From the CAP report (“10 Years After Deepwater Horizon, Oil Spills and Accidents Are on the Rise”, March 3):

Figure 1, left, we see that INC’s are down. INC’s are BSEE’s version of a moving violation; some are serious, some less so. But is the fact that they have decreased evidence of lax oversight, or better compliance? Sometimes BSEE “bundles” several related INC’s in a single violation; sometimes they’re counted separately. Counting INC’s is a poor way to judge performance.

Figure 1, right: the count of offshore inspections is down 13%. This is largely due to a change in policy guided by BSEE Director Scott Angelle that encourages remote review of electronic documents, saving expensive and hazardous helicopter flights by BSEE inspectors. (More on that subject below.)

Figure 2, left, is a graph of environmental performance. Barrels spilled per barrel produced increased a shocking 595% over two fiscal years! Shocking, that is, until you read the accompanying text:

A BSEE spokesperson responded to this analysis by noting that two individual incidents—a 1,900 barrel spill in fiscal year 2016 and a 16,000 barrel spill in fiscal year 2018—account for a substantial portion of the oil leaked during those periods…

That’s right: The spill rate “spiked” from 1 barrel in 556,000 barrels produced to 1 barrel in 80,000 because of a single spill event. One barrel spilled is too many, but even at 1:80,000 the record is a pretty good one. And why not show a longer trend for context?

Excerpt from TP/Advocate article (“Offshore oil and gas accidents, deaths spike amid regulatory rollbacks”, March 3):

The number of offshore worker fatalities in 2019 [nine total, according to numbers tracked from press stories – ed.] is more than for the previous five years combined. From 2014 to 2017, the BSEE reported one fatality in each fiscal year.

Clearly the blame is on Mssrs. Angelle and Trump and their scheme of relaxed regulation… Except that when we drill down on those nine fatalities, five were the result of helicopter accidents; the other four were the result of workers falling from platforms.

BSEE does not regulate helicopters. Offshore work is hazardous, but overall the safety record is good, exceptionally good compared to most comparable activities. Experience shows that the most hazardous part of working offshore is getting to work.

The other four fatalities were attributed to falls. These are avoidable, behavior-based accidents; usually they happen when there is an unguarded hole in the deck during construction. An unguarded hole is a violation, to be sure, and a boneheaded oversight.

Nobody is rolling back regulations regarding unguarded holes in decks.

The regulations being rolled back are highly technical. They relate to design criteria for wells and required mud weights. They address the testing frequency for blowout preventers. They address the myriad of safety systems and controls that allow for safe and pollution-free production of oil and gas (more on that here).

The Obama Administration overreacted after the BP Spill, bringing in the BSEE’s wish-list of regulatory changes, many of which had little to do with the root causes of the Deepwater Horizon accident. Rolling back the regulations showed eminent good sense on the part of Director Angelle and the Trump Administration.

Regulatory reform is opposed by people who always believe in an all-wise and ever-beneficent federal bureaucracy, and who believe the efficacy of regulations can be measured by the pound. Too much regulation has been turned over to Fairfax VA-based desk jockeys. Now they are pissed that their regulatory achievements are being rolled back in the name of common sense, clarity, and efficiency.

Am I jaded from my dealings with the MMS, later BSEE? Guilty as charged. All too often the agency gets bound in its own bureaucracy, its own agendas, and a blind adherence to the letter of the law over the substance. If there is a lesson from the Deepwater Horizon tragedy, it is that the brave souls who put their lives on the line deserve a regulatory regime that serves them better.