The attached comments were submitted to BOEM via Regulations.gov. The comments address specific provisions of the proposed rule and include a recommendation to hold companies fully accountable for their lease transfers, but not for subsequent transfers in which they are not a party. Do I get a t-shirt for being one of the first 2000 […]
Search Results for 'boem financial assurance rule'
Comments on BOEM financial assurance rule for decommissioning
Posted in California, decommissioning, Gulf of Mexico, Offshore Energy - General, Regulation, tagged BOEM, compliance and safety, decommissioning, financial assurance, oil and gas reserves, proposed rule on August 22, 2023| Leave a Comment »
Suit to block BOEM’s financial assurance rule – why no press releases?
Posted in California, decommissioning, energy policy, Gulf of Mexico, Offshore Energy - General, Regulation, tagged bankruptcies, BOEM, decommissioning, financial assurance, LA, lawsuit, MS, TX on June 25, 2024| Leave a Comment »
None of the plaintiffs issued a press release or otherwise announced the lawsuit on their websites. How often do Attorneys General from 3 States sue the Federal government without broadly publicizing their actions? Neither the AG for Louisiana, Texas, nor Mississippi issued a press release to announce their suit to block BOEM’s financial assurance rule. […]
John Smith comments on BOEM’s decommissioning financial assurance rule
Posted in decommissioning, Offshore Energy - General, Regulation, tagged decommissioning, final rule, financial assurance, John B Smith, third party guarantee on April 23, 2024| Leave a Comment »
Decommissioning specialist John Smith has summarized the major provisions of BOEM’s decommissioning financial assurance rule for OCS oil and gas operations. He has highlighted his comments in red. Previous post on this final rule: “BOEM’s decommissioning financial assurance rule is arguably a step backward in protecting the public interes
BOEM’s decommissioning financial assurance rule is arguably a step backward in protecting the public interest
Posted in decommissioning, Gulf of Mexico, Offshore Energy - General, Regulation, tagged BOEM, compliance, decommissioning, final rule, financial assurance, oil and gas reserves, reverse chronological order, safety on April 17, 2024| Leave a Comment »
The final decommissioning financial assurance rule has been published and is largely unchanged from the proposed rule that we reviewed last summer. Major concerns: BOEM’s concern (below) about investment in US offshore exploration and production is interesting given that their 5 year leasing plan strongly implies otherwise. BOEM’s goal for its financial assurance program continues […]
Lots of public comments on BOEM’s proposed financial assurance rule (decommissioning)
Posted in decommissioning, Offshore Energy - General, Regulation, tagged BOEM, decommissioning, financial assurance, Regulation on August 15, 2023| Leave a Comment »
1137 comments to date per Regulations.gov. This would imply one or more organized commenting campaigns. I will share my comments on this blog after they have been submitted.
BOEM’s proposed financial assurance rule (decommissioning): preliminary observations
Posted in California, decommissioning, energy policy, Gulf of Mexico, Regulation, tagged BOEM, decommissioning, financial assurance, proposed rule, reverse chronological order on July 10, 2023| Leave a Comment »
Some preliminary thoughts about BOEM’s proposed revision to the decommissioning financial assurance regulations for US offshore oil and gas operations:
Meanwhile, TX, LA, and MS have sued to block BOEM’s decommissioning rule
Posted in California, decommissioning, energy policy, Gulf of Mexico, Offshore Energy - General, Regulation, tagged BOEM, Cox bankruptcy, decommissioning, financial assurance, Gulf of Mexico, Hogan and Houchin, Pacific, TX LA MS suit on June 19, 2024| Leave a Comment »
What’s their solution? Since the States don’t seem to think there is much risk, perhaps they would like to guarantee decommissioning expenses. Have they looked into the Cox bankruptcy? How about Platforms Hogan and Houchin and the complex decommissioning challenges in the Pacific. Are they comfortable with taxpayer funding for offshore decommissioning? BOE recently defended […]
BOE defends BOEM (not common 😉)
Posted in California, decommissioning, Gulf of Mexico, Offshore Energy - General, tagged BOEM, decommissioning, financial assurance, GAO, Hogan and Houchin on June 5, 2024| Leave a Comment »
This blog has raised significant concerns about BOEM’s decommissioning financial assurance rule, and will continue to comment on decommissioning policy. That said, decommissioning issues are complex and have challenged industry and government in the US and internationally for decades. Add well plugging practices, corrosion, storm risks, reefing vs. total removal, alternative uses for old platforms, […]
John Smith: “California Reports Highlight the Risks of Using Industry Reported Costs to Set Financial Assurance Requirements”
Posted in California, decommissioning, Offshore Energy - General, Regulation, tagged BOEM, California, costs, decommissioning, John B Smith on May 16, 2024| Leave a Comment »
In the attached supplement to his comments on BOEM’s financial assurance rule for offshore oil and gas facilities, decommissioning specialist John Smith raises concerns about reliance on cost data submitted by operators. John contrasts operator estimates for platforms in California state waters with estimates provided by independent consultants. As summarized below and explained in the […]
Wind energy rule codifies increased financial risk for taxpayers
Posted in decommissioning, energy policy, hurricanes, Offshore Energy - General, Offshore Wind, tagged BOEM, Cape May County, decommissioning, financial assurance, streamlining rule, wind standards, wind turbines on May 13, 2024| Leave a Comment »
BOEM’s “Rule to Streamline and Modernize Offshore Renewable Energy Development” is intended to “make offshore renewable energy development more efficient, [and] save billions of dollars. Unfortunately, the savings associated with relaxed decommissioning financial assurance requirements translates to increased risk for customers and taxpayers. BOEM signaled their intentions on offshore wind (OSW) decommissioning three years ago […]
Bud's Offshore Energy (BOE) 