The subject Regulatory Agenda is attached. The proposed update to decommissioning requirements (abstract below) should attract attention! I would assume that, in addition to meeting Coast Guard requirements, a toppled structure would have to be accepted into a State reefing program. Otherwise the liability risks would be unacceptably high.
REVISIONS TO DECOMMISSIONING REQUIREMENTS ON THE OCS
Legal Authority: Outer Continental Shelf Lands Act, 43 U.S.C. 1331 to 1356a
Relevant Executive Orders: 14154
Abstract: This rule proposes to set ‘‘topple in place’’ as the default decommissioning standard, on the condition that such circumstances meet U.S. Coast Guard navigational requirements. This proposed rule would also address issues that may include to (1) idle iron by adding a definition of this term to clarify that it applies to idle wells and structures on active leases; (2) abandonment in place of subsea infrastructure by adding regulations addressing when BSEE may approve decommissioning-in-place instead of removal of certain subsea equipment; (3) BSEE approval for platform or facility toppling in place; and (4) other operational considerations.
Timetable:
Action Date FR Cite
NPRM ……………… 07/00/27
NPRM Comment Period End. 10/00/27
No date for a final Arctic drilling or decommissioning financial assurance rule is projected. With regard to the latter, many important issues were raised by commenters, and a new proposal is likely and desirable.
A rule writer’s work is never done! Entire careers have been spent updating a single regulation! 😉
Bud's Offshore Energy (BOE) 
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