Drilling Subcommittee Interim Report Summary
The interim report of the Drilling Subcommittee highlights the current status, progress, recommendations, and concerns in the drilling industry regulations. Key recommendations include revoking outdated regulations and updating Subchapter.N with the IMO MODU Code. Concerns such as low industry participation and outdated policies are also addressed. The subcommittee projects the next milestone to be the draft final report in January/February with the final report expected by March 18, 2018, before a meeting in NOLA.
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Drilling Subcommittee Interim Report Warren Weaver/Tom Horan Presentation Date 13 December 2017
Current Status Review of regulations identified in Task assignment ~100% complete: o 33 CFR Subchapter N (OCS Activities) o 46 CFR Subchapter I-A (MODUs) Representation: o 9-11 Subcommittee members + IADC, and Production subcommittee co- chair (class societies and Flag State) Task Progress: o On track o Four teleconferences (5 Sept, 21 Sept, 5 Oct) o Two in-person meeting, One w/ teleconference (13 Oct, 2 Nov)
Recommendations 1. Revoke 46 CFR parts 107 to 109 (Subchapter I-A). The U.S.-flagged MODU fleet has virtually disappeared in the last 15-20 years, while during this period Subchapter I-A has not been updated to reflect changing technology or international norms such as the IMO MODU Code. Based on the most recent information, four active MODUs remain U.S. flagged (three non self-propelled and one self-propelled) and the likelihood of any new construction for U.S. flag is seen as extremely low. Accordingly, the effort required to update Subchapter I-A is seen to outweigh the benefits. MODUs would continue to be regulated under 33 CFR parts 140 to 147 (Subchapter N). 2. Withdraw the 7 December 1999 notice of proposed rulemaking (NPRM) for 33 CFR Subchapter N [RIN 2115 AF39]. Withdrawal of this proposed rulemaking will remove Administrative Procedures Act constraints on ex parte communications and allow for an open dialogue with the Coast Guard with a view towards developing a new framework for Subchapter N that would better serve the Coast Guard, the industry, and the workforce. NOSAC, in its letter to the NOSAC Sponsor in response to the task statement on Economic Analysis dated Nov 6 2009, recommended Subchapter N to be re- issued as a new NPRM . From the Committee s viewpoint, no discernable progress has been made toward either finalization of the proposed rule, or issuance of a new NPRM, and it is time for a fresh start. 3. As Subchapter N is revised, incorporate by reference each of the three editions of the IMO MODU Code. As envisioned, this approach would require every MODU (U.S. or foreign flag) operating on the OCS to comply with the applicable edition of the MODU Code, as amended; and (2) require such MODUs to provide and maintain evidence to this effect from the flag-State. Provision should be made for allowing continued operation of MODUs built prior to the effective date of the 1979 MODU Code.
Concerns Low Industry participation (4 contractors in attendance) APA Restrictions regarding Ex Parte Communications Progress on other Rulemakings (DP, SEMS, Training and Manning of MOUs and OSVs) Outdated Policies (e.g. NVIC 3-88 Change 1, NVIC 7-84, NVIC 1-89)
Subcommittees Projections Next milestone: o Draft final report with review of policies and other topics and discuss recommendationss (Jan/Feb) Expected deliverables: o Final report by 18 March 2018 prior to meeting 27-28 March in NOLA Known concerns and issues: o Industry participation/input o APA Ex Parte Communication Constraints o Rulemaking Progress (SEMS, DP, Training) Next steps: o Schedule teleconferences for 2018 (bi weekly) o Schedule at least one in-person meeting in the Jan/Feb 2018 timeframe
