HBW Resources Offshore Energy Report

HBW Resources Offshore Energy Report

Below is a summary of publicly available activities currently underway that could affect the development of offshore oil and gas resources prepared by Brent Greenfield, HBW Resources’ Director of Ocean Policy and Regulatory Affairs.

DOI Offshore Agencies Release FY 2015 Budget Justifications

Detailed FY 2015 budget justifications for the Bureaus of Ocean Energy Management and Safety and Environmental Enforcement were recently released.

BOEM items of interest include the following:


•BOEM plans to formally kick off the 2017-2022 5 Year Plan process before October 1 by issuing an initial Request for Information
•Atlantic will be considered in future 5 Year Plans
•BOEM calls Atlantic OCS resource evaluation “a high priority” for the agency and Administration
•BOEM says its “growing role” in marine planning will likely increase the agency’s use of programmatic EIS’s and “comprehensive planning”
•BOEM to “enhance” the traditional programmatic EIS through a new format that depicts “impacts and issues” mainly through maps
•Plans to finalize the BOEM-NOAA PEIS for GOM seismic activity in FY 2014
•Intention to conduct an updated evaluation of undiscovered, technically recoverable oil and gas
resources in 2016

BSEE items of note include the following:

• BSEE determining whether regulatory action is needed to ensure agency access to industry real-time monitoring (RTM) facilities and whether additional action is necessary to ensure industry expansion of RTM technology to address areas like equipment reliability

• BSEE plans to issue proposed blowout preventer rule before October 1; rule to incorporate robust API standard and include 3rd party certification of the design/quality systems used to manufacture BOPs
• Budget request includes $905,000 increase to support two technical expert review of emerging technologies and the evaluation, testing, and use of Best Available and Safest Technologies
• In 2014, BSEE to begin implementation of “many” of the National Academy of Sciencesrecommendations on Best Available and Safest Technologies for offshore o&g operations
• BSEE to work with Ocean Energy Safety Institute (OESI) to develop a process defining how OEIS will test and evaluate Best Available and Safest Technology issues
• BSEE to “continue to modernize” permitting/inspection processes through planned development of ePermits and eInspections in 2014
• In FY 2014, BSEE plans to pilot an evidence-based risk analysis methodology for production facility inspections

Agreement Reached To Lift BP’s Federal Contracting Suspension/Debarment

The Environmental Protection Agency recently announced the execution of a 5-year agreement with BP to lift the company’s suspension and debarment from entering into new federal government contracts.  

In exchange, BP agrees to retain an EPA-approved independent auditor to conduct annual review and reports on the company’s compliance with the agreement, which includes provisions related to ethics compliance, corporate governance, and process safety.  

EPA Assistant Administrator for Office of Administration and Resources Management Craig Hooks called the agreement “fair,” adding that “[m]any months of discussions and assessments have led up to this point, and I’m confident we’ve secured strong provisions to protect the integrity of federal procurement programs.”

Proposed Greenhouse Gas Reporting Rule Revisions Address Offshore Oil & Gas

The Environmental Protection Agency has announced proposed revisions to a greenhouse gas reporting rule that in part would require the reporting of the quantity of offshore oil, natural gas, and condensate produced for sales.  The proposed rule would also require the reporting (in metric tons) of annual CO2, CH4, and N2O emissions from offshore oil and natural gas production for each emission source type listed in the most recent BOEMRE study.

Comments on the proposed rule are due by Thursday, April 24.

Comments Sought on APM/APD-related Information Collection Requests

The Interior Department’s Bureau of Safety and Environmental Enforcement (BSEE) recentlyannounced that it is seeking comments on its requests for Office of Management and Budget approval of an Application for Permit to Modify (APM)-related information collection and an Application for Permit to Drill (APD)-related information collection.  Comments are due by Monday, April 14.

According to the announcements, the collections would separate out the hours and non-hour cost burdens associated with APMs/APDs into its own separate collection and reflect more accurate burden estimates.

