Various commenters normally supported the proposal to permit restricting 3rd-occasion guarantees to a specific volume. Reaction:
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Many commenters asserted the proposal would end in major hardship to small corporations that did not meet this criterion and hence would need to offer supplemental economic assurance. Commenters argued that a prerequisite to provide supplemental financial assurance would increase the threats of defaulting, not purchasing upkeep of existing functions, shedding staff, delaying performance of recent decommissioning obligations, and diverting money money essential for potential OCS Vitality development. Reaction:
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Normally, industry commenters supported the phased solution and several other commenters encouraged that or not it's extended to five yrs to “mitigate prospective substantial risk to corporations and to deliver ample time for that bonding industry to adjust.” Reaction:
Several commenters expressed opposition to DOI's proposal, asserting that any co-lessee that does not retain an investment decision quality credit score score seabet (or equal proxy credit history ranking) need to be needed to provide supplemental monetary assurance. Commenters proposed that the Department demand supplemental economical assurance for their respective Operating curiosity shares from all co-lessees that don't maintain an expense grade credit rating score for leases that aren't exempt based on the reserve Evaluation.
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This remaining rule will have an impact on latest and future lessees, sublessees, RUE grant holders, and pipeline ROW grant holders. BOEM's Assessment demonstrates this involves approximately 391 businesses with history title ownership or operating legal rights in leases, and with passions in RUE grants and pipeline ROW grants.
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