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IBP1253_12 AFTER MACONDO: HOW HAS BRAZIL REACTED TO THE LARGEST ACCIDENTAL MARINE OIL SPILL IN HISTORY?

William Prescott Mills Schwind and Nara Galeb Porto
Copyright 2012, Brazilian Petroleum, Gas and Biofuels Institute - IBP
This Technical Paper was prepared for presentation at the Rio Oil and Gas Expo and Conference 2012, held between September, 17-20, 2012, in Rio de Janeiro. This Technical Paper was selected for presentation by the Technical Committee of the event according to the information contained in the final paper submitted by the author(s). The organizers are not supposed to translate or correct the submitted papers. The material as it is presented, does not necessarily represent Brazilian Petroleum, Gas and Biofuels Institute’ opinion, or that of its Members or Representatives. Authors consent to the publication of this Technical Paper in the Rio Oil and Gas Expo and Conference 2012 Proceedings.

Abstract The Macondo spill in the U.S. Gulf of Mexico was an undeniable and unprecedented environmental disaster. To many critics, however, the damage to the environment was exacerbated by harm to the economy, as a drilling moratorium and a regulatory slowdown practically eliminated new offshore drilling, cost both the nation and the region thousands of jobs and millions of dollars, and dealt a severe set-back to the offshore oil and gas industry in the United States. Over two years after the spill, the industry is still struggling to recover. What does Macondo mean for Brazil? As Brazil eyes its own abundant offshore oil and gas resources, the country is grappling with the environmental and political fallout of two recent spills that, while much smaller than Macondo, turned the public spotlight squarely on the possibility of a similar disaster in Brazilian waters. This article highlights the regulatory measures that were or are expected to be implemented in the United States and Brazil in the wake of Macondo, reviews the effects of the recent offshore spills in Brazil, and discusses evolutions in the contractual allocations of risks and responsibility in the international and the Brazilian oil and gas industry in response to Macondo. Introduction Beginning on April 20, 2010, oil from the Macondo spill in the U.S. Gulf of Mexico flowed for almost three months, leaking approximately 4.9 million barrels of oil and polluting over 320 miles of coastline. Over two years later, deepwater drilling activity in the U.S. Gulf of Mexico still lags far behind pre-spill levels, as the drilling moratorium implemented by the U.S. government in 2010 has gradually evolved into a regulatory slowdown that has practically eliminated new deepwater drilling. As a direct result, some E&P companies and oilfield service providers are redeploying capital, assets and human resources to onshore opportunities, particularly shale, and to international opportunities. What began as a human tragedy and an unprecedented environmental disaster has morphed into an economic disaster that has virtually paralyzed the offshore drilling industry in the United States. Brazil would be right to be concerned about the consequences of a Macondo-type disaster on its growing oil and gas industry, especially as spills in Brazil’s Frade and Carioca Nordeste fields threaten a political and regulatory backlash.

William Prescott Mills Schwind is a partner with Thompson & Knight LLP, based in Houston, Texas, where he focuses on international oil & gas matters, with a focus on Latin America. Nara Galeb Porto is an associate with Thompson & Knight LLP, based in Dallas, Texas and São Paulo, Brazil.

