Public Comments

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Erik G. Milito
President

July 14, 2026
BOEM Information Collection Clearance Officer
Anna Atkinson
Bureau of Ocean Energy Management
45600 Woodling Road
Sterling, VA 20166
Subject: Comments of the National Ocean Industries Association in response to the
notice of information collection related to oil spill financial responsibility for offshore
facilities
OMB Control Number 1010-0106
BOEM Information Collection Clearance Officer:
Thank you for the opportunity to provide comments in response to the information
collection request (ICR), OMB control number 1010-0106, related to revisions of
Forms BOEM-1019 (Insurance Certificate), BOEM-1020 (Surety Bond), and BOEM1023 (Financial Guarantee). NOIA strongly supports the revisions to the three
documents and urges the Bureau of Ocean Energy Management (BOEM) to publish
the final revised forms for use by industry without delay.
The National Ocean Industries Association represents companies that develop and
produce oil and natural gas on the U.S. outer continental shelf. NOIA represents the
operators that are required to submit the revised documents relevant to this ICR. We
thus have a direct interest in the ICR and in ensuring that BOEM’s financial
responsibility requirements remain clear, commercially workable, and supportive of
continued offshore energy investment.
Importantly, the revised forms effectively advance President Trump’s U.S. energy
dominance objectives, as defined in the key energy executive orders. Pursuant to
Executive Order 14156, “Declaring a National Energy Emergency,” executive
agencies are directed to “identify and exercise any lawful emergency authorities
available to them, as well as all other lawful authorities they may possess, to facilitate
the identification, leasing, siting, production, transportation, refining, and generation
of domestic energy resources.” Pursuant to Executive Order 14154, “Unleashing
American Energy,” it is the policy of the United States “to encourage energy
exploration and production on Federal lands and waters, including on the Outer
Continental Shelf, in order to meet the needs of our citizens and solidify the United
States as a global energy leader long into the future.” This executive order lists the
above objective as the very first priority. The revised forms are a concrete step, ready
for implementation, towards that mandate.
Importantly, as contemplated by the President’s executive orders, the changes to the

forms are important steps to enabling investment in U.S. offshore oil and gas projects.
There has been a pronounced degradation of the insurance market for offshore energy
operators, which threatens vital oil production from the U.S. offshore region. U.S.
offshore energy development currently provides nearly two million barrels of
domestic production per day, generates more than $30 billion in capital investment per
year, and supports more than 400,000 high-paying jobs throughout the country. The
changes to the forms are expected to significantly improve the availability of Oil Spill
Financial Responsibility (OSFR) coverage for oil and gas operators across the
industry.
The forms, in their current state, have served as a barrier to investment in offshore oil
and gas projects, and the revised documents are expected to help break down that
barrier. We support updating the three forms to make it clear that the agreed coverage
applies only to the period between the effective date of the coverage and the expiration
of the coverage as defined by the individual form. This creates consistency with
language specified in the certificates provided by the U.S. Coast Guard for similar
coverage. With the proposed changes, the expectation is that the insurance market will
respond positively in terms of the pool of insurers, the amount of coverage on the
market, and potentially in the premium rate. Given the scale of capital at stake and the
long lead times required for offshore projects, every month of delay compounds the
cost. Additionally, we support the accuracy of BOEM’s burden hours estimate for the
information to be collected under this form. We affirm that the changes will reduce the
reporting and recordkeeping burden We therefore urge BOEM to finalize and publish
the revised forms immediately.
NOIA and its members remain available for further discussions on the revised
documents. Please contact Erik Milito ([email protected]) with any follow-up questions
or to set up a meeting.
Very respectfully,

Erik Milito
President
National Ocean Industries Association

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