AAPL Among 41 Trade Associations Opposing Nomination of Sarah Bloom Raskin as Vice Chair for Supervision at the Federal Reserve

January 28, 2022 

The Honorable Sherrod Brown Chairman                                                                  The Honorable Patrick Toomey Ranking Member 

Senate Committee on Banking, Housing, and Urban Affairs 
534 Dirksen Senate Building 
Washington, DC 20510 
Re: Opposition to the Nomination of Sarah Bloom Raskin as Vice Chair for Supervision at the Federal Reserve 

Dear Chairman Brown and Ranking Member Toomey: 

We are 41 trade associations representing millions of workers all across the country. We provide 70% of the nation’s energy that supports life-sustaining functions such as keeping Americans warm in the winter, getting them to work and school to better their lives, powering ICUs and enabling medical devices, and delivering food to the dinner table. Oil and natural gas provide the feedstock for thousands of products used every day, from anything with a computer chip to the COVID vaccines that have saved millions of lives across the globe. American oil and natural gas is developed under strict environmental controls with industry-driven technologies that make it the most sustainably produced in the world.  Natural gas electricity generation is the number one reason our country has reduced more greenhouse gas emissions than any other over more than a decade. The world would truly be less healthy, safe, and environmentally protected without the energy we provide.  

We strongly oppose President Biden’s nomination of Sarah Bloom Raskin as Vice Chairwoman for Supervision at the Federal Reserve, the government’s most influential overseer of the American banking system. She is a strong advocate for debanking the very industry that powers America. Her multiple public statements indicate an agenda at odds with the President’s goal of providing Americans with reliable, affordable energy.  

Department of Energy projections show national and global oil and natural gas consumption increasing out to 2050, which belies Ms. Bloom Raskin’s public statements that the industry is a “dying one” that does not deserve access to the financial system. Her alarmist statements about “an unlivably hot planet” are not supported by the gold standard for climate science, the Intergovernmental Panel on Climate Change (IPCC) assessment reports, indicating poor judgement and a crisis mentality ill-suited for sober, balanced regulation of the banking sector as it underpins the entire economy. Further, her public writings and speeches advocate for using Federal Reserve stress tests and other regulatory levers as a means to reshape the entire financial system in ways Congress never intended. Such “reimagining of the economy” is not the purview of regulators absent legal authority form Congress. Her activist approach to regulation is undemocratic and highly inappropriate for such an influential position.  

Ms. Bloom Raskin’s favored policies would wreak havoc with the economy, as financial systems would be reoriented around subjective, political factors rather than firm principles of maximizing returns and capitalizing productive human endeavors that create value in the marketplace. A free market is the correct arbiter of value to real people, not activism. The fact that oil and natural gas are used in just about every facet of modern life speaks to their intrinsic value, and hence, their investment worthiness. Further, activists pressure investors and banks to make financial decisions that reflect a political agenda which they have been unable to achieve through the normal democratic process. Activists have been able to convince neither the American people nor the majority of their representatives in Congress to stop using oil and natural gas in the absence of a viable, reliable alternative, as it would mean fundamentally altering Americans’ healthy, safe, and prosperous lifestyles. As they are unable to convince Congress to pass laws that prevent Americans from using or producing oil and natural gas, activists such as Ms. Bloom Raskin are simply inappropriate for the Federal Reserve.  

Our industries have already felt the impacts of such activism, as the decapitalization of oil and natural gas has meant that companies cannot adequately invest in new production to respond to the high price signals the market is sending. Whereas just a few years ago the American producer was able to meet new demand to keep prices low at the pump, lack of access to capital has artificially constrained supply and the White House now begs OPEC and Russia for more oil. In fact the biggest impact President Biden could make to lower prices for Americans would be to withdraw Ms. Bloom’s nomination and call off the financial agencies from pursuing policies she promotes to choke off lending to oil and natural gas. Halting regulatory efforts to decapitalize oil and natural gas would send a strong signal to the market that it is safe to invest in the industry, thereby enabling American companies to increase production and lower prices for consumers. 

We urge you to take an important step to lower energy prices for Americans by not advancing the nomination of Ms. Bloom Raskin to the Federal Reserve. Thank you for considering our combined voices representing millions of energy and manufacturing workers.  

Sincerely, 

Alaska Oil and Gas Association 
Alaska Support Industry Alliance 
American Association of Professional Landmen 
Arkansas Independent Producers and Royalty Owners 
Coalbed Methane Association of Alabama 
Colorado Alliance of Mineral and Royalty Owners 
Colorado Oil & Gas Association 
Domestic Energy Producers Alliance 
Energy Workforce & Technology Council 
Gas and Oil Association of West Virginia 
Gulf Energy Alliance 
International Association of Drilling Contractors 
Illinois Oil and Gas Association 
Independent Oil Producers Agency 
Independent Petroleum Association of America 
Independent Petroleum Association of New Mexico 
Kansas Independent Oil & Gas Association 
Kentucky Oil and Gas Association 
Louisiana Oil & Gas Association 
Marcellus Shale Coalition 
Montana Association of Oil, Gas, and Coal Counties 
Montana Petroleum Association 
National Stripper Well Association 
New Mexico Oil and Gas Association 
North Dakota Petroleum Council 
Northern Montana Oil and Gas Association 
Ohio Oil and Gas Association 
Panhandle Producers & Royalty Owners Association 
Pennsylvania Independent Oil and Gas Association 
Pennsylvania Manufacturers’ Association 
Permian Basin Petroleum Association 
Petroleum Alliance of Oklahoma 
Petroleum Association of Wyoming 
Southeast Oil and Gas Association 
Texas Alliance of Energy Producers 
Texas Independent Producers and Royalty Owners Association 
The Energy Council 
U.S. Oil & Gas Association 
Utah Petroleum Association 
Western Energy Alliance 
West Slope Colorado Oil & Gas Association