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Brazil’s Crown Jewel The crown jewel of Brazil’s oil and gas industry is undoubtedly the massive pre-salt deposits that are located over 170 miles off of Brazil’s coastline, in water depths of more than 2,400 meters, at least 3 miles beneath the surface of the seabed, and covered by a layer of compressed salt that in places is almost 2 miles thick. The technical and logistical challenges to drilling pre-salt wells, to supplying and servicing the necessary manpower and equipment, and to storing and offloading any production will be formidable and could require new technology and techniques to be developed and deployed on a significant scale. Innovation always presents risks, and even when regulatory oversight is tight and industry standards are high, accidents in the oil and gas industry are never absolutely unavoidable. The challenges and risks of developing the pre-salt deposits increase the risks of an accident or a spill, and depending on how Brazil plans for or reacts to such a disaster, a spill could paralyze the Brazilian oil and gas industry, both for the deepwater pre-salt developments and for other offshore areas. The Effects of Macondo in the U.S. As oil was still flowing from the Macondo well, and even before the causes of the disaster had been identified, the U.S. government took action that was viewed by many industry experts as impulsive and even over-reaching. On May 28, 2010, President Obama issued a moratorium that stopped the issue of any new drilling permits for Gulf of Mexico developments and halted any existing deepwater drilling operations. The moratorium was designed to last six months, which was thought to be enough time for the government to investigate the spill and to issue new safety regulations. Concluding that the spill was partly due to lax regulatory oversight and a cozy relationship between the oil and gas industry and the Minerals Management Service (“MMS”), the federal regulator responsible for overseeing offshore oil and gas operations, the U.S. Department of the Interior split the MMS into two separate agencies: the Bureau of Safety and Environmental Enforcement (“BSEE”), charged with inspecting rigs and monitoring safety, and the Bureau of Ocean Energy Management Regulation and Enforcement (“BOEM”), responsible for leasing operations and development. The U.S. government also drafted stricter regulations governing offshore drilling, many of which still haven’t been finalized or implemented, leaving the oil and gas industry with uncomfortable regulatory uncertainty. The new rules require operators to demonstrate how they are prepared to deal with possible offshore blowouts and to detail standards for well design, casing and cementing in drilling permit applications. In addition, permits must be certified by a professional engineer. New regulations also require drilling plans to include a compliance statement and to identify resources that will be deployed to contain any subsea blowout. It is currently thought that the new regulations will be finalized before the end of 2012. Although the drilling moratorium officially ended in October, 2010, it lives on, according to many critics, through the regulatory slowdown that they have called a “permitorium.” After the spill, the BOEM did not issue another deepwater exploration permit until February, 2011, and by December 5, 2011, the BOEM had approved only 16 initial exploration plans for wells in water depths of 500 feet or more. On average, the approval process for issuing these drilling permits was 131 days, as compared to an average of 36 days before the moratorium. According to industry experts, however,
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the most significant regulatory obstacle is an environmental assessment that can take an average of 222 days or more to be approved. The U.S. government has also been slow to proceed with additional offshore lease sales. The first lease sale of Gulf of Mexico acreage following the Macondo spill took place on December 14, 2011, with the second sale of Gulf of Mexico acreage being announced for June 20, 2012. While the government trumpeted the June 20 sale as evidence of the Obama administration’s commitment to the oil and gas industry and to the country’s energy policy, news of the sale was received with skepticism by some industry players, since the sale will actually be a combination of two sales that had been planned long before Macondo or the moratorium: Sale 216, which was originally slated for 2011, and Sale 222, which was originally scheduled for 2012. Although it is difficult to gauge the true economic effects of the moratorium and the “permitorium,” and recognizing that some estimates have been criticized as being politically motivated or partisan, it is hard to deny that the economic impact has been both significant and controversial. Some experts claim that as many as 13,000 jobs have disappeared in the Gulf of Mexico region and that up to 19,000 jobs have been lost nationally, at a time when the U.S. economy is still struggling with slow growth and stagnant unemployment. Similarly, reports estimate that lost wages could total US$ 800 million in the Gulf region and up to US$ 1.1 billion nationally, and that lost tax revenues could reach US$ 155 million for Louisiana alone and close to US$ 350 million nationally. It is also difficult to predict the economic impact that the moratorium and the regulatory slowdown will have in the future. The American Petroleum Institute estimates that more than US$ 24 billion in