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Kumkum Ray
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OEMM Web Team
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NTL No. 2008-N07 |
Effective Date: August 28, 2008
|
Notice to Lessees and Operators of Federal Oil, Gas,
and Sulfur Leases and Pipeline Right-Of-Way Holders in the Outer Continental Shelf
Supplemental Bond Procedures
NOTE:
NTL 2008-N07
is available for download in Adobe's Portable
Document Format (PDF).
(? KB)
The Minerals Management Service (MMS) is
issuing this NTL to clarify the procedures and criteria MMS uses to
determine when a supplemental bond is required to cover potential
decommissioning liability. This NTL has been updated and revised to clarify
in paragraph III, that: 1) the lessee must initially meet a minimum net
worth of $65 million, as indicated on the lessee’s audited balance sheet; 2)
the lessee must initially meet an allowable cumulative decommissioning
liability amount calculated using only record title interest as a percentage
of its net worth; and 3) a portion of the value of a lessee’s proved
producing reserves may be added to their net worth, only after meeting
certain financial criteria. This NTL supersedes and replaces NTL No.
2003-N06, effective June 17, 2003.
Background
For each OCS lease, 30 CFR 256.53(d) and (e)
provide the Regional Director the authority to require additional security
[i.e. security above the amounts prescribed in 30 CFR 256.52(a) and
256.53(a) and (b)] in the form of a supplemental bond, based upon a
calculation of the potential decommissioning liability and an evaluation of
the lessee’s ability to carry out present and future financial obligations
in this regard. Each lease, right-of-use and easement (RUE), and
right-of-way (ROW) with determined liability must be covered by a
supplemental bond unless at least one lessee or holder of a RUE or ROW
demonstrates to the satisfaction of the MMS that it has the financial
ability to ensure that wells can be plugged and abandoned, platforms removed
and the drilling and platform sites, including pipeline corridors, cleared
of all obstructions, per MMS regulations. Supplemental bonds may
additionally be required to satisfy other lease obligations, as determined
by the Regional Director.
I. General
This NTL sets forth the procedures and
criteria that MMS uses to: calculate decommissioning liability, determine
the risk regarding the lessee’s ability to carry out present and future
financial obligations, and specify the types and terms of the supplemental
bonds or other additional security the MMS may require or accept. The MMS
reserves the right to vary from the procedures or criteria in this NTL on a
case-by-case basis within the framework established in the governing
regulations.
II. Timing of Review of Potential Lease,
RUE, and ROW Decommissioning Liability
Generally, MMS will conduct an initial review
of the potential decommissioning liability when a lessee submits an
Exploration Plan (EP) for approval.
- Reviews will also be conducted when
a lessee or holder requests approval of one of the following:
- Assignment of a record title
interest, or a portion thereof, in a lease.
- Significant revision to an
approved EP.
- Development and Production Plan
(DPP) or a significant revision to an approved DPP.
- Development Operations
Coordination Document (DOCD) or a significant revision to an
approved DOCD.
- Deepwater Operations Plan
(DWOP)
- Application for a pipeline ROW
or modification of an existing pipeline ROW.
- Assignment of an interest in a
pipeline ROW grant with associated platform facilities.
- Significant revision to an
approved pipeline installation plan for a pipeline having associated
platform facilities.
- Application for or modification
of a RUE.
- The MMS also may conduct reviews:
- periodically;
- when MMS becomes aware of
information that indicates a change in the financial strength of the
company or potential cumulative decommissioning liability; or
- when a Notification of an
Incident of Noncompliance (INC) is issued related to safety,
environment, non-payment of royalty, or other violations of MMS
regulations.
- If the lessee takes an action that
causes MMS to initiate a review and then withdraws the action, at MMS’s
discretion, the review may continue and, if necessary, the submission of
a supplemental bond may be required.
III. Determination of Financial Strength
and Reliability
Generally, a supplemental bond will be
required for a lease, RUE, or ROW, unless it is determined that at least one
record title owner or holder of the RUE or ROW meets the following
conditions that demonstrate financial strength and reliability:
- Provides an independently audited
calculation of net worth (including an independent auditor’s report and
a balance sheet) equal to or greater than $65 million, in accordance
with United States Generally Accepted Accounting Principles (U.S. GAAP)
or the International Financial Reporting Standards (IFRS), where
accepted by the U.S. Securities and Exchange Commission (SEC) in their
filings.
