Meeting in Mumbai on 22 January, the SCA Chapter assessed the relevant issues and the operational and compliance challenges involved. Members raised questions pertaining to applicability of the Merchant Shipping Act to MODUs, the authority of the DGS to levy fees associated with the enforcement of the regulations, and the necessity of obtaining Specified Period Licenses (SPL) for certain offshore drilling operations.
The work group – chaired by Ranajit Chakraverti of Transocean – was formed to pursue two courses of action: “representation” to the DGS of issues related to applicability, and filing of a writ petition in the courts challenging DGS authority to apply the regulations to MODUs, including a request for a stay of enforcement.
A draft position paper has been updated and circulated to interested companies for comment. Legal counsel will prepare representation documents and submit to the DGS, as well as prepare a writ petition to file on behalf of the IADC SCA Chapter.