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Letters or Comments

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.

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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. 

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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.

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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.

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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. 

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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.

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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.

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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.

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State Coalition Letter to EPA Regarding NAAQS

Wednesday, September 6, 2017

In a letter to the EPA Administrator Pruitt, 300 associations strongly urged the EPA to expeditiously reconsider the 2015 ozone standards. Representing many businesses, both large and small, that employ millions of Americans, and local governments in which those businesses thrive, the associations wrote with deep concerns about the harmful impact that the Environmental Protection Agency’s (EPA) 2015 rule, to make ozone standards the most stringent ever, could have on the economy. The letter adds that EPA’s current regulations are working, air quality continues to improve, and the United States is leading the world in reducing emissions. Therefore, implementation of the new ozone standards could needlessly and significantly damage the economy by imposing unachievable emissions limits and reduction targets on almost every part of our country, including rural and undeveloped areas.

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API Comments on Proposed Rule for RFS for 2018 and Biomass-based Diesel Volume for 2019

Thursday, August 31, 2017

API provides these comments in addition to comments submitted separately to the docket that were developed jointly with the American Fuel & Petrochemical Manufacturers (AFPM). This separate submittal to the docket contains additional information that reflects views of API and our members on issues that were not addressed in the comments submitted jointly with AFPM.

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