- Cumulative decommissioning liability
must be less than or equal to 50 percent of the most recent and
independently audited calculation of net worth. The MMS will use the
procedure outlined in paragraph IV of this NTL, to calculate the
cumulative decommissioning liability for each OCS lease, RUE, or ROW for
which the lessee owns record title interest or is a holder.
- Demonstrates reliability as
evidenced by the following:
- number of years of successful
operations and production of oil and gas or sulphur in the OCS or in
the onshore oil and gas industry;
- credit rating(s), trade references,
and verified published sources;
- a record of compliance with current
and previous governing laws, regulations, and lease terms; and
- other factors that indicate
financial strength or reliability;
and, the lessee or holder either:
- Produces fluid hydrocarbons in excess of
an average of 20,000 barrels of oil equivalent (BOE) per day from OCS
leases for which the lessee owns a record title interest.
Calculations of production will be based
on the most recent 12 months for which data and information are
available. [For the purposes of computing BOE for natural gas, 5.62
thousand cubic feet of natural gas equals 1 BOE as measured fully
saturated at 14.73 pounds per square inch atmosphere and 60 degrees
Fahrenheit according to 30 CFR 250.1203(b).]
- Demonstrates:
Meeting the criteria set forth in the
table below by providing independently audited financial statements
(including an independent auditor’s report and a balance sheet), in
accordance with U.S. GAAP or the IFRS, where accepted by the SEC in
their filings.
For lessees with stockholders’ equity or net worth of: |
If the lessee’s cumulative potential decommissioning liability is <
25 percent of stockholder’s equity or net worth, the lessee’s debt
to equity ratio (total liabilities/net worth) must be: |
If the lessee’s cumulative potential decommissioning liability is
>25 percent but < 50 percent of stockholder’s equity or net worth,
the lessee’s debt to equity ratio (total liabilities/net worth) must
be: |
$65 Million to $100 Million |
<
2.5 |
<
2.0 |
Above $100 Million |
<
3.0 |
<
2.5 |
In III.5 of this NTL only, the lessee may
request MMS to consider future net revenue associated with the value of
proved producing reserves in the calculation of net worth. The lessee must
choose either scenario A or B below in which MMS will evaluate all of the
lessee’s properties.
- The lessee may request that MMS consider
the lessee’s future net revenue associated with the lessee’s value of
proved producing reserves in the calculation of the lessee’s net worth,
for all OCS leases in which the lessee owns a record title interest
equal to the percentage of their interest. Based on potential risk
associated with the reserves, MMS may include up to 25 percent of
the reserve value in its calculation of the lessee’s net worth.
- The lessee may request that MMS consider
the lessee’s future net revenue associated with the lessee’s value of
proved producing reserves in the calculation of the lessee’s net worth
by providing to MMS for all OCS leases in which the lessee has a net
revenue interest as verified by an independent third-party estimate of
the total proved producing reserves. This third-party reserve report
shall break down proved producing reserves on a lease, reservoir and
well completion basis. It shall also include a cash flow spreadsheet to
show anticipated production, expenses, and cash flow. All net revenue
and operating expense interests must be provided and certified by a
third party. Upon receipt of this information, MMS will determine the
value of the proved producing reserves to be included in the lessee’s
net worth. If the lessee requests an analysis based upon record title
and operating rights interest, the decommissioning liability applied in
paragraph III.2 of this NTL will also account for the decommissioning
liability for each OCS lease, for which the lessee owns operating rights
interest. Based on potential risk associated with the reserves, MMS may
include up to 50 percent of the reserve value in its calculation of the
lessee’s net worth.
In addition to the other information included
in this section, the determination of the lessee’s or RUE or ROW holder’s
financial strength is valid for up to one year. MMS may extend the
determination, one year at a time, if: a) an independent accounting firm
provides the most recent audited evidence of your entities financial
strength and reliability, b) you continue to meet the criteria established
above, and c) if within the first two years of acquiring a financial waiver
of supplemental bonding you provide 10-Qs or quarterly reviews for the first
eight quarters of your financial waiver of supplemental bonding.
