IADC expresses concerns with BSEE/BOEM Arctic rule
On 27 May, IADC submitted a response to the US Department of the Interior’s proposed rule to revise and add new requirements to regulations for exploratory drilling and related operations on the Outer Continental Shelf seaward of the state of Alaska. The proposed rule was issued jointly by the Bureau of Safety and Environmental Enforcement (BSEE) and the Bureau of Ocean Energy Management (BOEM) on 24 February 2015.
IADC expressed concern with:
• The prescriptiveness of the rule in its references to operations of floating units, such that operations by other types of units are seemingly not permitted;
• The unnecessary burdens and the duplication of effort in developing and submitting the proposed integrated operations plans;
• The potential for the proposed BOP pressure test interval to adversely affect system reliability and the related need for coordination of all overlapping provisions of the proposal with any final action taken with regard to BSEE’s proposed rulemaking for blowout preventer systems and well control, published on 17 April 2015; and
• Over-involvement by BSEE in operational decision-making.
In addition, the letter expressed concerns about uncertainties regarding individual and contractor responsibilities and liabilities to the proposed rule, specifically regarding reporting of incidents; responsibilities related to the securing of the well; responsibility of performing tests; real-time data gathering, monitoring, recordkeeping and transmission capabilities and the responsible party for ensuring compliance with the specifications.
IADC responds to proposed US MODU and dynamic positioning requirements
On 6 May, IADC submitted a response to the US Coast Guard’s notice of the proposed rule, Requirements for MODUs and Other Vessels Conducting Outer Continental Shelf Activities with Dynamic Positioning Systems, which was issued on 28 November 2014. IADC noted substantial issues with the proposal, noting that the association does not believe that the proposal can be progressed to a final rule without a supplementary notice of proposed rulemaking to resolve significant deficiencies in the proposal. Many of those deficiencies relate to the prescriptiveness of the proposal.
Particularly, IADC noted that the proposal presents no clear and feasible path to implementation and the proposed definitions of critical OCS activities are inappropriate. IADC encouraged the Coast Guard to move further toward a performance-based rule as it revises the proposal.
Click here to access the proposed Arctic rule on the BSEE website.
