There is no inconsistency with BSEE selecting to not need appeal bonds at the phase of the buy to decommission and BOEM choosing to require them for the phase of financial assurance calls for. The BSEE determination is predicated in large part on the assumption that fiscal assurance is already set up by the time it issues decommissioning orders and so it doesn't face the threats that BOEM does at time of demanding financial assurance. See 88 FR 23569, 23579 (April eighteen, 2023) (noting BSEE's reliance to the monetary assurance rules for identifying an appeal bond is just not needed for the BSEE application).
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Some commenters asserted the P70 values, and occasionally even the P50 values, exceed their inner estimates for their decommissioning expenses and that BOEM really should make it possible for using corporation-delivered estimates.
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Commenters asserted that organizations would need to determine a proxy credit score ranking using the “intricate money types of S&P and Moody's”, which would be time intensive, Which delivering the knowledge that BOEM proposed to require in an effort to perform a proxy score would represent a stress for little providers. Response:
I will not likely address other essential issues in the realm of Dutch and Danish domestic authorized orders, together with their interactions with the eu human rights technique, or even the competence with the ISA and its organs.
A commenter requested the Department rethink allowing oil and fuel operators to decommission pipelines set up and should be certain that BSEE's decommissioning expenditures adequately meet up with the expense of eradicating all pipeline in the seafloor. Response:
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A number of commenters supported the use of the P70 value and proposed that BOEM undertake the P70 worth in the final rule for consistency with the mentioned function in the proposed rule: to make sure that current lessees are economically in the position to complete their decommissioning obligations. Response:
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