IADC, along with six other oil and gas industry trade associations, submitted a joint letter on 16 July to the US Bureau of Safety and Environmental Enforcement (BSEE) with comments on the agency’s Proposed BOP and Well Control rule. IADC supplemented this letter with a separate letter, which addresses the concerns of drilling contractors.
Specifically with regard to drilling contractors, IADC identified three major areas of concern with the proposed rule. These include its prescriptive requirements that go beyond international standards and will negatively affect the US market for MODUs; the significant costs to drilling contractors to comply with the rule, which were not accounted for in BSEE’s impact analysis; and the inspection and more massive BOP equipment requirements, which will negatively impact operations.
“At IADC, we welcome any opportunity to work collaboratively and constructively with BSEE and Director (Brian) Salerno, as we believe in the need for better regulation,” IADC President/CEO Stephen Colville said. “That is regulation that is fair, fit for purpose, practically implementable and affordable for our industry. We understand the weight of expectation on this proposed rule, given that well control is a key area of public concern, and we respect the direction of travel set by BSEE. However, the lengthy period of gestation of the rule is regrettably unmatched by the very short period for public comment on it, as the rule is both technical and wide-ranging.
“Our industry has identified a number of measures that are variously technically unfeasible, with little overall benefit to safety standards and unrealistic deadlines, and the related costs of compliance are very high,” Mr Colville continued. “IADC has identified areas where the duties of the drilling contractor need to be better defined in light of BSEE’s evolving view of the responsibilities and liabilities of entities other than the operator. Overall, the high cost imposed by the rule greatly exceeds the potential benefits derived from it, and will challenge the economics of outer continental shelf (OCS) operations.
“We know Admiral Salerno and BSEE share IADC’s concern to achieve the best possible outcome for safety in OCS well operations. So at IADC, we are confident that as BSEE and other key stakeholders come to recognize soon the shortcomings in the current proposed regulation, they will work urgently and collaboratively with the industry to rectify them.”
The other trade groups that submitted the joint comments with IADC were API, the Independent Petroleum Association of America, the National Ocean Industries Association, the Offshore Operators Committee, the Petroleum Equipment & Services Association, and the US Oil and Gas Association.