Overview
Title
Agency Information Collection Activities; Pollution Prevention and Control
Agencies
ELI5 AI
The government wants to know how clean the air is around places that get oil and gas from the ocean. They are asking people to tell them about it using a new computer system, but some people think it's too hard and takes too long.
Summary AI
The Bureau of Ocean Energy Management (BOEM) is planning to renew its information collection under the Paperwork Reduction Act, with a focus on pollution prevention and control in offshore oil and gas activities. The agency is seeking public comments on this information collection, which primarily concerns air quality standards compliance and the reporting of emissions. To streamline and improve this process, BOEM is introducing a new system, the OCS Air Quality System (OCS AQS), to replace outdated software. The public has until February 11, 2021, to submit comments, which will help BOEM minimize the reporting burden while ensuring compliance with environmental regulations.
Abstract
In accordance with the Paperwork Reduction Act of 1995, the Bureau of Ocean Energy Management (BOEM) proposes to renew its information collection control number 1010-0057 through the Office of Management and Budget (OMB).
Keywords AI
Sources
AnalysisAI
The document published in the Federal Register by the Bureau of Ocean Energy Management (BOEM) announces a proposal to renew its information collection concerning pollution prevention and control in offshore oil and gas activities. This renewal is part of an ongoing effort to comply with the Paperwork Reduction Act of 1995. The agency is requesting public comments on this proposal before February 11, 2021. This information collection is fundamental to ensuring that offshore activities comply with national air quality standards and other environmental regulations. The introduction of the new OCS Air Quality System (OCS AQS) aims to streamline the process by replacing outdated software.
Key Issues and Concerns
There are several critical issues highlighted in this document. One concern is the potential increase in the reporting burden. While the document notes an increase from 44 to 64 hours per facility, it does not provide details about the financial implications for respondents. This increase implies additional costs for compliance, yet the document lacks clarity on compensation or any adjustments to offset these costs.
Another concern involves the definition and scope of 'facilities'. The Offshore Operators Committee (OOC) challenges the requirement for reporting by drilling rigs and construction vessels, arguing that they do not meet the technical definition of a "facility" when not attached to the seabed. BOEM's response does not wholly address this ambiguity, potentially leading to unnecessary reporting burdens for operators without clear justification.
The transition from the Gulfwide Offshore Activity Data System (GOADS) to OCS AQS also introduces complexities and potential confusion among respondents. With any such transition, particularly involving technical platforms, adequate onboarding and transitional support are essential to minimize disruption. The document does not detail measures to facilitate a smooth transition for users.
Additionally, the document contains technical jargon and references to various CFR sections and legislation, such as the Paperwork Reduction Act, which may hinder understanding among those not well-versed in legal or regulatory frameworks. This could limit public engagement and the ability to provide substantive feedback.
Finally, although BOEM acknowledges technical errors with OCS AQS, it does not elaborate on these issues or how they might affect the reporting process, leading to potential uncertainty and lack of preparation among respondents. While burden hours have increased, there is no clear plan within the document on how BOEM intends to mitigate these additional burdens or provide necessary support.
Impact on the Public and Specific Stakeholders
The proposed changes may broadly impact the public by aiming to enhance air quality and environmental protection measures associated with offshore energy activities. This is crucial for coastal communities and ecosystems that could be affected by offshore energy production.
However, specific stakeholders, particularly those involved in offshore oil and gas operations, may face increased administrative demands and costs. The additional burden hours and the transition to a new reporting system could require more resources and time from operators, affecting their operations. If these challenges are not adequately addressed, stakeholders may experience operational inefficiencies or increased compliance costs, which could be passed on to consumers.
The document underscores BOEM's ongoing efforts to balance environmental safeguards with industry compliance. Nevertheless, it also highlights the need for more transparent communication and support to ensure these regulatory objectives are met without imposing undue burdens on stakeholders.
Issues
• The document discusses the renewal of information collection control number 1010-0057 but does not provide details on the potential financial burden on respondents beyond an increase from 44 to 64 hours per facility. This could imply additional costs without clarity on compensation or adjustments.
• There is a concern raised by the OOC regarding the requirement of reporting from drilling rigs and construction vessels when these do not meet the definition of 'facility'. BOEM's response seems to maintain a stance that may continue to impose unnecessary burden without further clarification or amendment.
• Complexity arises from the reporting requirements, particularly with the transition from GOADS to the OCS AQS system. This might lead to confusion among respondents due to a lack of comprehensive onboarding or transitional support.
• In several areas, the document relies heavily on industry jargon and technical references, such as the mention of several CFR sections and the Paperwork Reduction Act. This can hinder understanding for individuals not familiar with these legislations.
• BOEM acknowledges 'technical errors' with OCS AQS but does not clarify what these errors are or how they might affect the reporting process, leaving potential uncertainty for the respondents.
• Despite acknowledging increased burden hours, the document does not address how BOEM intends to mitigate this or provide support to the respondents.