GCREAG Regulatory Update January, 2014

1. GCREAG Regulatory Update January, 2014 Lincoln Stroh J. Connor Consulting, Inc.

2. Key Topics • BSEE Regulatory Agenda • USCG Regulatory Agenda • DOT Regulatory Agenda • Form / Information Collection Updates • Proposed, Final Regulations & New NTL • Deepwater Exploration Plan Approval Times

3. BSEE Regulatory Agenda • BOPs • NPRM March 2014 • Final Rule October 2014 • Production Safety Systems and Lifecycle Analysis • NPRM August 22, 2013 • Comment Period Ended October 21, 2013 • Final Action May 2014

4. USCG Regulatory Agenda • Proposed regulations to add new requirements for lifesaving, fire protection, training, hazardous materials used as stores, and accommodation spaces • Add standards for electrical and machinery installations in hazardous locations • Provide regulations for DP systems • Provide for USCG acceptance and approval of specified classification society plan reviews, inspections, audits, and surveys • NPRM September 2014

5. USCG Regulatory Agenda • Nontank Vessel Response Plans requires owners or operators of nontank vessels to prepare and submit oil spill response plans. Definition of nontank vessel: • Self-propelled vessels of 400 gross tons or greater that operate on the navigable waters of the US • Carry oil of any kind for main propulsion that are not tank vessels • Updates SOPEP requirements that apply to nontank vessels and tank vessels • Final Rule September 30, 2013 with effective date of October 30, 2013

6. DOT Regulatory Agenda • PHMSA: Pipeline Safety regs at proposed rule stage: • Safety of On-Shore Liquid Hazardous Pipelines • Addresses hazardous liquid operators improving protection of High Consequence Areas (HCA) and other vulnerable areas • NPRM April 2014 • Issues with using Plastic Pipe in Gas Pipeline Industry • Includes several issues regarding plastic pipe gas lines. • NPRM April 2014 • Operator Qualification, Cost Recovery and other Pipeline Safety Proposed Changes • Affects renewal process for special permits, cost recovery for design reviews, and incident reporting. • NPRM November 2013

7. DOT Regulatory Agenda • MARAD: Regulations To Be Followed by All Departments, Agencies and Shippers Having Responsibility To Provide a Preference for U.S.-Flag Vessels in the Shipment of Cargoes on Ocean Vessels • Would update and clarify the Cargo Preference rules that have not been revised substantially since 1971. • Next action is currently “undetermined”

8. Forms Update - APD / APM • Application for Permit to Drill and Application for Permit to Modify updates will include a certification statement to state that false submissions are subject to criminal penalties • Minor APD modifications • Comments on each are due by Feb. 3, 2014

9. New Form BSEE-0011 iSEE • Internet-Based Safety and Environmental Enforcement Reporting System • Created to clarify the needed information when someone reports an apparent violation • Any person may report to BSEE any hazardous or unsafe working condition on any facility engaged in OCS activities, and any possible violation or failure to comply with: • Any provision of the Act • Any provision of a lease, approved plan, or permit issued under the Act, • Any provision of any regulation or order issued under the Act, or • Any other Federal law relating to safety of offshore oil and gas operations • Comments due January 17, 2014

10. OSHA Injury Reporting Proposed Rule • To require DIRECT electronic submission of workplace injury / illness data to OSHA “or its designee” (i.e. BSEE / form BSEE-0131) • Expands OSHA’s current direct collection abilities • Data is already tracked by employers (this won’t change), but is only accessed during inspections • 3 new requirements: • > 250 employees = quarterly e-submission of info • > 20 employees AND in certain industries = annual e-submission via form 300A to replace annual survey • E-submit injury / illness data as requested by OSHA

11. Extension of Prior Notices to Lessees • Two NTLs previously extended until the end of calendar year 2013 (NTL No. 2013-G02) are being extended again until June, 30, 2014. • NTL 2008-G04 provides guidance on the information requirements for OCS plans required by 30 CFR 550, subpart B, and • NTL 2008-G05 describes the shallow hazards program, which was designed to ensure that exploration, development, production, and transportation operations are conducted with a minimum risk to human life and the environment.

12. Upcoming Regulations • Mike Saucier (BSEE) listed upcoming regulations at the December OOC Meeting: • Blowout Prevention Systems (in preparation, due out early 2014) • Arctic regulations (joint with BOEM) • Upcoming proposed rules: • Suspensions of Production and Operations • Natural Gas Fluids Measurement • Oil Spill Mechanical Recovery

13. Deepwater Initial EP Approval Times

14. Down the Road • January 28/29 – Hilton N.O. BSEE Standards Workshop • January 29 – USCG Sector New Orleans Area Committee meeting • March 19 – Central GOM Lease Sale 231 – N.O. • March 19 – Eastern GOM Lease Sale 225 – N.O. (following CGOM sale) • April 9/10 – Center for Offshore Safety 2nd Annual Forum • June 4 - Must be in compliance with SEMS II

15. Thank you! Lincoln Stroh J. Connor Consulting, Inc. 281.578.3388 Lincoln.Stroh@jccteam.com