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December 13, 2010
Department of the Interior
Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE)
381 Elden Street, MS–4024
Herndon, Virginia 20170–4817
Attn: Regulations and Standards Branch (RSB)
Re: Increased Safety Measures for Energy Development on the Outer Continental Shelf, 1010–AD68
Dear Sir or Madam:
The American Petroleum Institute (API), The International Association of Drilling Contractors (IADC), the Independent Petroleum Association of America (IPAA), the National Ocean Industries Association (NOIA), the Offshore Operators Committee (OOC), the Offshore Equipment and Operating Procedures Joint Industry Task Forces (JITF) and the US Oil and Gas Association appreciate this opportunity to provide written comments on BOEMRE‘s already-implemented interim final rule, Oil and Gas and Sulphur Operations in the Outer Continental Shelf—Increased Safety Measures for Energy Development on the Outer Continental Shelf, 75 Fed. Reg. 63346 (Oct. 14, 2010) (hereinafter, the ―interim final rule‖).1
These trade associations and joint industry task forces represent oil and gas producers who conduct essentially all of the OCS oil and gas exploration and production activities in the Gulf of Mexico. Additionally, many of our members are involved in drilling, construction and support services for the offshore oil and gas industry and will be significantly impacted by this BOEMRE rulemaking.
(cont'd at the link.)