investment in the U.S. oil and gas industry could be lost in the next several years. The API also reports that, since April of 2010, 11 drilling rigs have redeployed from the U.S. Gulf of Mexico to international locations, including Brazil, Egypt and Angola. The Effects of Macondo in Brazil To their credit, Brazilian regulators have taken the Macondo disaster seriously. In the immediate wake of the spill, Brazil’s petroleum regulator, the National Oil Agency (Agência Nacional do Petróleo, Gás e Biocombustíveis or “ANP”) and environmental regulator, the Brazilian Institute of Environment and Natural Renewable Resources (Instituto Brasileiro do Meio Ambiente e dos Recursos Naturais Renováveis or “IBAMA”), sent representatives to the United States to study the accident, to evaluate lessons learned from the containment and clean-up efforts, and to recommend improvements to Brazil’s regulatory regime. The ANP was also quick to review its protocols and procedures, with a focus on health, safety and environmental management, and to require all companies drilling oil and gas wells in Brazil to provide information on their safety and control systems. Although Brazil has yet to implement any major regulatory changes as a direct result of the Macondo spill, the ANP has adjusted some of its rules on safety barriers, well control and cementing. It has also reviewed standards for monitoring an operator’s performance and competency. Generally, however, the ANP has focused on stricter and more rigorous enforcement of regulations that were in effect before Macondo. In particular, the ANP has increased the intensity and the scope of its inspections of offshore platforms and facilities that are operating in Brazil, resulting in several being temporarily shutdown. The ANP has also invested in training its personnel and in improving communication at all
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levels, including with environmental regulators, health regulators, and with the oil and gas industry itself. Interestingly, the ANP has also recognized that a catastrophic oil spill can be a public relations disaster, so it has worked hard to raise its public profile and to show the Brazilian public that it takes public health and safety seriously. For its part, IBAMA has also taken a more rigid approach to reviewing applications, to analyzing emergency plans, and to issuing environmental licenses. In addition, IBAMA, together with the Brazilian Navy’s Department of Ports and Coasts (Diretoria de Portos e Costas), the government of the State of Rio de Janeiro, Petrobras, the ANP and others, has organized working groups to define and prescribe improved strategies to prevent accidents, identify risks, and respond to spills. Among other activities, the working groups are preparing a National Contingency Plan for Oil Spills (the Plano Nacional de Contingência para Derrames de Petróleo or “PNC”) and recommending regulations on the use of new drilling and production technology. The PNC has actually been under development since 2000, when a ruptured pipeline at a Brazilian refinery spilled almost 350,000 gallons of oil into Guanabara Bay. Although the final PNC is not expected to be released until sometime in 2012, and neither the working group nor the Brazilian government has released full details of the plan, the PNC is expected to feature an inter-agency spill management committee, which will be headed by the Brazilian Navy and which will include representatives from the ANP and IBAMA. The PNC will coordinate spill prevention, cleanup and punishment, similar to inter-agency arrangements in the United States. The PNC is also expected to be financed by a fund of up to R$ 1 billion (US$ 547 million) that will be established by the Brazilian government. Some experts have expressed concern that, unless the fund receives ongoing financing, it could turn into nothing more than a static contingency fund. Those same experts point out that R$1 billion would not be nearly enough money to contain a disaster on the scale of Macondo, and have recommended that the PNC be funded with a per-barrelproduced fee, like the U.S. Oil Leak Responsibility Fund. Some of those same oil and gas industry experts have also recommended that the best way for the Brazilian government to respond to Macondo would be to improve the training and capability of the Brazilian Navy, the ANP, IBAMA and other regulators to enforce existing rules and to respond to a similar disaster, and to continue to invest in acquiring and deploying technology, such as satellitebased oil spill monitoring system and remote sensing devices. Recent Brazilian Oil Spills But could additional changes be coming soon in Brazil? Recent offshore spills in Brazil have conjured vivid memories of the Macondo disaster, and there has already been significant political and even legal fallout. In November, 2011, nearly 3,000 barrels of crude spilled into the Atlantic from the Frade field in the Campos Basin, located 370 kilometers off the coast of the State of Rio de Janeiro and 1,200 meters beneath the ocean surface. Although the spill was brought under control within four days, Brazilian regulators and government officials strongly criticized the operator for allegedly failing to share full information about the spill in its early stages and for allegedly failing to keep emergency equipment on hand to deal with the spill. Under significant political pressure, IBAMA was quick to impose a fine of US$ 28 million for environmental damages and US$ 5.4 million for failures in the operator’s emergency plan.

