From: The Honorable Charles W. Boustany, Jr.
Sent By: kaitlin.sighinolfi@mail.house.gov
Date: 6/20/2016

Deadline to sign on is Thursday, June 23rd

Dear Colleague:

Please join me in sending the below letter to the Bureau of Safety and Environmental Enforcement (BSEE) requesting they delay implementation of the Well Control Rule until questions from industry have been addressed. Much of the language published in the final rule was vague at best, and we understand that numerous companies have submitted detailed questions to BSEE in effort to gain explicit understanding of what is required of them in order to comply with the law.  Questions such as how BSEE will address ongoing operations when the rule takes effect, and whether or not new permits are required or if operations can continue under previously approved permits demonstrate how indistinguishable the final rule language was for implementation.

At a time when the oil and gas industry has been inundated with new rules and regulations required of them, it is critical that the Administration provide clear direction so that safety, not convenience, is the driving force behind this initiative.

For questions, or to sign the letter, please contact
kaitlin.sighinolfi@mail.house.gov
.  The deadline to sign the letter is COB Thursday June 23rd.

Sincerely,

Charles W. Boustany, Jr., M.D.

Member of Congress

____________________________________________________________________________________________________________________________________________________________________

Dear Director Salerno:

We write to urge you to delay implementation of the final well control rule before it takes effect on July 28, 2016. Much of the language published in the final rule was vague at best, and we understand that numerous companies
have submitted detailed questions to BSEE in effort to gain explicit understanding of what is required of them in order to comply with the law.  Questions such as how BSEE will address ongoing operations when the rule takes effect, and whether or not new permits
are required or if operations can continue under previously approved permits demonstrate how indistinguishable the final rule language was for implementation.

The Deepwater Horizon disaster was a terrible tragedy, one we understand deeply throughout Louisiana.  We would argue that no one wants to prevent any such disasters in the future as much as we do.  While risk can never be
completely eliminated, we believe efforts must be taken to reduce that risk and improve safety of operations.  We remain committed to that goal.  Now that the rule has been finalized, we want to ensure that the industry is able to continue actively working
throughout the Gulf of Mexico.  Implementation of new rules is challenging for any industry.  Throughout our discussions with those working in the Gulf of Mexico, we believe they want to comply with new regulations, but have not been provided the necessary
guidance in order to realistically do so. 

BSEE’s final rule language is unclear on major details, such as whether or not the agency will require new permits for current operations, as well as specific industry standard questions, like whether or not BSEE intends to
apply subpart G for BOPEs used in coiled tubing operations. We are concerned that the confusion surrounding industry compliance with the final rule could increase risk, stifle innovation and delay implementation of new technologies which would improve safety
and operations industry-wide.  We know this is not BSEE’s intent, and we urge either re-evaluation or release of updated language for the final rule that addresses questions submitted by industry.  We are sure you would agree that safety, not convenience,
must always be the driving force behind these initiatives.

We strongly believe additional dialogue with industry experts, through substantive technical workshops, is necessary to improve safety and fix serious technical uncertainties that currently exist in the rule.  We appreciate
your consideration of our concerns, and remain committed to working with you and the Administration, to achieve safe operations offshore.  We look forward to your timely response.

Sincerely,