Organisation Name
American Petroleum Institute (API)
InfluenceMap Query
GHG Emission Standards
Data Source
Legislative Consultations
 
 

Score for this Data / Query Cell

-1.64

InfluenceMap has researched and collated the following pieces of evidence associated with the data source and query indicated above. Extraordinary information is indicated by a coloured flag in the upper right corner. Evidence items in order of data inputted with exceptional items first.

 

Opposing GHG emissions standards

InfluenceMap Comment:

Directly advocating to policy makers to oppose GHG emissions standard. (Evidence from joint statement submitted during the EPA's consultation on 'Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units, December 2014)

Extract from Source:

EPA is proposing this rulemaking as a key component of the President’s Climate Action Plan, which identifies a wide range of actions that the administration is implementing to address the challenges of climate change. In proposing to achieve greenhouse gas (“GHG”) emission reductions from existing electricity generating units (“EGUs”) in the proposed ESPS, however, EPA for the first time in the more than 40 year history of the Clean Air Act (“CAA”) is bootstrapping unprecedented, newfound legal powers onto its existing legal authority without the necessary legislative amendment. This self-enacted authorization would elevate the Agency to the most influential and pervasive federal regulator of not just the environment, but the generation, distribution, and utilization of electricity in the nation. Such a role reaches far beyond the bounds of the CAA, and the very mission of EPA as an agency established to reduce air pollution and not as a regulator of the nation’s electricity grid.

Created: 03/06/2015 Last edited: 01/09/2016

 

Opposing GHG emissions standards

InfluenceMap Comment:

Supporting stay and continued review of new source performance standards (NSPS) for the oil and gas sector (API, letter to EPA Administrator Scott Pruitt, August 2017)

Extract from Source:

API previously submitted comments on the legal authorities the United States Environmental Protection Agency (“EPA” or “Agency”) possesses to issue a two-year stay of these provisions. These comments expand further on some of the technical issues and challenges industry would face in the absence of staying the provisions. [...] API encourages EPA to proceed with its review and revision of the underlying rule as expeditiously as possible, based on sound science and economics, considering the operational and technical issues that have already been raised in comments and litigation.

Created: 14/11/2017 Last edited: 15/11/2017

 

Opposing GHG emissions standards

InfluenceMap Comment:

Calling for repeal of Bureau of Land Management methane regulations (API, Joint letter to US senate, repeal BLM methane rule, February 2017)

Extract from Source:

Western Energy Alliance, the Colorado Oil & Gas Association, and the Colorado Petroleum Council strongly support the use of the Congressional Review Act to overturn the Bureau of Land Management’s (BLM) Waste Prevention, Production Subject to Royalties, and Resource Conservation Rule, otherwise known as BLM’s methane rule. [...] Furthermore, the BLM methane rule is a usurpation of air quality regulatory authority by BLM. Congress gave EPA and states authority to regulate air quality under the Clean Air Act (CAA), not BLM. BLM’s rule largely contains CAA-like provisions, and much of its purported value are in the form of monetized air quality benefits. As a land management agency, BLM lacks not only the statutory authority but the resources and expertise to regulate air quality.

Created: 14/11/2017 Last edited: 14/11/2017

 

Not supporting GHG emissions standards

InfluenceMap Comment:

Supporting US EPA's move to losen requirements associated with methane emissions standards, advocating for further roll backs (API, Comment of OIl and Natural Gas Sector: Emissions Standards for New, Reconsturcted, and Mofidfied Sources Reconsideration, December 2018)

Extract from Source:

API supports EPA’s reconsideration of the rule and appreciates the proposed changes that provide additional clarity for our industry to maintain compliance. However, the proposed rule includes several missed opportunities and, in many circumstances, has increased the stringency of the rules without securing additional environmental benefit. Overly burdensome recordkeeping and reporting, overlapping regulatory requirements with state leak detection and repair programs, and a reinterpretation of several important aspects of the rule are all examples where further improvement is warranted to balance compliance assurance with securing emissions reductions. [...] We hope that EPA continues to significantly streamlines this process in the final rule. The rule also fails to reduce the burden of overlapping regulatory requirements that have no environmental benefit.

Created: 16/01/2019 Last edited: 16/01/2019

 

Opposing GHG emissions standards

InfluenceMap Comment:

Directly supporting roll-backs related to the BLM methane emission regulation (API, Comment on BLM Waste Prevention, April 2018)

Extract from Source:

Unlike the 2016 Rule, which impermissibly sought to achieve air quality and climate change enhancement goals in the guise of “waste” prevention,2 API supports the Proposed Rule’s recognition that air quality and methane regulation are beyond BLM’s statutory purview.3Pursuant to the Clean Air Act’s comprehensive regulatory scheme, regulation of air quality and methane is the exclusive province of EPA and the states, and neither the Mineral Leasing Act of 1920 (“MLA”), nor the Federal Land Policy and Management Act (“FLPMA”), give BLM authority to regulate air emissions associated with venting and flaring from existing or future wells. Many of the requirements BLM proposes to remove from the current regulations do not reduce waste of oil or gas, and some even increase waste by forcing operators to utilize additional marketable gas for flares to control emissions[...]ordingly,API supports theProposed Rule’s reinstatement ofBLM’s pre-2016 understanding that, in thecontext of venting and flaring, “waste” is an avoidable loss of oil and gaswhere thecost ofcapture exceeds the lost economic value of the production, and that the agency may not imposeon diligent operators requirements thatcost morethan the economic value of the resources theyare requiredto conserve

