Comments for Arctic Specific Regulations Needed
The Bureau of Ocean Energy Management (BOEM) and Bureau of Safety and Environmental Enforcement (BSEE) have released draft Arctic-specific regulations pertaining to oil and gas exploration and development in the Alaska Outer Continental Shelf (OCS). The Alaska OCS has the potential to be an essential and integral part of the nation’s “all of the above” domestic energy strategy. The proposed Arctic-specific regulations focus solely on the OCS within the Beaufort and Chukchi seas.
Action requested: This comment period, and upcoming BOEM decisions on Shell’s plans to explore its Chukchi leases this year, will play a crucial role in the feasibility and fate of Arctic exploration, and your voice is needed in support of reasonable regulations and decisions. Alliance members are encouraged to submit comments on the proposed regulations by May 27, 2015.
Comments may be submitted online: http://www.regulations.gov In the search tab on the main page, enter BSEE-2013-0011, select the document, then “Submit a Comment.”
By Mail, reference “Oil and Gas and Sulphur Operations on the Outer Continental Shelf-Requirements for Exploratory Drilling on the Arctic Outer Continental Shelf (1082-AA00).”
Attention: Regulations and Standards Branch 381 Elden Street, HE3314 Herndon, VA 20170-4817
Points to consider for your comments:
- The draft regulations should be revised, taking into account the National Petroleum Council’s Arctic report.
- The Draft Arctic Regulations are not justifiable from a cost-benefit perspective.
- The Draft Arctic Regulations do not define a workable process pursuant to which an operator can apply to use equivalent technology to a Same Season Relief Rig (SSRR).
- The Draft Arctic Regulations will significantly complicate the permitting environment for the U.S. Arctic OCS by imposing redundant and potentially conflicting regulatory requirements on operators.
- The Integrated Operations Plan (IOP) requirement set forth in the Draft Arctic Regulations is redundant with existing requirements for Exploration Plans (EP).
- The Draft Arctic Regulations include a requirement for a Blow-Out Preventer (BOP) pressure test every seven days, which is not justifiable from a risk-based perspective as it unnecessarily increases the wear-and-tear on assets. Current BSEE regulations require a BOP test every 14 days.
- The Draft Arctic Regulations establish an early end of season date for drilling activities well in advance of the average onset of ice pack – cutting an already short operating season in the Arctic even shorter. Despite this move to limit season length in the Arctic OCS, the Draft Arctic Regulations do not provide any corresponding relief on the issue of lease terms.
Comment deadline is May 27, 2015