Petroleum Institute (API) sent a letter to the Chairman and Ranking Members of the House and Senate Judiciary Committees opposing House and Senate NOPEC legislation (H.R. 5904 and S. 3214), No Oil Producing and Exporting Cartels (NOPEC) Acts of 2018, currently under consideration by these committees. Industry sees these bills as creating significant detrimental exposure to US diplomatic, military and business interests while having limited impact on the market concerns driving the legislation.