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As the political smoke from the November, 2011 spill was beginning to clear, a seepage from the Frade field was found in March, 2012. The amount of the seepage was estimated to be less than one barrel of crude, the operator was prompt in reporting the incident, and it wasn’t even clear that the seepage was connected to the November spill. Nevertheless, news of the seepage had the effect of returning the Frade spill to the headlines. A particularly zealous Brazilian federal prosecutor, possibly viewing the Frade spill as an opportunity to make a name for himself, levied criminal charges for “environmental crimes” against 17 individual executives of the operator and one of its key subcontractors, several of whom were non-Brazilian, and asked them to surrender their passports. He also filed a lawsuit against the operator and the subcontractor seeking more than US$ 10.6 billion in environmental damages from the spill, claiming contingency plan failures, calculation errors, inaccuracy in sizing, missing information, improper cleaning and a lack of supervision. Then, less than five months later, the same prosecutor filed a second lawsuit against the operator and the subcontractor for a further US$ 10.6 billion in damages from the seep. Notwithstanding the fact that the seepage was minimal, the prosecutor claimed that the damages from the spill and the seepage should be treated the same. Unsurprisingly, it is widely thought in both Brazilian and international industry circles that the damages amount sought by the two lawsuits is arbitrary and not based on actual environmental damages. Possibly in recognition that the federal prosecutor’s zeal could set a questionable precedent that might have the unintended effect of discouraging international investment in Brazil’s oil and gas industry, there appear to have been efforts in Brazilian political and legal circles to marginalize the prosecutor and remove some of the sensationalism surrounding the Frade spill. Without dismissing any of the charges or lessening the damages sought, the cases were moved to a different court in Rio de Janeiro, which removed them from the prosecutor’s jurisdiction. In addition, a Brazilian court recently denied a request that would have barred the operator and the subcontractor from operating in Brazil. The Brazilian government has also used a more conciliatory tone in recent weeks to discuss joint investigations with the operator into the causes of the spill. A similar accident at an ultra-deepwater drilling platform in January of 2012 spilled almost 160 barrels of crude into the Atlantic Ocean, at a site 300 kilometers off the coast of the State of São Paulo and a water depth of 2,140 meters. Reports suggest that a tube ruptured during a long-term well test at the Carioca Nordeste field, which is one of a cluster of offshore oil discoveries made four miles deep in the Santos Basin. Differently from the Frade spill, the Carioca Nordeste leak is from a well that is operated by Brazil’s national oil company. To date, no fines have been imposed and no other actions of a legal nature have been taken regarding the Carioca Nordeste spill, but that may change. In light of the dramatic actions taken by the Brazilian government and federal prosecutors in connection with the Frade spill and seep, and to avoid allegations that Brazil’s national oil company is being treated more favorably than the international operator, the ANP claims that it will “be even harder” on the state-run company than it was on the Frade operator. These latest accidents, though far smaller in size, severity or effect than the Macondo spill, have turned the Brazilian spotlight back to questions about the safety of offshore drilling. Once again, many Brazilian politicians have called for policies to be adopted immediately to prevent and mitigate accidents, to evaluate whether Brazilian legislation is sufficient, to assess the effectiveness of Brazilian regulators, and to create a center for oil spill prevention, supervision and control. It is almost certain that additional regulatory changes are coming in Brazil.
