Comment on BSEE-2012-0005-0001
This is a Comment on the Bureau of Safety and Environmental Enforcement (BSEE) Proposed Rule: Oil and Gas and Sulphur Operations on the Outer Continental Shelf: Oil and Gas Production Safety Systems
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Office of Management and Budget
Attn: Interior Desk Officer, 1014-0003
RIN 1014–AA10: Oil and Gas and Sulphur Operations on the Outer Continental Shelf — Oil and Gas Production Safety Systems
In response to the recently issued proposed rulemaking that was noticed in the Federal Register on Aug 22, 2013, The Offshore Operators Committee (OOC) on behalf of its members respectfully submits the following comments on the economic analysis developed by the agency on the proposed rule changes. OOC is an organization of some 144 producing and service companies who conduct essentially all of the OCS oil and gas exploration and production activities in the Gulf of Mexico. Comments made on behalf of OOC are submitted without prejudice to any member's right to have or express different or opposing views.
The Offshore Operators Committee (OOC) is providing comments on the Paperwork Reduction Act provisions in the proposed rulemaking titled Oil and Gas Production Safety Systems, RIN 1014-AA10. The OOC is concerned that the Bureau of Safety and Environmental Enforcement (BSEE) has not fully described the information collection requirements associated with the proposed rulemaking. In addition, OOC has concerns about the Economic Analysis (dated June 27, 2013) that was developed in conjunction with this rulemaking and the information collection burden.
General Concerns with the Paperwork Reduction Act Information Collection Requirements
The OOC is concerned that BSEE has not explained why many of the new requirements in the proposed rule are necessary to ensure safety for offshore oil and gas operations on the OCS, and has not explored or explained the expected impacts of the new requirements. Additionally, OOC believes that BSEE has significantly under estimated the burden hours for some of the new requirements.
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Comment Period Closed
Oct 21 2013, at 11:59 PM ET
Tracking Number: 1jx-87p3-98fv
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Date Posted: Sep 24, 2013
Submitter Name: Allen Verret
Organization Name: Offshore Operators Committee