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My comments on BOEM’s proposed revisions to decommissioning financial assurance requirements

Posted in California, decommissioning, energy policy, Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , , , , , on May 6, 2026| 1 Comment »

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.
Comments – BOEM financial assurance ruleDownload

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Regulatory reform comments

Posted in energy policy, Offshore Energy - General, Regulation, tagged , , , , , , on July 23, 2025| Leave a Comment »

My comments in response to the Dept. of the Interior’s regulatory reform notice are attached. First and foremost, I believe these recommendations would reduce safety and environmental risks. Second, I am confident that they would also reduce governmental costs and the regulatory burden on industry.

The first attachment discusses regulatory fragmentation and recommends actions to reduce the complexity and redundancy of the offshore regulatory regime. The second attachment proposes a Drilling Safety Leaders Pilot Program as a means of evaluating a more adaptable framework regulatory framework for operators with outstanding performance records.

DOI-2025-0005 Regulatory ReformDownload
Drilling Safety Pilot – WOMP- 7-2025Download

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OK, but what do you think about the revisions to the Well Control Rule? 😀

Posted in Offshore Energy - General, Regulation, well control incidents, tagged , , on November 23, 2022| Leave a Comment »

I recommend we Nationalize the Oil and gas industry. I think the government is the right entity at this time to seize all the assets and infrastructure of the cartels. The resources mostly on public lands and water, belong to the USA anyway. It is time we transition more rapidly to renewables to break the leverage of the cartels on governments, and people, to stop wars and profiteering.

People are paying high prices and cartels like API, Exxon, Sinclair are making record profits from American’s purses. All the while escaping the costs of oil spills and leaks, and denying responsibility for climate change disasters and their costs.

Anonymous WCR commenter (0010)

Diverse input on proposed regulations is healthy and desirable. However, comments should not be posted at Regulations.gov unless (1) the commenter is identified and (2) the comments include at least one sentence about the regulation being proposed.

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Comments on revisions to BSEE’s Well Control Rule

Posted in Offshore Energy - General, Regulation, well control incidents, tagged , , on November 10, 2022| Leave a Comment »

Comments on the proposed revisions to BSEE’s Well Control Rule are due on Monday (11/14/2022). My comments were submitted yesterday, and I have attached a copy for those who might be interested. Bud

wcr-comments-2Download

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Comments on BSEE’s proposed Well Control Rule are due by Nov. 14

Posted in drilling, Offshore Energy - General, Regulation, well control incidents, tagged , , , on October 18, 2022| Leave a Comment »

Comments on BSEE’s proposed revisions to the Well Control Rule are due in 27 days (by Nov. 14). Given the fundamental importance of well control to offshore safety and pollution prevention, all interested parties are encouraged to comment. Although some of the proposed revisions are rather nuanced, the document is neither long nor complex.

My completely independent comments are being drafted and will be posted here after they have been submitted to Regulations.gov.

My comments will explain why the proposal may reduce the rigor of the BOP system performance standard and will address a related shear ram issue. The comments will also discuss the management of BOP equipment failure and other safety data, the use of independent third parties and standards development organizations, dual shear rams on surface BOP stacks, ROV intervention capabilities, and BOP test data reporting and management.

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Well Control Rule comments

Posted in drilling, Offshore Energy - General, Regulation, tagged , , , on October 11, 2022| Leave a Comment »

Hopefully, the attached response is indicative of the quality of comments BSEE will receive on their proposed WCR revisions.

The comments, which were submitted by a retired engineer (always the best commenters 😉), express the opinion that BSEE should not remove the option for submitting failure data to BTS. While my comments will express a somewhat different opinion, I thought he made good arguments in support of his position.

bsee-2022-0009-0004_attachment_1Download

The chart below is excerpted from the SafeOCS Dashboard cited in the comment letter:

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