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BOEM acknowledges the commenters' problems which the P70 estimates could possibly be larger than the particular price of decommissioning for precise platforms. In general, it could be more expensive for the government to decommission a facility than it can be for an OCS operator to take action. As a result, regardless of whether the P70 value is increased than business-derived values, it might be far more aligned with the costs that The federal government would incur to accomplish the decommissioning, that is the applicable consideration when identifying the fee to decommission a facility if the business fails to take action.
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A person commenter expressed problem that the proposed rule specifies that an appeal bond will “immediately” change to some fiscal assurance obligation should really the lease operator drop its enchantment and noted that bonds usually do not run During this fashion. If finalized, the commenter asserted the charm bond must supply a particular quantity of days for that lease operator to write-up its financial assurance obligation to allow the surety to underwrite the operator at some time the bond is set to become justified.
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Commenters expressed concerns pertaining to BOEM's proposal to make use of a proxy credit history score for entities with out an issuer credit history ranking.