Comments on new technical and economic data available for EPA`s proposed offshore oil and gas discharge guidelines and standards

The purpose of this paper is to provide comments on the Environmental Protection Agency (EPA) Notice in the Federal Register entitled, ``Oil and Gas Extraction Point Source Category, Offshore Subcategory; Effluent Limitations Guidelines and New Source Performance Standards; New Information and Request or Comments`` (53 FR 41356; October 21, 1988). This Notice announces the availability of new technical, economic and environmental assessment information relating to the development of Best Available Technology economically achievable (BAT and New Source Performance Standards (NSPS) regulations under the Clean Water Act governing the discharge of drilling fluids (muds) and drill cuttings from offshore oil and gas facilities. The Notice is part of a rulemaking process which formally began with the initial release of rules in August 1985 and which incorporates numerous comments and additional data received subsequent to the release of the 1985 rules. The comments in this paper will concentrate on the following five issues: Estimated project impacts are misrepresented by assuming weighted-average incremental costs of regulation. Economic impacts are inaccurate, since annual compliance costs will likely affect the number of wells drilled, by the effect of compliance costs on project economics and the reduction in industry cash flows on capital available for drilling. Initial well productivity assumptions for various scenarios do not vary with field size. The assumed lease costs, which are based on historical data, do not accurately reflect the future value of leases. The experimental decline rates assumed for the Pacific are too high.