Page 7 - IAGC July Newsletter

IAGC Newsletter IAGC Newsletter

IAGC to Submit Comments, Express IAGC Comments on Metal
Export Regulations

Concerns with NOAA’s Proposed IHAs Effecting Industry

The IAGC, along with other trade
n 6 June 2017, the National Oceanic and Summary of issues: associations, submitted the Oil & Natural
Atmospheric Administration (NOAA) requested • Small dolphin exemption should apply to all dolphin Gas Industry comments on Section 232
Ocomments on its proposal to issue Incidental species regardless of dolphin behavior. National Security Investigation of Imports
Harassment Authorizations (IHAs) to incidentally take • NMFS proposes to require shutdowns for certain of Aluminum (23 June 2017) and Steel
marine mammals during G&G activities, pursuant to the types of marine mammal observations “at any (31 May 2017) to the U.S. Department of
Marine Mammal Protection Act (MMPA) in the Atlantic distance”. This requirement is arbitrary and unrea- Commerce.
Outer Continental Shelf (OCS). Nearly 700 days after the sonable because it is unlimited (“at any distance”)
first applications for IHAs were submitted to NOAA’s and therefore contemplates shutdowns for circum- he Secretary of Commerce initiated an the proper findings of this Section 232 investigation and
National Marine Fisheries Service (NMFS), our members stances in which no Level A or Level B harassment investigation into the large volumes of excess avoid broad applications which sweep in all imported
finally have the opportunity to comment on the proposed will occur. Tcapacity worldwide in an effort to potentially steel and aluminum products from all countries.
authorizations. • Maintaining 2 PSOs on-duty at all times requires limit or tax the imports of steel and aluminum. Limiting steel and aluminum imports into the U.S. will
The IAGC’s comments will express concerns with each source vessel to accommodate 4-5 PSOs at all In summary, the Associations urge the Department have a dramatic effect on the Oil & Gas industry as we use
the impracticability of some of the proposed mitigation times. of Commerce to use the following criteria to determine and consume large amounts of both products throughout
measures and with NMFS’s substantial overestimation of • IAGC believes using Passive Acoustic Monitoring the appropriate policy recommendations to address the the lifecycle of exploration through the final product.
the number of incidental takes that may occur as result (PAM) should be optional. findings of this Section 232 investigation of steel and Prices of both commodities will increase with these
of the surveys. The best available scientific data and aluminum imports: potential regulations causing each phase of the oil lifecycle
information demonstrate that mitigation programs can For over 40 years, the federal government and aca- 1. When determining harm to national security, to become more expensive and reducing the ability of the
and do effectively minimize and avoid the incidental take demic scientists have studied the potential impacts of employ a narrow definition of “national security” U.S. Oil & Gas industry to compete on a global scale.
of marine mammals associated with offshore geophysical G&G activities on marine mammal populations and have that conforms with 15 CFR § 705.4 and that does not We will continue to monitor the policy developments
survey operations. NMFS has proposed some mitigation concluded that any such potential impacts are insignifi- include steel and aluminum supply to the U.S. oil and of Section 232 for steel and aluminum imports. Read full
measures that are not practicable. These measures will cant. This conclusion has been publicly reaffirmed on natural gas industry. comments for Aluminum and Steel.
likely result in increased survey duration, which, in turn, multiple occasions by the Bureau of Ocean and Land 2. Consider the extent of existing trade remedies already
can increase the potential exposure of marine mammals to Management (BOEM). in place to address the unfair steel and aluminum trade
potential seismic-related effects because shutdowns and The extensive record of information regarding the practices of U.S. trade partners and only put forward IAGC Committees to Consult
delays necessarily result in overall increased surveying time insignificant effects of OCS seismic surveying demon- new actions that are targeted precisely and narrowly
to preserve data quality and integrity. strates that the Proposed IHAs will have no more than a to any previously unaddressed underlying causes of on OGA Regulations
The comment period ends 21 July. temporary, localized, and negligible impact on marine distortions in the global market for steel and aluminum.
mammals and marine mammal species or stocks. The 3. Consider the ways in which new U.S. tariffs, quotas or Over the past 4 years, the IAGC EAME Committee has led
proposed seismic surveys are critical to the safe and other measures could have a potential negative effect IAGC’s efforts in negotiations with OGA (the United King-
orderly development of the oil and gas resources of the on U.S. energy security beyond their initial and direct dom’s Oil and Gas Authority) on how geophysical data will
Atlantic OCS, and can be accomplished with insignificant effects on steel and aluminum, such as how they may be regulated in the UK’s jurisdiction going forward. As part
environmental impacts. The IAGC therefore strongly increase costs for oil and natural gas industry by being of that process, the OGA is seeking ‘consultation’ on recently
supports NMFS’s authorization of IHAs to address any in- passed through the chain of distribution, and how proposed ‘regulations for the retention and disclosure of
cidental harassment of marine mammals that may result they could potentially affect affordable energy for information and samples’. The IAGC EAME and Global Data
from the proposed Atlantic OCS surveys. consumers, including the US government. Licensing Committees will be responding to the comment
The IAGC will continue to work to ensure members The Associations believe that any policy deadline on 25 August 2017.
have the oppor tunity to survey in new markets around recommendations to address the findings of this Read the UK Oil & Gas UK Regulation Consultation for
66 the world including the Atlantic OCS. Section 232 investigation should be narrowly tailored to Comments, as well as some background materials. 7