IPAA Comments to the Bureau of Ocean Energy Management on its Revised Notice to Lessees on Risk Management, Financial Assurance, and Loss Prevention

IPAA Comments to the Bureau of Ocean Energy Management on its Revised Notice to Lessees on Risk Management, Financial Assurance, and Loss Prevention

On behalf of our members, the Independent Petroleum Association of America (IPAA) would like to provide additional comments on the Bureau of Ocean Energy Management’s (BOEM) proposed guidance on the agency’s supplemental bonding requirements. IPAA submitted detailed comments to the Department of the Interior in response to the Advanced Notice of Proposed Rulemaking (ANPR) on this matter last year and is disappointed that the agency decided to forgo a formal rulemaking process. We are greatly concerned that new regulations will be issued through a revised Notice to Lessee (NTL) without any corresponding changes to the Code of Federal Regulations, thus creating new binding requirements outside the rulemaking procedures of the Administrative Procedures Act (APA). The BOEM contemplates significant changes to the regulations governing offshore activities and such changes should be promulgated as rules through the APA, not through a guidance document such as an NTL. Attached is a copy of the extensive comments IPAA filed on this matter with the Department last November.

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