NOIA Urges Continued Dialogue on Proposed Air Quality Rule

RandallLuthi_webFor Immediate Release: Tuesday, June 21, 2016
Contact:  Justin Williams, (202) 465-8464,

NOIA Urges Continued Dialogue on Proposed Air Quality Rule

Washington, D.C.NOIA President Randall Luthi issued the following statement after joint trade comments were filed yesterday on BOEM’s Air Quality Control, Reporting and Compliance Proposed Rule:

“NOIA is committed to safe and sustainable offshore operations, and the countless jobs, affordable energy and energy security that it provides. That is why we joined with the American Petroleum Institute, the Offshore Operators Committee, the Independent Petroleum Association of America, the International Association of Drilling Contractors and the Offshore Marine Service Association in submitting comments to the Bureau of Ocean Energy Management (BOEM) on the Air Quality Control, Reporting and Compliance Proposed Rule. We are concerned that the proposed rule is premature and would have no beneficial impact on air quality, while greatly increasing unnecessary regulatory costs to the offshore oil and gas industry.

“In short, this rule appears to be regulations for regulations sake. BOEM has not demonstrated that revised rules are needed, nor it has it even completed the air modeling studies it commissioned to inform the rule. There are approximately forty instances in the proposed rule where BOEM has specifically solicited comments on provisions that have not been fully developed or defined. In addition, this proposal includes far more than just a few regulatory updates – it changes provisions on mobile support craft emissions, establishes a new monitoring boundary of where to determine whether there are significant impacts to air quality, and expands the current definition of a facility.

“While BOEM estimates that the rule would cost $97 million over ten years, we estimate a ten year cost upwards of $3.4 billion. This is a tremendous cost that should not be placed on industry without first thoroughly and completely reviewing all the impacts and consequences of a fully developed and articulated rule.

“We urge BOEM to re-open the public comment period to provide more opportunity for transparent collaboration between BOEM and industry.  Otherwise, BOEM enters the black box of writing the final rule without a meaningful two-way dialogue.  In addition, without BOEM’s air modeling studies in hand, rushing this rule only serves to meet a political agenda.  Continuing to seek technical input would make a future rule that is workable, effective, enforceable and meets the goals of a safe and productive offshore industry.”



NOIA is the only national trade association representing all segments of the offshore industry with an interest in the exploration and production of both traditional and renewable energy resources on the nation’s outer continental shelf.  NOIA’s mission is to secure reliable access and a fair regulatory and economic environment for the companies that develop the nation’s valuable offshore energy resources in an environmentally responsible manner. The NOIA membership comprises about 300 companies engaged in business activities ranging from producing to drilling, engineering to marine and air transport, offshore construction to equipment manufacture and supply, telecommunications to finance and insurance, and renewable energy.

National Ocean Industries Association
1120 G Street, NW • Suite 900
Washington, DC 20005

Phone: 202.347.6900 | Email: