The Department of Interior (DOI), acting through the Bureau of Energy Management (BOEM), issued a new final rule titled Risk Management and Financial Assurance for OCS Lease and Grant Obligations, which became effective June 29, 2024, requiring oil and gas companies operating on the Outer Continental Shelf (OCS) that are without an investment-grade credit rating to provide supplemental financial assurance to cover the cost of potential decommissioning liabilities, which would equal $6.9 billion in the aggregate.
On June 17, 2024, the states of Texas, Louisiana, and Mississippi, along with several oil and gas trade associations (the Plaintiffs), filed suit against BOEM in the Western District of Louisiana challenging this rule. The Plaintiffs are seeking equitable relief from the agency's action in the form of either a stay of effectiveness of the new regulations or an injunction to prevent the agency from implementing them.
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