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Posts Tagged ‘OOC’

Important reports and comments on the Rice’s whale restrictions in the Gulf of Mexico

Posted in energy policy, Gulf of Mexico, Offshore Energy - General, tagged , , , , , on October 10, 2023| Leave a Comment »

API’s comments on the Rice’s whale restrictions include a balanced assessment by Darren Ireland (begins on p. 22), a respected marine mammal scientist, and a good analysis of the economic impacts by EIAP.

Darren Ireland concludes (emphasis added):

“The proposed critical habitat has been deemed, by NMFS, to have the essential physical and biological features needed for the Rice’s whale to feed, breed, and reproduce. However, direct evidence for what oceanographic features within the 100-400 m isobath band identified by NMFS are required to sustain the Rice’s whale is lacking, and the extent of those truly important features elsewhere in the GOMx is uncertain and may not reach into the central or northwestern GOMx as predicted by the habitat based density model (Garrison et al. 2023). Even though there is evidence to support the possible occurrence of Rice’s whale near the FGBNMS in the northwestern GOMx, there are no data that show this area is being used to support important life history functions such as breeding, feeding, or migrating. Additionally, the sightings and acoustic detections that have been recorded there are much less frequent than those recorded for Rice’s whale in the core habitat in the northeastern GOMx. Based on the limited data available on the use and occurrence of Rice’s whale in the central and northwestern GOMx (one acoustic study (Soldevilla et al. 2022b), one confirmed sighting (NMFS 2018a) and a few unconfirmed sightings (Rosel et al. 2021)), there is insufficient scientific evidence to determine that essential features for Rice’s whale conservation are indeed present in the central and northwestern GOMx. In fact, data on the life-history requirements of Rice’s whale even in the core habitat are still lacking and need further investigation.“

EIAP’s key findings on the estimated economic impacts from these restrictions are summarized in the table below. Those are very significant costs given the uncertainty of the whale habitat in the central and western GoM.

Separate comments submitted by the Offshore Operators Committee are also quite strong. Their letter is attached.

2023_10_06_ooc_comment_letter_proposed_rule_designation_of_critical_habitat_for_the_rices_whale_finalDownload

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Congratulations to the Offshore Operators Committee on their 75th anniversary

Posted in Gulf of Mexico, Offshore Energy - General, tagged , , on June 8, 2023| Leave a Comment »

I believe the OOC is the world’s oldest trade association for the offshore oil and gas industry. The OOC was formed in 1948, five years before the enactment of the OCS Lands Act and just one year after the first Gulf of Mexico well was completed out of sight of land.

For much of their history, OOC had just a single, part-time employee. The organization has matured, but still operates in the same efficient manner, relying on subject matter experts from their member companies. Since the days of the OCS Orders, the OOC has consistently provided informed comments on operating regulations. As a regulator, I had issues with some of their comments over the years, but the dialogue was (almost😉) always polite and professional.

Congratulations to the OOC for the support they have provided for US offshore energy! Although many have had important roles, these former OOC representatives come immediately to mind for their contributions to offshore safety: John Rullman, Steve Brooks, Mark Witten, Sandi Fury, Dave Wisch, Ken Arnold, Charlie Williams, Phil Smith, Peter Velez, Allen Verret, Wanda Parker, Cort Cooper, Charlie Duhon, Jodie Connor, Craig Castille, Susan Hathcock, and Pat O’Connor. Many of these retired safety leaders, and current OOC Executive Director Evan Zimmerman, were recipients of MMS Offshore Leadership Awards.

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A 2013 Supreme Court houseboat decision applies to massive floating production units

Posted in energy policy, Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , , on May 8, 2023| Leave a Comment »

Dr. Malcolm Sharples, a leading marine engineer and offshore safety advocate, brought this Supreme Court’s decision and the resulting regulatory confusion to my attention.

It turns out that the SOCTUS decision about this houseboat…..

has created regulatory uncertainty for floating production facilities like this:

In a 7-2 decision, the court ruled that a gray, two-story home that its owner said was permanently moored to a Riviera Beach, Florida, marina was not a vessel, depriving the city of power under U.S. maritime law to seize and destroy it.

Reuters

The floating production facilities are still subject to Coast Guard regulation and inspection pursuant to separate authority under the OCS Lands Act. The extent to which Coast Guard approval and inspection practices will change is not entirely clear. The Coast Guard will issue new certificates of inspection for these floating facilities, and new policy guidance is being developed.

Attached are answers that the Coast Guard provided to questions from the Offshore Operators Committee.

20223-fof-pl-qa-w-ooc-24mar2022Download

This may be a good warmup for an upcoming post on regulatory fragmentation.

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Well Control Equipment Systems Safety Report

Posted in drilling, Gulf of Mexico, Regulation, well control incidents, tagged , , , , , on March 10, 2022| Leave a Comment »

This useful SafeOCS report summarizes and itemizes well control equipment failures associated with well operations on the Gulf of Mexico OCS in 2020. Of particular note was the absence of any loss of containment (leak of wellbore fluids) events in 2020 or the prior two years.

Unfortunately, there appear to be significant reporting gaps despite the fact that reporting of these data is required by regulation (30 CFR 250.730(c)). The reporting issues are particularly serious for surface systems (surface BOP and associated equipment). Per SafeOCS, surface rig reports were received from less than 50% of active operators and rigs. Reporting for subsea systems (subsea BOP and associated equipment) was much better with 85% of the active rigs represented.

Of further concern with regard to the reporting of surface equipment events, the data indicate only 5.3 events per 1000 hours for surface systems vs. 71.5 for subsea systems. While subsea systems are more complex, the cost of pulling and repairing subsea equipment dictates newer, better maintained equipment. As a result, surface BOPs have historically had higher failure rates than subsea BOPs. The data below are from a presentation to MMS approximately 15 years ago. Both the Sintef and OOC data show higher failure rates for surface BOPs.

The SafeOCS team did a very good job of analyzing the reports and presenting the data. However, the reporting issues need to be investigated and resolved to get maximum value from this very important work.

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