Created: 16/01/2019 Last edited: 16/01/2019

 

Opposing GHG emissions standards

InfluenceMap Comment:

Directly advocating to policy makers to oppose federal methane emissions standards (API Public Hearing Statement on Oil and Gas Rulemakings, July 2017)

Extract from Source:

First, even as US oil and natural gas production has surged, methane emissions have declined significantly. [...] Second, throughout the development of the 2012 oil and gas NSPS rule and its amendments in 2016, API has maintained a collaborative working relationship with EPA staff to provide operational and emissions data to inform the developments of these important rules. During this time, our objective has remained the identification of cost-effective emission control requirements that reduce VOC emissions for new sources and, as a co-benefit, also reduce methane. This approach, when combined with the leadership the industry has demonstrated to voluntarily reduce emissions from existing sources, has already proven effective. [...] EPA’s 2012 rule, which directly reduces VOC emissions from oil and gas operations and those of methane as a co-benefit, was developed in collaboration with industry, is based upon industry innovation, and is proving effective. Unfortunately, as described in detail in our comments on the proposed rule, EPA’s 2016 rule failed to account for all of the costs associated with the final rule requirements and did not provide significant environmental benefit beyond a rule focused on VOC losses. To close, API and its members recognize the importance of developing oil and gas resources responsibly. However, the last thing we need are more duplicative and costly regulations that could increase the cost of energy for Americans, undermine our competitiveness, and hinder our ability to provide the energy our nation will continue to demand for many years to come.

Created: 01/08/2017 Last edited: 14/11/2017

 

Opposing GHG emissions standards

InfluenceMap Comment:

Supporting stay and continued review of oil and gas new source performance standards (NSPS) (API, letter to EPA Administrator Scott Pruitt, August 2017)

Extract from Source:

Below, we highlight three of the key regulations which we urge EPA to review: oil and gas New Source Performance Standards (NSPS), Renewable Fuels Standards (RFS) and Ozone National Ambient Air Quality Standards (NAAQS) implementation. [...] First, regarding the oil and gas final NSPS rule issued last year,1 API submitted a detailed petition for administrative reconsideration of the final rule to Administrator McCarthy in August, 2016. The previous 2012 standards and innovation are already effectively reducing emissions. We are encouraged by EPA’s April 4, 2017 announcement to review the 2016 standards,2 and API supports a full review of all elements of the rule and the revision of the standards. Additionally, we recommend that EPA act quickly to extend the rapidly approaching compliance deadlines while the agency reconsiders the rule.

Created: 14/11/2017 Last edited: 14/11/2017

 

Not supporting GHG emission standards

InfluenceMap Comment:

Supporting re-opening of EPA light duty vehicle emission standards, therefore objecting to previousl finalisation of standards (API, comment on reconsideration of final determination of midterm evalution of GHG standards MY2022-2025 for LDV, October 2017)

Extract from Source:

The American Petroleum Institute (API) appreciates the opportunity to comment on the reconsideration of the final determination of the midterm evaluation of greenhouse gas emissions standards for model year 2022-2025 light-duty vehicles. [...] API supports EPA’s and NHTSA’s reconsideration of the Mid-Term evaluation process, which was cut short abruptly and prematurely by the Obama Administration in early January 2017. [...] The issue of reference/baseline year was especially highlighted by API in September 2016. API objected to using 2021MY as baseline and, instead, recommended that costs and benefits of model year 2022-2025 standards be compared “against the latest year for which actual sales and technology cost data are available.”

Created: 14/11/2017 Last edited: 14/11/2017

 

Not supporting GHG emissions standards

InfluenceMap Comment:

Actively supporting the rollback of technical measurement requirements associated with EPA methane regulations (API, Public Hearing, NSPS-OOOO, November 2018)

Extract from Source:

Unfortunately, the proposed rule includes several missed opportunities. There are significant capital investments and scientific studies underway to advance the development and use of new emission detection technologies. The agency’s insistence on requiring site-specific approval for each new technology will only stifle this positive development. We hope the EPA significantly streamlines this process in the final rule. The rule also fails to reduce the burden of overlapping regulatory requirements that have no environmental benefit. While the agency agrees that many state leak detection and repair programs are equally effective, significant and duplicative recordkeeping and reporting remains. This is just regulatory burden without environmental benefits and we encourage the agency to recognize that and improve this requirement in the final rule. We also encourage the EPA to recognize the value of the field data measurements that have been shared with the agency.

