Bud's Offshore Energy (BOE)

Attached are my comments on BOEM’s proposed revisions to the decommissioning financial assurance regulations. These comments were submitted to Regulations.gov yesterday (3 days early 😀). Bud

Concluding Remarks

1. MMA’s highest priority must be assuring that facilities are safely decommissioned without public funding. Supplemental financial assurance determinations and lease assignment approvals must be consistent with that priority.  
2. Predecessor liability is an important financial assurance principle, but legal boundaries and administrative procedures must be clearly established. 
3. Safety and compliance are inextricably related to financial performance, and must be considered in determining supplemental assurance requirements. 
4. Using reserve estimates to reduce supplemental assurance exposes taxpayers to geologic and accounting risks. 
5. Unacceptable public risks have resulted from financial assurance decisions intended to advance offshore wind development.