San Joaquin Valley Rule 3170, Federally Mandated Ozone Nonattainment Fee; Submitted August 6, 2002.

The American Petroleum Institute (API) represents over 400 member companies involved in all aspects of the oil and natural gas industry. API is pleased to submit these comments. API members have reviewed the comments developed on the August 19, 2009, proposed U.S. Environmental Protection Agency ("EPA") limited approval and limited disapproval of San Joaquin Valley Air Pollution Control District (the "District") Rule 3170 ("Rule 3170") (74 Fed. Reg. 41,826) by the Western States Petroleum Association ("WSPA") on EPA's proposed action. API supports the points delineated in the the attached comments.