November 2014

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As Warren Buffett once wrote in a 2002 letter to the shareholders of Berkshire Hathaway, Inc., “you only find out who is swimming naked when the tide goes out.” Well, the tide is going out for many in the oil and gas industry with oil prices plummeting over the last five months to a mere $75 per barrel as of November 19, and it is not a pretty sight…for most. (more…)

Monday, November 17, 2014, is the last day to provide comments to the Bureau of Ocean Energy Management (BOEM) in connection with its Advance Notice of Proposed Rulemaking (ANPR) with respect to risk management, financial assurance and loss prevention associated with Outer Continental Shelf (OCS) leases. 79 Fed. Reg. 49027, 79 Fed. Reg. 61041. The ANPR invites industry comments with respect to BOEM’s need to develop a comprehensive program to assist in identifying, prioritizing and managing the risk associated with industry activities on the OCS. BOEM has identified and requested comment on four major topics: 1) identification of pertinent risks/liability, 2) risk monitoring and risk management, 3) demonstrating financial assurance over project lifestyles, and 4) financial assurance, bonding levels and requirements. The ANPR continues the trend of increased regulatory oversight in the wake of the Macondo disaster previously discussed in this blog. BOEM specifically notes that it will coordinate and consult with other federal agencies, including Bureau of Safety and Environmental Enforcement and the Office of Natural Resources Revenue. (more…)