Multi-Association Comments to the Bureau of Safety and Environmental Enforcement on its Notice of Proposed Rulemaking on Blowout Preventer Systems and Well Control

Multi-Association Comments to the Bureau of Safety and Environmental Enforcement on its Notice of Proposed Rulemaking on Blowout Preventer Systems and Well Control

To whom it may concern: The American Petroleum Institute (API), the International Association of Drilling Contractors (IADC), the Independent Petroleum Association of America (IPAA), the National Ocean Industries Association (NOIA), the Offshore Operators Committee (OOC), the Petroleum Equipment & Services Association (PESA), and the US Oil and Gas Association respectfully submit the following comments on the proposed regulatory changes to Blowout Prevention Systems and Well Control requirements in 30 C.F.R. part 250. The Bureau of Safety and Environmental Enforcement (BSEE) announced these proposed changes on April 17, 2015, in a notice of proposed rulemaking entitled, “Oil and Gas and Sulphur Operations in the Outer Continental Shelf—Blowout Preventer Systems and Well Control.”