Bonds, Bankruptcies and Billion-Dollar Backlogs: Federal Offshore Decommissioning Liability

Public Policy & Regulation attorneys Jim Noe and Kamran Mohiuddin co-authored an article for the State Bar of Texas Oil, Gas & Energy Resources Law Section's spring 2025 report. Their article dives into the federal offshore decommissioning liability regime, explaining how regulation in this area developed and how its joint and several liability framework functions. They begin with basic jurisdictional questions such as where state waters end and federal waters begin and what denotes the Offshore Continental Shelf (OCS) subject to federal leasing, along with a summary of what oil well decommissioning obligations arise under the Outer Continental Shelf Lands Act (OCSLA) and how liability accrues. The article then turns to maintenance and monitoring requirements and regulatory compliance hurdles for industry participants. Mr. Noe and Mr. Mohiuddin offer insightful analysis and commentary to assist companies and individuals with finding practical approaches to the thorny issue of decommissioning liability.

READ: Bonds, Bankruptcies and Billion-Dollar Backlogs: Federal Offshore Decommissioning Liability (Membership required to view)