IV. Determination of the Decommissioning
Liability
Regardless of any assumptions made by MMS in
estimating decommissioning costs, the lessee is responsible for ensuring
that all decommissioning obligations on its lease are satisfied. When MMS
requires the lessee to provide and maintain a supplemental bond, the amount
of the supplemental bond for the lease will be determined as follows:
- The
MMS will estimate the cost to plug and abandon wells, remove platforms
and other facilities, and restore the lease to its original condition by
clearing the obstructions from wells, platform sites, RUEs, and ROWs.
MMS assumes that all facilities will be removed and transported to shore
for recycling or disposal.
- The
MMS calculations are drawn from best available data and include costs
for removing and transporting the facility onshore, plugging and
abandoning wellbores, and performing site clearance according to the
requirements of 30 CFR 250 Subpart Q and Gulf of Mexico NTL No. 98-26.
This estimate is based upon costs in the Region and assumes that a rig
will be used to plug and abandon all wellbores. These figures will be
adjusted when available information shows that the numbers are not
accurate. The lessee may provide additional information for
consideration when MMS estimates decommissioning liability. When
providing additional data, the lessee should explain the basis for the
data.
- The following procedure may be used
to estimate the need for and amount of supplemental bonds for all
entities:
- Determine the decommissioning liability for all
leases, RUEs, and ROWs for which the lessee owns record title
interest or is a holder (and the decommissioning liability
associated with the lessee’s operating rights interest where the
lessee has requested the MMS to include proved producing reserves
for such operating rights interest in the calculation of its net
worth as discussed herein).
- Apply lease-specific bonds (i.e., lease-specific
general bonds, lease-specific supplemental bonds, and lease-specific
guarantees) to identified leases.
- Exclude from the lessee's decommissioning
liability calculation, for the purpose of supplemental bond
determination, the full amount of the decommissioning liability for
any lease(s) for which MMS has determined that one or more
co-lessees have sufficient financial strength such that it is not
necessary to require a supplemental bond. The MMS will exclude less
than the full amount of the decommissioning liability when it is
determined that additional security is needed based upon the
financial or operational history of the companies involved.
- After calculating the remaining potential
liability, the financial strength and reliability of the company
will be evaluated using the procedures discussed herein. The MMS
will then determine the need for a supplemental bond and the amount.
- Request lease-specific supplemental bonds through
the designated operator who coordinates the submittal with the
lessees.
- The lessee may facilitate the
review and approval of the request by providing detailed information on
existing leasehold facilities. The lessee may provide evidence to
support an adjustment in the estimate of the cumulative potential
decommissioning liability. This evidence may include:
- the itemized data and information by
lease, RUE, or ROW used as a basis for the estimate of the
cumulative potential decommissioning liability represented by wells
and facilities on the lease(s), and
- the itemized data and information by
lease, RUE, or ROW on which a third party bases its estimate of
cumulative potential decommissioning liability.
- When conducting a subsequent review of
the need for a supplemental bond, MMS will consider all pertinent
information which affects bonding assessment, such as the number of
wells drilled or plugged and abandoned in the time that has elapsed
since the last review of the lessee’s cumulative potential
decommissioning liability, the number of platform installations or
removals since the last review, changes in the amount and value of
reserves being produced, the projected rates of oil and gas production,
inflation, and other changes in the market conditions. The objective of
the review and analysis will be to ensure that the supplemental bond
coverage or alternate form of security provided is not less than the
amount established based upon the lessee’s cumulative potential
decommissioning liability.
V. Acceptable Forms of Supplemental
Bonding
Within 45 days following MMS written
notification, the lessee must submit one of the following to meet the
supplemental bond obligation:
- A
lease, RUE, or ROW-specific surety bond, U.S. Treasury Securities, or an
alternate form of supplemental security approved by the Regional
Director, in the full amount required. If the value of the lessee’s
security falls below this amount, or if the U.S. Treasury no longer
certifies that the company that issued the bond is acceptable, the
lessee must notify MMS within 15 days and take necessary action to meet
the supplemental bond obligation. Note that MMS will require any
security presented as a means for satisfying the supplemental bond
requirement to fully comply with applicable regulations, requirements or
recommendations of the U.S. Treasury.