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Contractual Allocation of Risks and Responsibilities While regulatory changes designed to manage and minimize offshore risks are still being studied, recommended, and implemented, immediate effects of the Macondo spill are already being seen in the suite of contracts that are typically put in place for oil and gas developments. Even before efforts to contain and clean-up the Macondo spill had begun in earnest, legal and business teams in the U.S. oil and gas industry began analyzing risk allocations in their projects, which naturally led to a review of contractual provisions allocating liabilities, risks and indemnities arising from operating risks and environmental hazards. It is common practice in the oil and gas industry to base joint operating agreements on model forms that have been developed by professional associations such as the American Association of Professional Landmen (the “AAPL”) and the Association of International Petroleum Negotiators (the “AIPN”). Given the inherent risks in oil and gas operations, especially offshore operations, and the fact that the operator will conduct those operations on behalf of the non-operators, these forms are designed to protect the operator from certain liabilities arising from its activities. Although the exact contractual requirements can vary, joint operating agreements for offshore operations typically require the operator to behave as a “reasonably prudent operator” and/or to conduct its operations in compliance with applicable law and according to “good and prudent industry practices.” The precise meaning of this standard varies with the governing law of the contract, but in many jurisdictions, the standard required of the operator is not particularly high, and requires only that the operator use average intelligence and diligence in conducting its operations. Similarly, joint operating agreements also typically limit the situations in which operators can be liable for damages caused to the other parties, including environmental damage. Many provide that the operator will not be liable to the non-operators for losses or liabilities that do not result from the operator’s gross negligence or willful misconduct. In most jurisdictions, gross negligence can be a difficult standard for the non-operators to demonstrate, and proving it can depend on both the operator’s actual knowledge at the time the operator acted or failed to act and on the severity of the harm that was caused. Joint operating agreements also provide in many cases that non-operators can remove an operator only for “good cause,” which typically means gross negligence, willful misconduct or a breach of or failure to perform its obligations under the joint operating agreement As a result of the post-Macondo reexamination, the risk allocation provisions of a number of already-existing joint operating agreements for offshore operations have been renegotiated and revised. Negotiations around new joint operating agreements have focused on standards for operator’s performance and provisions that would exempt non-operators from sharing responsibility for damages caused by the operator´s gross negligence and willful misconduct. Non-operators have also pushed for deductibles, liability caps and other mechanisms that would limit their obligation to indemnify the operator for damages arising from operational matters. In addition, non-operators have also begun to resist contractual provisions that would require them to bear environmental risks arising from operations. Negotiations around risk allocation have also impacted oilfield services contracts and construction contracts for platforms, drillships and other offshore assets. Some service providers and contractors are demanding shelter from damages arising from the operator´s gross negligence and willful misconduct, as well as indemnity protection from liabilities due to matters outside of their control or responsibility. In some cases, construction contractors have also pushed for indemnity protection against any matters arising from the operational use of the asset after their construction activities
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are complete. Oilfield service providers and construction contractors have also insisted on protection from reservoir damage, leaked hydrocarbons or other types of catastrophic environmental damage arising from matters outside of their control. Liability caps have also reemerged as a popular trend in the indemnification clauses of joint operating agreements, construction contracts and oilfield services agreements, but they are far from perfect or cure-all provisions to address all of the risks of a Macondo-type spill, and in fact, can be problematic. In construction contracts and oilfield services agreements, it has become increasingly common for contractors to agree to a commonly accepted ‘knock-for-knock’ indemnity, in which each party indemnifies the other party for harm to its own personnel and property, regardless of fault, but then to also try to limit overall liability to a capped amount, usually the value of the contract. While this approach sounds like a good idea in concept, in practice, a cap can impact not only the indemnity clause and the underlying insurance coverage, but also