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Offshore Companies Face Surge in BSEE Enforcement Actions and Penalties

The Energy Law

In recent years, offshore companies have witnessed a marked uptick in the number of enforcement actions undertaken by the Bureau of Safety and Environmental Enforcement (BSEE). [1] BSEE has also begun to target offshore contractors, who, until recently, have not faced exposure to agency enforcement actions. See Island Operating Co.,

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Implications of NTL 2012-N06 on OSRP Preparation and Review

The Energy Law

United States Dep’t of the Interior Bureau of Safety and Environmental Enforcement, GUIDANCE TO OWNERS AND OPERATORS OF OFFSHORE FACILITIES SEAWARD OF THE COAST LINE CONCERNING REGIONAL OIL SPILL RESPONSE PLANS, NTL No. 2012-N06 (2012), [hereinafter NTL 2012-N06]. NTL 2012 N-06, 3. NTL 2012 N-06, 5.

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EPA and BSEE Team Up to Resolve Offshore Environmental Violations

The Energy Law

The Violation In March 2012, BSEE conducted an inspection of ATP’s floating production platform facility, known as the ATP Innovator, while it was moored to the sea floor about 45 nautical miles offshore of southeastern Louisiana (about 125 miles south of New Orleans) and engaged in the production of oil and natural gas. .

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EPA Releases Final Rule Requiring Oil and Gas Sources to Report Emissions of Greenhouse Gases

The Energy Law

The industry segments covered by the rule are: offshore petroleum and natural gas production; onshore petroleum and natural gas production; onshore natural gas processing; onshore natural gas transmission compression; underground natural gas storage; liquefied natural gas (LNG) storage, import, and export; and natural gas distribution.

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The Fifth Circuit Rejects the DOJ’s Attempt to Charge Black Elk Contractors with OCSLA Felonies

The Energy Law

In 2010, Black Elk Energy Offshore Operations, LLC (“Black Elk”) owned and operated a production facility on the West Delta 32 Lease Block located in the Gulf of Mexico. In September 2012, Black Elk hired Compass Engineering and Consulting, LLC (“Compass”) to draft construction plans for maintenance on the platforms. United States v.

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Fifth Circuit Reverses District Court’s Imposition of Attorneys Fees on DOI for Reissuance of Drilling Moratorium in GOM Following Deepwater Horizon Incident

The Energy Law

Shortly thereafter, the Secretary lifted the second moratorium, effectively mooting Hornbeck’s case. Hornbeck Offshore Servs., 3d__, 2012 U.S. Specifically, Hornbeck argued that the DOI’s rescission and re-issuance of the moratorium disobeyed the court’s order enjoining enforcement of the initial moratorium. Salazar , __F.3d__,

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BSEE’s Investigations and Review Unit Changes the Playing Field on the OCS

The Energy Law

In all but the most egregious cases, the typical civil enforcement action has in the past been resolved with the correction of the noncompliance and the payment of any required civil penalty. For reasons of logistics, the interviews are unlikely to take place offshore. See 30 C.F.R. §§ 250.191, 250.1404.

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