Agency Information Collection Activities; Proposals, Submissions, and Approvals: Oil Spill Financial Responsibility for Offshore Facilities

The London insurance associations (LMA and IUA) support the agency's action to redraft the insurance certificate to clarify that coverage applies to claims arising during the annual period of coverage. They provide specific technical suggestions to the draft to reduce ambiguity and ensure that insurers are not held liable for ongoing incidents that occurred outside of their specific policy terms.

The National Ocean Industries Association (NOIA) strongly supports the revisions to BOEM forms related to oil spill financial responsibility for offshore facilities. They argue that the changes will improve the availability of insurance coverage, reduce reporting burdens, and facilitate investment in U.S. offshore oil and gas projects.

Arena Energy, LLC supports the Bureau of Ocean Energy Management's (BOEM) proposed revisions to oil spill financial responsibility (OSFR) forms. The company argues that the revisions correct market uncertainty, align with the Oil Pollution Act of 1990, and reduce the reporting burden on operators.

W&T Offshore, Inc. supports the proposed revisions to the Oil Spill Financial Responsibility (OSFR) forms, arguing that the new "first occurring" temporal trigger provides much-needed clarity and resolves coverage disputes. The company emphasizes that these changes will improve insurance market availability, reduce operator costs, and support federal energy production goals.

The commenter supports the collection of data regarding oil spill financial responsibility. They argue that the fossil fuel industry should bear all costs for spills and environmental damage without taxpayer subsidies, and they advocate for mandatory prison sentences for top management in the event of a spill.