other commitments under the contract, often in a way that is unintended. For example, a general liability cap could limit liability for failure to obtain licenses and permits, failure to pay taxes, violation of a third party’s intellectual property rights, payment of a bribe or other violation of an anti-corruption law, or breaches of the contract’s confidentiality provision, which is not what most parties intend. A better practice would be to limit the scope of the liability cap to damages arising from personal injury and/or environmental contamination. Impact on Brazilian Contracts As might be expected, the increased focus on risk allocation provisions in international contracts has affected the way that companies manage liabilities in their Brazilian projects. As the Brazilian oil and gas industry evolved and developed, it became a common industry practice to base many of the agreements that are used in Brazil on model contracts that are commonly used and widely accepted in the international oil and gas industry, but to modify them for use in Brazil. For example, the Model International Joint Operating Agreement developed by the AIPN has become such a standard in Brazil that the AIPN even offers an official translation into Portuguese. As Brazilian legal experts readily note, however, many contracts that are widely accepted in the international oil and gas industry were prepared for use in common law jurisdictions, and adapting an international contract for use in Brazil can sometimes be imprecise. Nowhere is that more evident than in contractual provisions that allocate risk and liability, which are treated very differently under civil law and common law; localizing a contract for use in Brazil will not necessarily resolve all of those differences. For example, concepts such as “gross negligence” and “willful misconduct” are different in Brazil, and certain types of indirect damages and punitive damages that are relatively common in some jurisdictions are not recognized at all in Brazilian law. Similarly, the dispute resolution provisions of some industry agreements may not be enforceable in Brazil, and issues such as injunctions, debt recovery and enforcement may need to be resolved by Brazilian courts, even if the contract requires arbitration. As international oil and gas agreements continue to evolve and adapt to changing risk allocations in a post-Macondo world, Brazilian contracts will no doubt continue to do the same. As changes are made to international contracts, however, it is worth remembering that not all of those changes would be appropriate in a Brazilian contract or would be enforceable in Brazil. Conclusions
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The full impact of the Macondo disaster on Brazil’s oil and gas regulatory regime is still yet to be determined, and the same can be said of the Frade and Carioca Nordeste spills. The industry has already seen an effect on risk allocation negotiations in operation and construction contracts, and additional regulatory and contractual changes may be on the way. As pre-salt developments continue to unfold, and as risks become increasingly significant and acute, Brazil will likely continue to focus on offshore safety and spill prevention. References “Brazil to charge Chevron executives over fresh oil leak.” BBC News Latin America & Caribbean, March 17, 2012. “Brazilian Regulator: Chevron Needs to Show It Can Prevent Spill before Drilling Again.” Dow Jones Newswires, April 30, 2012. “Chevron and Transocean are double sued in environmental damages.” Petroleumworld, April 9, 2012. “Chevron publishes an open letter to the public on major Brazilian spill.” Inpex Corporation Press Release, March 2012. “Contract Risk Management – A Post Macondo Primer.”Oil & Gas IQ “Frade Response: Updates and Information on Our Work to Resolve the Frade Field Incident in Brazil’s Campos Basin.” Chevron Press Release, March 23, 2012. “`Indústria de petróleo é de risco,’ diz diretora do Ibama.” O Estado de São Paulo, May , 2012. “Is Brazil on Track to Manage its Oil Bonanza Effectively?” Featured Q&A: Inter-American Dialogue’s Latin America Advisor: Energy, January 30-February 2, 2012. “Liability Caps.” Conoco Phillips Monthly Contract Issue, February, 2011. “The U.S. – Brazil Strategic Energy Dialogue.” White House Fact Sheet, April 9, 2012. BLOUNT, J. “Chevron, Transocean face second $11 billion Brazil lawsuit.” Chicago Tribune, April 3, 2012. BRANSFORD, A. “Ex- BP Engineer Faces 1st Criminal Charges in Deepwater Probe.” Law 360, April 25, 2012. CALKINS, L.B. “U.S. in Contempt Over Gulf Drill Ban, Judge Rules.” Bloomberg, February 3, 2011. COIMBRA L.and BLOUNT, J. “Brazil shifts court for Chevron spill.” Chicago Tribune, April 13, 2012. DLOUHY, J. “Lawmaker presses for payment of drilling ban damage claims.” Fuel Fix, April 11, 2012.
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SHRESTHA, B. “Brazil Fails in 2nd Bid to Halt Chevron Operations After Spill.” Law 360, April 11, 2012. TILOVE, J. “Gulf of Mexico oil and gas lease sale plans fail to impress industry critics.” The Times-Picayune, January 26, 2012. VIEIRA, W. “Tudo O Que Você Queria Saber Sobre Prè-Sal, Mas NinGuèm Teve, Coragem De Explicar.” Super, pg. 78-83, 2011, January, 2011.

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