In the attached paper, John Smith and Robert Byrd summarize the daunting decommissioning challenges facing California offshore operators:
- Large, deep-water structures.
- Lack of decommissioning infrastructure and services locally.
- High HLV mobilization costs.
- Jones Act restrictions.
- Limited onshore processing and disposal options.
- Air quality compliance costs.
- Site clearance and debris removal requirements.
- Environmental and space use operating constraints.
- A complex regulatory framework and risk of litigation.
- An unworkable reefing law and lack of a State approved artificial reefing program.
Does the regulatory framework prevent you from doing what the regulations require? Catch-22?
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