- A
plan to MMS for review and approval whereby the lessee commits to fully
fund a lease or RUE-specific decommissioning escrow account. Generally,
the lessee must fully fund a lease or RUE-specific decommissioning
account within four (4) years or by the beginning of the year in which
it is projected that 80 percent of the originally recoverable reserves
have been produced, whichever is earlier. The plan must include the
following:
- An initial payment into the
lease or RUE-specific decommissioning escrow account equal to or
greater than 50 percent of the estimate of the cumulative potential
lease/RUE decommissioning liability. At the lessee’s request, the
MMS may approve an initial payment of less than 50 percent following
the review of a third-party estimate of the proved producing
reserves for the lease, if MMS determines that the lesser amount
doesn’t create a risk to the Government.
- A prescribed time schedule for
making specified incremental payments (e.g., monthly payments) in
amounts that will ensure that the amount in the lease or
RUE-specific decommissioning account will increase at a faster rate
than the rate at which the originally recoverable reserves are being
produced from the lease.
- A commitment by the financial
institution in which the lessee established the lease or
RUE-specific decommissioning account to notify MMS of the date and
amount of the initial deposit and of each incremental payment into
the account.
- A
risk insurance policy for the benefit of MMS that covers the
residual liability in the event of any catastrophic failure that
prevented the completion of the remaining payments. This requirement
has been met, in the past, by including MMS as a beneficiary on
existing policies.
The MMS will review the above-described
information and will approve it either as submitted or request specific
revisions. For example, MMS will analyze both the initial payment amount as
well as the time schedule for making specified incremental payments based on
an analysis of current, past, and projected rates of production from the
leasehold(s), or cash flow for facilities utilized by ROW, characteristics
of the producing reservoir(s), decommissioning information available in
MMS’s databases, and/or other information provided.
The lessee must immediately submit, and
subsequently maintain, a supplemental bond in an amount equal to the
remaining portion of the estimate of the amount of the lessee’s cumulative
potential decommissioning liability in the event the lessee fails to:
- Make the initial payment into a
MMS approved lease or RUE-specific decommissioning account; or
- Pay on the date due an
incremental payment into the MMS-approved lease or RUE-specific
decommissioning account in the amount agreed.
The following table provides an example of an
incremental payment schedule for a lease or RUE-specific decommissioning
escrow account.
The following is an example of a lease-specific
decommissioning account, the time schedule prescribed, and the
amount of each incremental payment, to fund the account over a
4-year period. This example describes a situation in which, based on
our estimate of your cumulative potential decommissioning liability,
we required a $5 million supplemental bond. |
Year |
Percent of Recoverable Reserves Produced at End
of Year as a Percentage of Originally Recoverable Reserves |
Dollar Amount (Security) Required at Start of
Year |
Quarterly Payment During Year |
1 |
20 |
$2,500,000 |
$156,250 |
2 |
40 |
$3,125,000 |
$156,250 |
3 |
60 |
$3,750,000 |
$156,250 |
4 |
80 |
$4,375,000 |
$156,250 |
Assumptions and Notes: 1. Total Supplemental Bond Amount:
$5,000,000
2. The amount of the initial payment is 50 percent of the
cumulative potential decommissioning liability since 50 percent is
greater than the percentage of the originally recoverable reserves
projected to be produced by the end of Year 1.
3. By the end of Year 3, MMS projects that 60 percent of the
originally recoverable reserves will have been produced. Therefore,
the lessee will need to fund at least 60 percent of the total
supplemental bond ($3,000,000 = 60% x $5,000,000) by the start of
Year 3.
4. By the end of Year 4, MMS projects that the lease will have
produced over 80 percent of the originally recoverable reserves.
Therefore, the lessee will need to fund the entire $5,000,000 by the
end of Year 4. Quarterly payments of $156,250 during the 4-year
period will increase the fund to $5,000,000 by the end of Year 4. |
VI. Using a Third-Party Indemnity In Lieu
of a Supplemental Bond
The lessee may submit a third party indemnity
agreement in lieu of a supplemental bond. The indemnity must be provided by
a third party (indemnitor) who will guarantee compliance with all lease
obligations. The indemnitor must also comply with all requirements in 30 CFR
256.57. The MMS will accept a third party indemnity only if the indemnitor
and the indemnitee agree to meet all of the criteria below.
- The
indemnitor must:
-
Meet the qualifications for a lessee in 30 CFR 256.35(b);
-
Demonstrate satisfactory levels of financial strength and business
history that exceed financial and production thresholds in paragraph
III of this NTL; and
-
Not have total outstanding and proposed indemnifications that exceed
25 percent of its unencumbered net worth in the United States.
