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Posts Tagged ‘Regulation’

Back to the Future!

Posted in Regulation, tagged , , , , , on November 1, 2010| Leave a Comment »

 

Hyannis Halloween - 1981

 

Note the sign (above) on our office at Barnstable Municipal Airport in Hyannis. Prior to 1982 when the Minerals Management Service was formed, the OCS regulatory program was part of the US Geological Survey (Conservation Division) and the leasing program was in the Bureau of Land Management. After a 28-year marriage, these functions are again being separated.

As one who worked in the OCS program for 10 years prior to the formation of MMS, I think the the pre-1982 framework is conceptually preferable. However, unless the separation is carefully executed, disruptive conflicts between the two organizations are guaranteed.  Such conflicts were common in the pre-MMS days, and the Department of the Interior had to set up a special office to coordinate activities and manage disputes.

In addition to being independent, the new regulatory authority must be fully responsible (without interference) for all regulatory actions from plan approval through abandonment.  Without such independence and authority, the separation will only add to the regulatory confusion that has handicapped the OCS program throughout its history.

Technical and scientific personnel in the OCS regulatory program must be freed from non-productive and time-consuming internal disputes and coordination responsibilities so they can concentrate on performance measurement, risk assessment, safety leadership, standards, and technical studies.

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Offshore Wind Turbine Safety

Posted in Offshore Wind, Wind Energy, tagged , , , , on June 25, 2010| Leave a Comment »

Kudos to the National Academies and the very distinguished panel of experts who will be advising the government on the best approach for regulating offshore wind turbines.

I look forward to speaking to them next week.

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Will Other Nations Learn the Lessons from Montara?

Posted in accidents, Offshore Energy - General, Regulation, well control incidents, tagged , , , , , , on April 20, 2010| Leave a Comment »

My experience is that you unfortunately often need a major accident or even a disaster to engender political support for streamlining regulatory regimes.   Moreover, history shows that major accidents apparently must happen in your own jurisdiction to have such an effect on political support. Magne Ognedal

Magne’s astute comment repeatedly came to mind while I was reading the Montara testimony.  Our political systems are good at reacting, but are not so good at making tough decisions when the spotlight is elsewhere.  Crises provide the political capital needed to make major changes, but seldom yield the best solutions.

Will the Montara blowout provide the impetus needed for other countries to review and improve their offshore regulatory regimes?  These Montara issues should be of concern to all of us:

  1. Multiple regulators with unclear divisions of responsibility
  2. Regulatory gaps and overlap
  3. Ineffective use of standards and best practices
  4. Lack of clarity regarding operator and contractor responsibility and accountability
  5. Balancing goal-setting with prescription
  6. Monitoring operations effectively without taking “ownership”
  7. Applying regulatory resources efficiently and where the risk is greatest
  8. Absence of meaningful performance measures for operators and regulators
  9. Authority to remove rogue operators
  10. Ability to update standards and regulations in a timely manner
  11. Weaknesses in training programs for operators, contractors, and regulators

I’ll stop at ten (now eleven :)).

Many of these issues will be discussed at the International Regulators’ Offshore Safety Conference in Vancouver (18-20 October). I hope you plan to attend!

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