Of particular interest are mandated reviews of the:
RIsk Management and Financial Assurance Rule: Those who want to gut this rule should come to the table with proposals that better protect the taxpayer from decommissioning liabilities. Pretending that decommissioning financial risks don’t exist or that they are someone else’s (or the govt’s) problem is unacceptable.
5 Year leasing program – This review is urgently needed. See this and this!
BOP/Well Control Rule – This keystone safety rule has undergone multiple reviews in recent years. Because of the rule’s importance, further review for continuous improvement purposes may nonetheless be warranted. Here are the blog comments on the current version of the rule.
Pioneering offshore engineer J.L. Daeschler, a Frenchman who lives in Scotland and has worked on drilling rigs worldwide, shared his 1974 training certificate signed by Bill Hise, the first director of the Blowout Prevention and Well Control Training Center at LSU. JL recalls his training:
The LSU well control course was new and very well organized. Training options were limited at that time. LSU took a step forward and incorporated equipment donated by Cameron Iron Works, Armco Steel /National, VETCO, and others.
The course was split between indoor class room style and outdoor trainingon a live well to remind us of the real things, like hard hats, tally books, and safety shoes.
LSU had a 1200 ft vertical well and a small 2″ diameter gas injection line to create a bottom hole gas kick, using a nitrogen truck as the supply. (note: the live well was a first for any well control school.) You had a choice of several manual chokes. I selected the Cameron Willis choke to circulate the gas kick out with no increase in mud weight (drillers method).
The mud return level, kick detection, and general management of the operation were realistic as if on a rig. The gas would whistle and escape thru a vent line.
The training was simple and effective in that proper well control procedures were learned. In the process, there were many errors. Mud was seen flying out of the mud shaker/pits. School management would bring things under control and explain the errors that were made !!!
Given the importance of minimizing drilling risks, the Minerals Management Service (MMS) was the primary funder of the LSU facility. MMS predecessor, the Conservation Division of USGS, first established well control training requirements in 1975 (pasted below).
… Union Oil Company’s reckless well plan forever scarred the U.S. offshore program. Learn more about the details.
Santa Barbara blowout
Examinations of the Santa Barbara, Montara, and Macondo blowouts, the Piper Alpha fire, and other major incidents should be a part of every petroleum engineering curriculum, and should be mandatory for those who conduct and regulate offshore oil and gas operations.
There is no better learning experience than studying the failures that had such enormous human and economic consequences.
Withdrawal from the Paris Climate Change Agreement:The US Ambassador to the UN shall immediately submit formal written notification of the US withdrawal from the Paris Agreement under the United Nations Framework Convention on Climate Change.
Regulatory Freeze: Agencies may not propose or issue a rule until approved by a Presidential appointee. OMB may exempt emergency or urgent rules (déjà vu for regulators 😉).
Alaska: Withdraws a Secretarial Order intended to halt ANWR oil and gas leasing. Rescinds cancellation of ANWR leases.
Encourage energy exploration and production on Federal lands and waters, including on the Outer Continental Shelf.
Eliminate the electric vehicle (EV) mandate.
Requires immediate review of actions that could burden the development of energy resources.
Develop and begin implementing action plans to suspend, revise, or rescind all unduly burdensome agency actions.
Revoke climate change and “clean energy” EOs.
Terminate all activities, programs, and operations associated with the American Climate Corps (RIP 😉).
Expedite and simplify permitting processes.
Facilitate the permitting and construction of interstate energy transportation and other critical energy infrastructure, including pipelines.
Disband the Interagency Working Group on the Social Cost of Greenhouse Gases.
Terminate the Green New Deal.All agencies must immediately pause the disbursement of funds appropriated through the Inflation Reduction Act of 2022 (Public Law 117-169) or the Infrastructure Investment and Jobs Act (Public Law 117-58).
The Secretary of Energy is directed to restart reviews of applications for LNG export projects as expeditiously as possible.
33 years before Elon and Vivek’s DOGE, there was the Clinton-Gore Government efficiency initiative known as the National Performance Review, aka the National Partnership for Reinventing Government (NPR).
President Clinton (March 3, 1992): “Our goal is to make the entire federal government less expensive and more efficient, and to change the culture of our national bureaucracy away from complacency and entitlement toward initiative and empowerment.”
Al Gore led this effort with gusto. While not revolutionary, the NPR was quite successful in streamlining government programs. VP Gore presented symbolic and prestigious “Hammer Awards” (image above) to initiatives that were judged to have accomplished the NPR objectives:
put customers first
cut red tape
empower employees
get back to basics
My Division in the Minerals Management was one of the few government offices to be honored with two hammers. Kudos to Bill Hauser and Kumkum Ray for leading these two efforts:
reducing the pressure test frequency for blowout preventers after completing a detailed statistical analysis demonstrating that there would be no increase in failure risk.
simplifying the operating regulations and rewriting the text in plain, easy-to-understand English.
Who would have thought Al Gore, Elon Musk, and Vivek Ramaswamy had so much in common? 😉
Addressing regulatory fragmentation will improve efficiency and lower costs for industry and government while reducing safety and environmental risks.
Unfortunately, the regulatory regime for US offshore oil and gas operations is noteworthy for redundancy, uncertainty, and complexity that divert industry and governmental attention from safety and environmental protection objectives to administrative processes, interpretations, and jurisdictional boundaries.
