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BOEM acknowledges the commenters' fears the P70 estimates might be bigger than the particular cost of decommissioning for precise platforms. Normally, it could be more expensive for the government to decommission a facility than it can be for an OCS operator to do so. Therefore, even though the P70 worth is greater than organization-derived values, it may be far more aligned with the costs that The federal government would incur to complete the decommissioning, which can be the pertinent consideration when determining the price to decommission a facility if the corporation fails to do so.

A number of commenters opposed the usage of the ratio, asserting that standard fluctuations within the demand and cost of oil and gas, coupled with the upcoming world-wide change faraway from fossil fuels to renewable Vitality, ensure it is very likely that the worth of proved oil reserves in all leases will drop as time passes.

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Other commenters asserted that BOEM need to consider the obligations from the predecessors during the chain-of-title in advance of looking for supplemental fiscal assurance from present lessees, normally the result is click here requiring “double bonding.” Reaction:

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“We’re probably discussing months just before ultimate conclusions,” pending more details from technical reports and knowledge from NBI’s Worldwide companions, Lohi stated.

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One particular commenter presented an up to date analysis of stress, together with a comparison with the a few proposed decommissioning estimate values, which was referenced by a number of commenters of their remark submissions. The commenter's Examination asserted that the outcome throughout the liability levels “are mostly depending on Each and every company's `portfolio' of decommissioning liabilities” and mentioned that in almost any portfolio of uncertain outcomes, some cost estimates will exceed their envisioned price, Although some Charge estimates might be considerably less. Accordingly, the commenter asserted, percentile values aren't additive, as precise variances from estimates would offset each other so which the P70 with the blended outcomes of the portfolio would tactic the sum on the indicate.

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Several commenters recommended the Office completely clear away the analysis to ascertain if supplemental monetary assurance is needed. One commenter specially questioned the Office to eliminate this move solely and to easily require all OCS leaseholders, regardless of monetary power, to deliver supplemental financial assurance.

BOEM agrees Together with the commenters that the decommissioning legal responsibility should not be double counted; it isn't the Bureau's intent to double rely the decommissioning liability. The restrictions are obvious that BOEM is asking for the discounted value of the reserves ( e.g.,