Upsetting The Outer Continental Shelf Ecosystem Through Overbonding

At a time when the Bureau of Safety and Environmental Enforcement's ("BSEE") Well Control Rule has shifted focus away from its sister agency's regulatory maneuvering, the Bureau of Ocean Energy Management ("BOEM") is changing the way it approaches securitizing decommissioning obligations – a shift with the potential to change the face of the Outer Continental Shelf ("OCS").

Industries, like ecosystems, thrive on symbiotic relationships. Even companies that compete for resources need each other to ensure the health of the industry as a whole. While BOEM's anticipated new requirements for supplemental financial security may not affect majors directly, they do affect the smaller players, and the loss of those smaller players will ultimately affect the health of the OCS economic ecosystem.