Comments Sought on Revision to USCG Oil/Hazmat Transfer Procedures

The U.S. Coast Guard recently announced that it is seeking comments on its request for Office of Management and Budget approval of a revision to an information collection related to oil and hazardous materials transfer procedures applicable to vessels with a capacity of at least 250 barrels of oil or hazardous materials.  Such vessels must develop and maintain transfer procedures that provide basic safety information for operating transfer systems with the goal of pollution prevention.

Comments are due by Wednesday, April 9.  

Comments Sought on Request to Conduct DWH-related Research on Sea Turtles in GOM

NOAA’s National Marine Fisheries Service (NMFS) has announced that it is seeking comments on arequest by Tasha Metz (Texas A&M University at Galveston, Department of Marine Biology) for a permit to take loggerhead, green, Kemp’s ridley, and hawksbill sea turtles for scientific research.  Comments are due by Friday, April, 11.

The research would be comprised of the following two projects: (1) continuation of work started during the Natural Resource Damage Assessment documenting and assessing possible impacts of Deepwater Horizon oil and dispersants on sea turtles throughout selected beachfront, tidal pass, and estuarine/bay habitats west of the Mississippi River delta; and (2) continuation of assessing the impact of Fibropapilloma virus infection on recent increases in and continued growth of Texas’ green turtle population.

DOI Announces U.S. EITI Public Meetings

The Interior Department recently announced that the U.S. Extractive Industries Transparency Initiative Multi-Stakeholder Group Advisory Committee will hold public meetings in Washington, DC on April 23-24June 10-12September 9-11, and November 18-20.  The public can participate in the September 10 meeting by teleconference at 888-843-9231 (Passcode: EITI), and can attend the October and December meetings in person or by teleconference at 866-707-0640 (Passcode: 1500538).  Documents and presentations under discussion at the October and December meetings will be accessible athttp://bit.ly/1cR9W6t.  

Agenda items for the upcoming meetings include a review of the draft Terms of Reference for procuring an independent administrator for USEITI implementation (April), a review and discussion of the Opt-in process for states and tribes to participate in USEITI (June), a review and discussion of the reporting template and the Department’s hiring of an independent administrator (September), and drafting of a work plan to meet all EITI requirements and planning for 2015 (November).  

Final meeting agendas and materials will be available here.

EPA Announces Issuance of Air Quality Permit for Statoil GOM Activities

The Environmental Protection Agency recently announced the Oct. 28, 2013 issuance of a final Outer Continental Shelf air quality permit for Statoil Gulf Services, LLC.  The permit covers Statoil’s plans to operate a semi-submersible drill rig or drillship (and associated support vessels) for exploratory drilling activities at multiple locations within 14 DeSoto Canyon lease blocks.  EPA received no public comments on its preliminary decision to issue the permit.

Shipping Coordinating Committee Announces Public Meeting

The State Department has announced that the Shipping Coordinating Committee will hold an open meeting on Friday, April 18, 2014 in Washington, DC to prepare for the 101st Session of the International Maritime Organization’s (IMO) Legal Committee to be held in London April 28-May 2,2014.

According to the announcement, agenda items to be considered at the IMO meeting include “liability and compensation issues connected with transboundary pollution damage from offshore oil exploration and exploitation.”

The U.S. State Department on Wednesday also announced that the Shipping Coordinating Committee will hold an open meeting on Wednesday, March 12, 2014 in Washington, D.C. to prepare for the 66thSession of the International Maritime Organization’s (IMO) Maritime Environment Protection Committee to be held in London from March 31-April 4, 2014.

According to the announcement, agenda items to be considered at the IMO meeting include reduction of greenhouse gas emissions from ships, identification and protection of Special Areas and Particularly Sensitive Sea Areas, technical cooperation activities for marine environmental protection, noise from commercial shipping and adverse marine life impacts, and role of the human element.