Comment from Doug Morris, American Petroleum Institute

API appreciates the opportunity to comment on this proposed rule. API supports efforts by the MMS to update, streamline and clarify the existing Outer Continental Shelf (OCS) leasing and bonding regulations. MMS states that it is simply reordering and reorganizing the leasing requirements to “reflect the leasing process more efficiently.” Given the stated intent of streamlining the regulations, MMS should ensure that the final rule is limited to reordering and reorganizing the regulations, and clarification only as necessary. Please refer to the attached comments for API's comments on the specific provisions.