Perfunctory documents still haunting offshore regulations?

The initial post-disaster review of the contingency plans for the BP-Macondo operations revealed that the plans were a pile of boilerplate used as a proxy for the required papers. This was made clear to the public when the documents included mitigation plans for walrus, an Arctic animal that if seen in the Gulf of Mexico would only be found in zoos or aquariums.

In response to the failed regulatory oversight that precipitated the BP Oil disaster the Department of the Interior’s Minerals Management Service was split into three distinct agencies that included Bureau of Ocean Energy Management (BOEM) and, Bureau of Safety and Environmental Enforcement (BSEE) and the Office of Natural Resources Revenue (ONRR). This was done because it was found that there was way too much ‘friendly traffic’ between assets management, safety regulation, and the industry – a situation that had evolved through years of ‘expediency’ favoring industry over environmental and operational safety practices.

Supposedly this division of oversight, safety, and revenue collection has ushered in a new, less reckless management regime, so that when offshore permits are needed to perform some action the fossil fuel industry will go to BOEM to get their action plans reviewed, go to BSEE with their operations and contingency plans, and go to ONRR to work out how much we taxpayers get paid for the exploitation of our resources.

While the evidence does point to improvement, particularly on the more expansive actions, there is an ongoing flow of little actions – exploratory drilling requests, small construction projects, and equipment placements that may still be plagued with lax oversight.


Sevan Brasil Dynamically Positioned drill rig Photo: Subsea World News

This week a colleague in the industry sent us an exploration plan that was out for public comment. This plan is considered a ‘small’ operation and requires only a 10 day review. Lots of these get pushed through the permitting process, all requiring the same documentation. Digging a bit into the plan we found that despite the deployment of three dynamically positioned drill rigs and a host of other noise-producing technologies there was no mention of any noise impacts throughout the entire document.

We also found indications that this plan contains a lot of perfunctory boilerplate that has little to do with the proposed actions. I sent in comments to this plan which included my “boilerplate” concern. But knowing that this plan is just one of many that are sent out for review each year, monitoring these for environmental shortcomings would be a full time job – a job that we are paying BOEM to do.

I presume BOEM will get back to me with their response. Hopefully this plan is only a glitch in their system and not an indication of a larger systematic failure. I’ll keep you posted.