May 15, 2026 Comments Re: Risk Management and Financial Assurance for OCS Lease and Grant Obligations
Dear Ms. Thundiyil:
The Gulf Energy Alliance (GEA), the Independent Petroleum Association of America (IPAA) the U.S. Oil and Gas Association (USOGA), the Southeast Oil and Gas Association (SOGA), the Mississippi Energy Institute (MEI), the Louisiana Oil and Gas Association (LOGA), and the American Energy Institute (AEI) (hereinafter “the Associations”) respectfully submit the following comments in response to the Bureau of Ocean Energy Management’s proposed rule entitled Risk Management and Financial Assurance for OCS Lease and Grant Obligations, 91 Fed.
Reg. 11212 (March 9, 2026) (to be codified at 30 C.F.R. pts. 550, 556, and 590) (“the Proposed Rule”). …
It is vitally important that the Proposed Rule, with minor modifications, promptly become a final rule. Regulatory uncertainty regarding this specific issue has hindered investment in the GOA for ten years. At such a tenuous time for the offshore oil and gas industry, finalizing the Proposed Rule will provide necessary regulatory certainty, respect market participants’ previous bargains, and allow this critical sector of the American economy to flourish—all to the benefit of taxpayers, state and local governments, and the United States itself.