- The
MMS will review the financial information that the indemnitee or the
indemnitor submits to determine an indemnitor’s financial strength,
business history, and compliance with current financial and production
thresholds. The indemnitee or the indemnitor will provide information
MMS determines is necessary including the indemnitor’s:
- Current rating for its most
recent bond issuance by either Moody's Investor Service or Standard
and Poor's Corporation;
- Net worth, taking into account
potential liabilities under its guarantee of compliance with all the
terms and conditions of the lease, MMS regulations, and any other
existing guarantees to MMS;
- Ratio of current assets to
current liabilities, taking into account potential liabilities under
its guarantee of compliance with all the terms and conditions of MMS
lease, RUE, or ROW regulations, and any existing guarantees to MMS;
and
-
Unencumbered fixed assets in the United States.
- The
MMS will review the following financial information that the indemnitee
or the indemnitor submits and that an officer of the company certifies
as correct:
- Independently audited financial
statements (including an independent auditor’s report and a balance
sheet), in accordance with U.S. GAAP or the IFRS, where accepted by
the SEC in their filings.
-
If within its first two years of acquiring a financial waiver of
supplemental bonding, 10-Qs or quarterly reviews for the first eight
quarters of the indemnitor’s financial waiver of supplemental
bonding.
- An
evaluation will be based on the stability of the indemnitor, in part on
the length of time that the indemnitor has been in continuous operation.
An indemnitor’s continuous operation:
- Is the time immediately before
submission of an indemnity agreement; and
-
Does not include periods of interruption of operations not within
indemnitor’s control and that do not affect the likelihood of the
indemnitor remaining in business during the indemnitee’s
exploration, development, production, plugging, removal, and
clearance operations on the lease, RUE, or ROW.
- The
indemnitor must submit an indemnity agreement providing for compliance
with all lease obligations, the obligations of all operating rights
owners, and the obligations of all operators on the lease. A third-party
indemnity must contain each of the following provisions:
- If the indemnitee, the
operator, or an operating rights owner fails to comply with any
lease term or regulation, the indemnitor must take corrective action
or provide within 7 calendar days sufficient funds for MMS to
complete corrective action.
-
If the indemnitor takes corrective action to bring a lease into
compliance with MMS requirements or provides funds for MMS to bring
the lease into compliance, these actions do not reduce the
indemnitor’s liability.
- If
MMS approves the third party indemnity, the indemnitor must submit an
indemnity agreement that meets the following criteria, (see Attachment 1
for Example Agreement):
- The indemnity agreement must be
executed by the indemnitor and all persons and parties bound by the
agreement.
- The indemnity agreement must
bind each person and party executing the agreement jointly and
severally.
- When a person or party bound by
the indemnity agreement is a corporate entity, two corporate
officers who are authorized to bind the corporation must sign the
indemnity agreement.
-
The indemnitor and the other corporate entities bound by the
indemnity agreement must provide MMS copies of:
- the authorization of the
signatory corporate officials to bind their respective entities;
- an affidavit certifying
that the agreement is valid under all applicable laws; and
-
each entity’s appropriate authorization to
execute the indemnity agreement.
- If the indemnitor or another
party bound by the indemnity agreement is a partnership, joint
venture, or syndicate, the indemnity agreement must bind each party
who has a beneficial interest in the indemnitor; and provide that,
upon MMS demand under the third party indemnity, each party is
jointly and severally liable for compliance with all terms and
conditions of the lease.
- The indemnity agreement must
provide that, within seven (7) calendar days of a demand for
forfeiture under 30 CFR 256.59, the indemnitor will either commit
itself to take all necessary corrective action or provide sufficient
funds for MMS to take corrective action.
-
The indemnity agreement must contain a confession of judgment. It
must provide that, if it is determined that the indemnitee, the
operator, or an operating rights owner is in default of the terms of
the lease or in violation of the OCS Lands Act (OCSLA) or its
implementing regulations, the indemnitor will not challenge the
determination and will remedy the default.
- If an
indemnitor wishes to terminate the period of liability under its
indemnity, it must:
- Notify the indemnitee and MMS
at least 90 days before the proposed termination date;
- Obtain MMS approval for the
termination of the period of liability for all or a specified
portion of the indemnitor’s indemnification; and
-
Remain liable for all obligations accrued during the period that the
indemnitor’s indemnification is in effect.
