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Posts Tagged ‘OCS facilities’

Launch from the Ocean Odyssey, a semi-submersible drilling rig modified by the Sea Launch consortium

The Bureau of Ocean Energy Management today announced the publication of a Request for Information to explore the potential use of the Outer Continental Shelf for offshore space launch and re-entry activities.

“The Outer Continental Shelf presents a significant opportunity to support the future of America’s space economy. Offshore launch, re-entry, and recovery infrastructure could expand operational flexibility, increase capacity, reduce constraints on growing launch demand, and strengthen the nation’s commercial and national security space capabilities. With approximately 3.2 billion acres under federal jurisdiction, BOEM is uniquely positioned to help evaluate this emerging opportunity,” said Acting BOEM Director Matt Giacona. “This Request for Information is an important first step in assessing how offshore development could support the next era of U.S. space leadership.”

Rigs-to-Rockets is one of the alternative OCS uses promoted on this blog. Sea Launch was the first company to launch rockets from a converted semi-submersible drilling rig (photo above).

Kudos to BOEM for this initiative. Their Federal Register Notice is attached.

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Sen. Mike Lee has introduced legislation to repeal the Jones Act, which is drawing additional scrutiny for the increased cost of transporting US oil production and LNG to US ports.

Because facilities on the Outer Continental Shelf are US ports under the Jones Act, the Act has been problematic for both the offshore oil and wind industries. The attached Customs and Border Patrol document delves into the nuances of Jones Act compliance for lifting operations (p.14-15) and “points” on the OCS (p.17).

EXAMPLE: CBP interprets the OCSLA to extend the Jones Act to artificial islands and similar structures, as well as to mobile oil drilling rigs, drilling platforms, and other devices attached to the seabed of the OCS for the purpose of resource extraction and/or exploration operations. Such objects located on the OCS are considered points or places in the United States for purposes of the Jones Act. Similarly, floating warehouse vessels, when anchored on the OCS to supply drilling rigs on the OCS, are also coastwise points.

Check out this complex CBP ruling on the transportation of well fluids from one location in a subsea well cluster to another. See if you understand and agree with their conclusion (below).

The transportation of fluids as described in the FACTS section above, by a dynamically-positioned, foreign-flagged drill ship between wells located within an IF (integrated facility), which subsequently, transships the fluids to a coastwise qualified barge for transportation to a coastwise point, violates 46 U.S.C. § 55102.

On a related matter, it’s still unclear to me whether the attachment of the lower marine riser package to a subsea wellhead makes a floating, dynamically positioned drillship a US port under the Jones Act.

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