...we are not supportive of the extensive, prescriptive regulations as proposed in this rule. We believe industry's current safety and environmental statistics demonstrate that the voluntary programs implemented since the adoption of API RP 75 have been and continue to be very successful.
The proposed rule prescribes stricter requirements than the approach on which it is based (API Recommended Practice 75, Development of a Safety and Environmental Management Program for Offshore Operations and Facilities, or SEMP), and may generate significant difficulties for operators and contractors to abide by the rule.
This proposed action is a major, paper work intensive, rulemaking that will significantly impact our business, both operationally and financially, and will bring little or no benefit towards improving safety of offshore operations. In addition to the unnecessary burden to industry, it will create an additional unwarranted burden to regional MMS staff that will require additional inspector/auditor training and increased workload demand.
We also endure a Mine Safety and Health Administration that seeks power over coal miners versus improving their safety and their health. As someone who has overseen the mining of more coal than anyone else in the history of central Appalachia, I know that the safety and health of coal miners is my most important job. I don’t need Washington politicians to tell me that, and neither do you. But I also know — I also know Washington and state politicians have no idea how to improve miner safety. The very idea that they care more about coal miner safety than we do is as silly as global warming.
A public plan would be unfairly matched against private plans and according to a 2009 Lewin Group Study, if the public plan’s reimbursement rates are similar to Medicare, an estimated 119 million people will shift from private insurance to the public plan. Within years, private insurers could be driven out of business and a “Single Payer System” will evolve. Moreover, an improperly constructed employer mandate could have a devastating impact on main street businesses that would be saddled with a significant economic burden.
I think that every single company that offers a credit card is reassessing its cost….reassessing what they do and how they do it.
This bill fundamentally changes the entire business model of credit cards by restricting the ability to price credit for risk. It is a fundamental rule of lending that an increase in risk means that less credit will be available and that the credit that is available will often have a higher interest rate.
ABA is very concerned about the direction this legislation is headed and we are concerned over the impact it will have on the ability of consumers, students and small businesses to get credit cards.
[The bill would] have a dramatic impact on the ability of consumers, small businesses, students, and others to get credit at a time when our economy can least afford such constraints.
Creating a government-run plan -- in any form -- to compete alongside the private sector for non-Medicare/Medicaid eligible individuals is unnecessary to achieve comprehensive reform and would have devastating consequences.