- Each indemnity agreement is deemed
to contain all terms and conditions above, even if the indemnitor has
omitted them.
VII. Termination of Supplemental Bond or
Third Party Indemnity, or Determination that a Supplemental Bond is Not
Necessary
MMS reserves the right to deny the lessee’s
request for a finding that a supplemental bond is not necessary, even though
an independent accountant provides an audit and certification that the
lessee meets the financial strength and performance criteria described
herein. Normally, such a denial or revocation of a previous finding will be
based on a review of independently audited information that indicates that
recent or anticipated future events may adversely affect the lessee’s
ability to comply with current and/or future decommissioning obligations.
The MMS may also require a supplemental bond on any lease, regardless of any
prior determination under these requirements, if it is determined that the
designated operator has not fully and consistently complied with MMS
regulations.
- When
any of the following occur, the lessee must take necessary action
immediately to meet these requirements. If the lessee does not, MMS may
issue a civil penalty, stop operations on the lease, or take any other
action authorized by the OCSLA or the implementing regulations.
- The MMS requires the lessee to
provide a supplemental bond, when it was previously determined that
the lessee’s financial strength was sufficient such that a bond was
not required. In such cases, the lessee will have a minimum of 40
days notice before the lessee must furnish a supplemental bond.
- The lessee’s third party
indemnitor ends the period of the guarantee.
- The lessee’s bonding company
ends the period of bond protection.
- The value of the lessee’s
security falls below the required amount of the supplemental bond.
- The U.S. Treasury no longer
certifies that the company that issued the bond is acceptable.
-
Financial insolvency of lessee, lessee’s surety, or lessee’s
financial institution.
- If the lessee chooses to provide a
lease or RUE-specific decommissioning escrow account instead of
providing a bond, the lessee may be allowed up to an additional 70 days
to prepare and allow MMS to review a plan for incremental payments and
to contribute funds to the account, according to the plan.
VIII. Addresses
Use the following contact information to
obtain further information or to submit information:
Alaska OCS:
Jeffrey Walker, RS/FO
Minerals Management Service
Alaska OCS Region
3801 Centerpoint Drive, Suite 500
Anchorage, AK 99503-5823
jeffrey.walker@mms.gov
(907) 334-5300
Gulf of Mexico & Atlantic OCS:
Joshua Joyce, Regional FARM Program
Coordinator
Minerals Management Service
Gulf of Mexico OCS Region
1201 Elmwood Park Boulevard
New Orleans, LA 70123-2394
joshua.joyce@mms.gov
(504) 736-2779
Decommissioning assessment concerns:
Stephen Dessauer, Regional Decommissioning
Assessment Coordinator
Minerals Management Service
Gulf of Mexico OCS Region
1201 Elmwood Park Boulevard
New Orleans, LA 70123-2394
stephen.dessauer@mms.gov
(504) 736-2646
Pacific OCS:
Jaron Ming, Regional FARM Program Coordinator
Minerals Management Service
Pacific OCS Region
770 Paseo Camarillo, MS 7000
Camarillo, CA 93010-6064
jaron.ming@mms.gov
(805) 389-7514
Decommissioning assessment concerns:
David Gebauer,
Regional Decommissioning Assessment Coordinator
Minerals Management Service
Pacific OCS Region
770 Paseo Camarillo, MS 7210
Camarillo, CA 93010-6064
david.gebauer@mms.gov
(805) 389-7795
(805) 389-7775
Guidance Document Statement
The MMS GOMR issues NTL’s as guidance
documents in accordance with 30 CFR 250.103 to clarify, supplement, and
provide more detail about certain MMS regulatory requirements and to outline
the information you provide in your various submittals. Under that
authority, this NTL sets forth a policy on and an interpretation of a
regulatory requirement that provides a clear and consistent approach to
complying with that requirement.
Paperwork Reduction Act of 1995 (PRA)
Statement
The information collection referred to in
this NTL provides clarification, description, or interpretation of
requirements in 30 CFR 256 and 30 CFR subpart Q. The Office of Management
and Budget (OMB) has approved the information collection requirements in
these regulations and assigned OMB Control Numbers 1010-0006 and 1010-0142,
respectively. This NTL does not impose additional information collection
requirements subject to the PRA.
Chris C. Oynes
Associate Director
Offshore Energy and Minerals Management
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