Oct 20, 2015 Industry Letter to the Bureau of Ocean Energy Management Requesting an Extension for Public Comment on its Risk Management, Financial Assurance Guidelines
The American Petroleum Institute (API), the National Ocean Industries Association (NOIA), the Offshore Operators’ Committee (OOC) and the Independent Petroleum Association of America (IPAA) respectfully request that the Bureau of Ocean Energy Management (BOEM) extend the 45 day period for comments on the proposed guidance that BOEM will use to determine a lessee’s financial ability to carry out its obligations, primarily the decommissioning of OCS facilities, and the potential need for additional security posted on BOEM’s website on September 22, 2015. We appreciate the opportunity to review the draft guidance and the workshop that BOEM held on October 9. After reviewing the proposal and hearing BOEM’s presentation at the workshop, industry feels that 30 additional days are needed to fully analyze the potential impacts of the changes and to provide constructive feedback. Accordingly, we respectfully request that the deadline for comments on this proposed guidance be extended to December 6, 2016.