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Wednesday, October 17, 2018

PUBLIC MEETING ON US GULF FPSO REGULATIONS

INTERTANKO was present as an observer at the FPSO meeting held on 3 May 2001 in Houston.

The meeting was chaired by Commander Peter Richardson, USCG.  Also in attendance were several Coast Guard headquarters and regional personnel, a representative of the Minerals Management Service (MMS) as well as industry.  The meeting had approximately 150 attendees.

Commander Richardson explained that the purpose of the meeting was to be a listening session.  Consequently, the Coast Guard was not going to make a presentation but was there to take public input.  The public docket was, therefore, being reopened for 30 days to allow the introduction of both oral and written comments.

The first presenter was from Deepstar Industry Consortium.  The Consortium, which is composed of 15 deepwater operators and 40 vendors, is dedicated to developing enabling technology for deepwater drilling.  The Consortium urged the Coast Guard to develop better regulations which take account of the current technology.  They indicated that they would be submitting written comments.

The next speaker was from the Federal Pilots Association of New Orleans. He criticized the final Environmental Impact Statement (EIS) on FPSOs for indicating that the use of federal pilots for the shuttle tankers (which is permitted because the tankers will be engaged in "coastwise" trading) was potentially less safe than using state pilots.  He stated that his pilotage group is just as, if not, more qualified than the state pilots and asked that the EIS be revised to reflect that.

A speaker from the Offshore Operators Committee (OOC), an industry group that represents drillers and producers in the Gulf of Mexico, stated that there was no need for new regulations.   The OOC believes that if anything, FPSO operations require nothing but tweaking of current requirements.  The OOC also stated that tanker regulations should not be applied to FPSO operations. The speaker wanted the Coast Guard and MMS to develop a streamlined permitting process that would avoid duplicative requirements.  The OOC would be submitting written comments.

A representative from the Shuttle Tanker Committee of the American Petroleum Institute (API) was next.  He urged the Coast Guard and MMS to use existing industry standards since most of the operators considering FPSO operations in the Gulf of Mexico are using such vessels safely in other places of the world.  API also wants to use existing tankers and tug-barge units as shuttle tankers.  API also urged that the entire FPSO "system" be evaluated in developing requirements and that the drilling, production, storage and transportation components not be viewed piecemeal.

A speaker from Lloyd's Register asked that the role of classification societies be specified in any regulations developed.  He also urged the adoption of existing international and industry standards.

The final speaker was from the Offshore Marine Services Association and he stated that the Coast Guard should not rely on antiquated rules for FPSOs. He also urged the Coast Guard to consider dynamically positioned vessels to be "moored" or "held fast."

With no other speakers, Commander Richardson then described the next steps. There will be no further listening sessions and the FPSO Working Group, a joint Coast Guard-MMS body, was going to continue meeting in order to develop a course of action.  The working group was reviewing existing FPSO operations and requirements, making site visits to such operations worldwide, and then will make recommendation to senior officials in the agencies as to the best course of action.  This process is expected to be completed by the end of the year.  The final step would be to implement the recommendations.  The Coast Guard's goal is not to have new regulations if they can avoid it.  It was not decided how, or when, additional industry input would be solicited. 

The Coast Guard is reopening the period for public comment on Floating Production, Storage, and Offloading Units in the Gulf of Mexico. The public meeting was part of a regulatory project and the comment period has been re-opened to give more time to collect data and to develop comments.  Comments must be received on or before 16 July 2001. Comments or questions may be directed to Jonathan Benner on e-mail: jonathan.benner@troutmansanders.com