“Poster Child”for regulatory fragmentation?
The 12 Federal entities that have some OCS regulatory responsibilities are identified in the above chart. The organizations with core regulatory roles are included in the overlapping circles. The responsibilities of BOEM and BSEE are so inextricably intertwined that those bureaus occupy the same circle.
Coastal states also have OCS regulatory roles through authority granted in the Coastal Zone Management Act.
When multiple agencies have jurisdiction over a facility, system, or procedure, the redundancy inevitably results in inconsistency, ambiguity, and gaps in oversight. The focus of operating companies and contractors is diverted from safety and risk management to understanding and satisfying the regulators. The inevitable result is a compliance mentality that weakens the safety culture.
Interagency agreements in the form of MOUs and MOAs, which are ostensibly for the purpose of managing redundancy, are often unclear or inconclusive. They tend to be more for the benefit of the agencies than the regulated industry. The interests of the regulators and protecting turf are paramount.
Where legislation is not required (e.g. BOEM and BSEE), use executive orders to combine and streamline the regulatory functions.
Where agencies have separate legislative authority, establish a lead regulator by executive order pending corrective legislation. Under the EO, the agencies would function as a joint authority under the direction of the lead regulator.
A combined BOEM/BSEE would be the logical choice for leading the joint authority given that OCS energy is their sole focus and they are accountable for the success of OCS programs.
Use a management system regulatory approach that holistically considers all of the legislatively enacted regulatory objectives.
Increase the attention given to regulator and operator performance in terms of both outcomes and efficiency.
Reduce and simplify permitting requirements for operating companies that have demonstrated outstanding safety and environmental performance over a sustained period.
“At the heart of the dispute are rules from the federal Bureau of Ocean Energy Management – BOEM – which require energy producers in the Outer Continental Shelf to provide a bond to pay for well, platform, pipeline and facilities cleanup if the operating company fails to do so.”
“These insurance companies and their unreasonable demands for increased collateral pose an existential threat to independent operators like W&T.”
Comment: If insuring offshore decommissioning is so risk-free and lucrative, why aren’t other companies entering the market?
“Several states, including Texas, are challenging the BOEM rule and in one case they specifically cite W&T as an example of how the rule could be misused to irreparably harm energy producers.“
Comment:As previously posted, the concerned States should propose alternative solutions that would promote production while also protecting taxpayer interests. Arguing that decommissioning financial risks are not a problem is neither accurate nor a solution.
“In over 70 years of producer operations in the Gulf of Mexico, the federal government has never been forced to pay for any abandonment cleanup operations associated with well, platform facility, or pipeline operations.”
Comment: Shamefully, from the standpoints of both the offshore industry and the Federal government, that statement is no longer true. The taxpayer has now funded decommissioning operations in the Matagorda Island Area offshore Texas (BSEE photo below) and more significant decommissioning liabilities loom.
Timeframe for government and industry actions following the 2005 hurricane season.
Optimally, the regulator establishes clear objectives for the operating companies and a schedule for achieving those objectives. This approach was demonstrated with great success following the 2005 hurricane season (Katrina and Rita) when numerous mooring system and other stationkeeping issues were identified.
Minerals Management Service Director Johnnie Burton sent a letter (attachment 1) to industry leaders calling for a face-to-face meeting with Department of the Interior Secretary Gale Norton. The Secretary outlined her concerns and informed offshore operators that there would be no drilling from moored mobile drilling units or jackup rigs during the next hurricane season until the issues identified during Hurricanes Katrina and Rita were addressed.
The collaborative effort that followed was a resounding success (2nd attachment). In addition to addressing station keeping concerns, a comprehensive list of hurricane issues was developed. Industry and government then worked together to assess mitigations and develop new standards and procedures. The essential MODU standards were completed before the 2006 hurricane season, and all of the related concerns were effectively addressed prior to the 2009 hurricane season. Had the government elected to promulgate regulations to address all of these issues, much of this work would have never been completed.
The Secretary of the Interior is the most important energy production position in the US govt, particularly for the offshore sector.
In recent years energy policy has been increasingly influenced (if not directed) by White House staff, most notably the White House Climate Office. Given that Burgum will also lead the new created National Energy Council, direction from White House staffers or other departments should not be an issue.
Burgum should work effectively with Dept. of Energy appointee Chris Wright, an engineer who understands energy production.
There is no apparent Republican dissent, so Burgum should have no problem being confirmed.
All of the offshore policy forecasts in the post-election post still stand.
Burgum is currently the Governor of North Dakota. Some energy production stats for the state:
ND ranks 4th if the OCS, for which Bergum will soon be responsible, is included. The OCS ranked 2nd in oil production, behind only TX, despite seemingly being managed to fail.
Wind: In 2023, wind was the second-largest electricity generating source in ND behind coal. At the beginning of 2024, ND had about 4,000 megawatts of installed wind power generating capacity.
What about carbon sequestration (disposal)?
As Governor, Burgum supported CCS projects that could be lucrative for North Dakota.
As Interior Secretary and Energy Czar, he will have to consider the high Federal subsidy costs, efficacy, and net environmental benefits.
Companies looking to benefit from publicly financed CCS projects will lobby hard for Federal support. Budget hawks and most environmental activists will be strongly opposed. It will be interesting to see who prevails.
Bud's Offshore Energy (BOE) 