Created: 16/01/2019 Last edited: 16/01/2019

 

Opposing GHG emissions standards

InfluenceMap Comment:

Directly advocating to policy makers to support a two-year delay for the introduction of methane standards in the US (Response to Environmental Protection Agency’s (EPA’s) “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain Requirements, July 2017)

Extract from Source:

EPA Has Multiple Sources of Legal Authority to Extend the Compliance Deadlines.A. EPA Should Extend the Relevant Compliance Deadlines (Rather Than Issue a Stay), Pursuant to Its Authority Under CAA § 111. EPA has authority under CAA § 111(b) to extend compliance deadlines and/or establish future effective compliance dates. Section 111(b) sets a timeline for when initial NSPS must be done, when EPA must review the NSPS, and when revised NSPS are effective. Section 111(b) does not, however, instruct when compliance with NSPS must be achieved. Also, there are no time requirements for when EPA conducts a voluntary or ahead-of-schedule review of the NSPS. EPA has authority under the plain language of CAA § 111(b) to extend compliance deadlines. [...] B. A Stay Pending Judicial Review Is Warranted Under APA § 705. APA § 705 states that “[w]hen an agency finds that justice so requires, it may postpone the effective date of action taken by it, pending judicial review.” 5 U.S.C. § 705. An APA § 705 stay is warranted here, as litigation is pending and justice requires EPA to stay the rule until the case is decided or settled. [...] EPA’s General Rulemaking Authority Under CAA § 301(a) Authorizes a Stay of the Proposed Provisions for Two Years. CAA § 301 grants EPA authority to issue regulations as “necessary to carry out” its obligations under the Act. Here, there is no more specific statutory provision in the Clean Air Act, nor is there any other statutory bar to EPA using its authority under CAA § 301. A two-year stay is necessary for EPA to meet the statutory standard under CAA § 111 and respect the process enshrined in CAA § 307. As such, EPA’s use of CAA § 301 here is appropriate.

Created: 14/08/2017 Last edited: 14/08/2017

 

Opposing GHG emissions standards

InfluenceMap Comment:

Supporting review and revision of oil and gas emission standards (API_Letter to EPA Administrator Pruitt, Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources, May 2017)

Extract from Source:

Thank you for your April 18, 2017 letter to the American Petroleum Institute1 and others,communicating the agency’s intent to convene a proceeding for reconsideration of the FinalRule, “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and ModifiedSources,”[....] Consistent with President Trump’s stated objectives of American energy independence and economic growth, EPA and other federal agencies should ensure that regulations are achievable and cost-effective. API supported previous EPA regulatory reviews to relieve the burdens imposed by EPA rules in 2011 and 2015, while continuing to promote public health, safety and the environment as industry and citizens support. [...]  We are encouraged by EPA’s April 4, 2017 announcement to review the 2016 standards, and API supports revision of those standards.

Created: 14/11/2017 Last edited: 15/11/2017

 

Opposing GHG emissions standards

InfluenceMap Comment:

Supporting the repeal of GHG emission standards under the Clean Power Plan (API, Testimony at a public hearing on GHG from existing electric generation units, regions to New Source Review Program, October 2018)

Extract from Source:

API has supported the Trump administration’s review of the Clean Power Plan as promulgated on October 23, 2015 and supports the administration’s proposed repeal of the CPP

Created: 16/01/2019 Last edited: 16/01/2019

 

Not supporting GHG emission standards

InfluenceMap Comment:

Whilst not opposing GHG emission regulation for US power generation units, API is supporting the Trump Administrations weakened alternative to the CAPP whilst also advocating that power plants run on natural gas and CHP remain exempt for new standards (API, Comments on ACE, October 2018)

Extract from Source:

API is not herein refuting the existence of climate change or arguing against all regulation of GHG emissions. [...] API supports EPA’s proposal to exclude natural gas-fired EGUs from the “affected facilities” that will be subject to regulation under the Proposed ACE Rule. Natural gas-fired stationary combustion turbines are already highly efficient, and any further emission reductions would likely be modest in size and prohibitively expensive. For similar reasons, API also supports EPA’s proposed exclusion of combined heat and power (“CHP”) units and simple cycle turbines. [...] EPA’s proposed evaluation of BSER also appropriately limits the Agency’s role to the provision of non-binding guidance and preserves the primary role of States in establishing standards of performance for specific facilities or groups of facilities based on their own unique attributes. EPA’s proposed revisions to the Agency’s emissions guideline implementing regulations reflect this important State role and Congressional intent in enacting Section 111(d). API believes that States using the flexibility provided in this proposal can, and should, consider CHP units, natural gas combined cycle units, natural gas co-firing in coal-fired EGUs, and carbon capture and storage as they set State-specific standards of performance under Section 111(d). [...] API also believes that EPA has appropriately recognized New Source Review (“NSR”) permitting as a significant obstacle to efficiency improvements. Because these adverse impacts are present in other sectors, such as the refining and petrochemical manufacturing sectors, however, API recommends that EPA expand the proposed NSR changes to include all industry sectors.

Created: 16/01/2019 Last edited: 16/01/2019