The table below captures the shorter public comments and provides links to the longer ones. They are listed in the order they were posted on Regulations.gov.
| commenter | summary/link |
| anonymous | I recommend under no circumstance that we allow the onsite worker to approve the commingling of bore holes because there is extreme significant safety and environmental hazards that exist. The best alternative is to have an environmental engineer and environmental scientist approve any commingling |
| Our Children’s Trust | …your regulatory proposal is inconsistent with the federal law, the best available science on protecting the health and lives of children, and the legal mandate that agency decision-making does not deprive children of their fundamental constitutional rights… |
| E.P. Danenberger | See BOE post |
| anonymous | I support updating the regulations to align with the One Big Beautiful Bill Act, but I encourage BSEE to ensure that safety standards and environmental protections remain the highest priority in all commingling approvals. Clear guidance for industry compliance and transparent public reporting would also strengthen confidence in this rule. |
| Ananda Foster | Regulations need to catch up with technology and we have not had a chance to do that yet. If you allow them on throttle access, they will destroy it. We all rely on the ocean, how can you do this to your own constituents? |
| API | Supports direct final rule |
| bp America | Supports direct final rule |
Legislatively dictating well construction, completion, or operational approvals is a redline for me, and I continue to strongly believe the downhole commingling rule should be published as a draft for public review and comment.
The only industry comments are from API and bp America. Both support the direct final rule, and I respect their position. My main quarrel is with the legislative action that put us in this position.
I have had many disagreements with API members over the years, but the dialogue has always been professional. Technical and policy disagreements are healthy for the OCS program, and I will continue to raise potential issues and concerns on this blog.
With regard to bp, I have been impressed by their commitment to the Gulf of America, as summarized in this excerpt from their comments:
Bud's Offshore Energy (BOE) 