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Some commenters asserted that the P70 values, and sometimes even the P50 values, exceed their inner estimates for their decommissioning expenditures and that BOEM need to allow the usage of enterprise-supplied estimates.
Commenters advisable that BOEM be steady and intentional in its use of “economical assurance,” “safety,” and “bond” throughout the closing rule. Specifically, they questioned BOEM to contemplate utilizing the global term “protection” as in the 2020 Proposed Rule in lieu of “economical assurance,” which alternatively can make reference to the process of furnishing protection as opposed to the security by itself. Response:
BOEM acknowledges the commenters' assist, as well as the Department is finalizing, as proposed in 30 CFR 556.901(d), the option for businesses with out issuer credit rankings to ask for the Regional Director to find out a proxy credit score according to audited economical info for The newest fiscal year along with the S&P credit model. three. Valuing Proved Oil and Fuel Reserves
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Conversely, quite a few commenters asserted that the P70 worth was not adequately conservative to safeguard other functions and the general public inside the party of default.
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BOEM agrees with the commenters which the decommissioning liability shouldn't be double counted; it is not the Bureau's intent to double depend the decommissioning liability. The regulations are apparent that BOEM is asking for the discounted worth of the reserves ( e.g.,