May 6, 2008· Comment submitted by Ted Steichen, Advisor, Regulatory and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-ORD-2005-0029-0024
The American Petroleum Institute ("API") represents nearly 400 member
companies involved in all aspects of the oil and gas industry. API attended the
Unites States Environmental Protection Agency (EPA) Clean Air Science
Advisory Committee (CASAC) meeting on May 1, 2008 regarding the Second
External Review Draft of the Integrated Science Assessment for Oxides of
Nitrogen -- Heath Criteria (NOx ISA) and provides the attached comments.
While API recognizes that this draft of the NOx ISA is a considerable
improvement over the first draft, substantial improvements to the document are
still necessary.
Nov 6, 2007· Comment submitted by Howard J. Feldman, Director, Regulatory and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-ORD-2005-0029-0010
The American Petroleum Institute (API) represents nearly 400 member companies
involved in all aspects of the oil and natural gas industry. API attended the United
States Environmental Protection Agency (EPA) Clean Air Science Advisory
Committee (CASAC) meeting on October 24-25, 2007 regarding the First External
Review Draft of Integrated Science Assessment for Oxides of Nitrogen -- Health
Criteria (ISA). At that meeting, API provided oral testimony to the panel. The
attached comments expand on the statement API provided to CASAC. API
concludes that significant revision of this ISA is necessary. Please see the
attached comments for details.