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
- 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.
- Predecessor liability is an important financial assurance principle, but legal boundaries and administrative procedures must be clearly established.
- Safety and compliance are inextricably related to financial performance, and must be considered in determining supplemental assurance requirements.
- Using reserve estimates to reduce supplemental assurance exposes taxpayers to geologic and accounting risks.
- Unacceptable public risks have resulted from financial assurance decisions intended to advance offshore wind development.
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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 BOEM, comments, decommissioning, financial assurance, predecessor liability, proposed regulation, reserve estimates, safety and compliance 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
Read Full Post »