Natural Resources Committee on Dec. 9th, 2013

[The Chair, Conservative, Leon Benoit]

Good afternoon, everyone. We're here to continue our study on Bill C-5, an act to amend the Canada-Newfoundland Atlantic Accord Implementation Act, the Canada-Nova Scotia Offshore Petroleum Resources Accord Implementation Act and other acts and to provide for certain other measures.

We have witnesses with us today, but just before we get to them, there are a couple of things I want to mention. One is that we will put aside 15 or 20 minutes at the end of today's meeting to deal with future business. The other thing is quite disturbing, and it's starting to happen all too often.

I got a call, as did some of my colleagues, from a person in the media, someone from Canadian Press, who talked about information from an in camera meeting. The person had specifics on that information and said only that it came from an opposition member. I have no way of knowing whether that's true or not, but I just want to remind all members of the committee that when things are dealt with in camera, they have to stay in camera. It's really important that we can trust that what is said in camera and what is dealt with in camera stays in camera.

It is extremely disappointing to me that this has happened. It has happened at other committees too. It has to stop. It is a breach of members' privilege. I trust that it will stop. If somebody has unintentionally disclosed something that they hadn't intended to—and I know that can happen if you get into an interview and you kind of forget what you should and shouldn't be talking about—certainly I'd be interested in hearing from whoever has done that. We can have a bit of a chat about it. I just have to believe that this isn't going to happen in the future and that what is discussed in camera will stay in camera.

Mr. Julian, go ahead.

[Peter Julian, NDP, Burnaby—New Westminster, BC]

Mr. Chair, your point about what's in camera staying in camera is very valid, and we, the NDP, as the official opposition always respect that. We do need to be reminded that the motion was in the public domain. It was read out in the public domain. That portion of the meeting was in public.

[The Chair, Conservative, Leon Benoit]

That's true, Mr. Julian, but there was other information with specifics given to us, including the vote results and who voted which way that simply couldn't be a guess on the part of the media person. What you're saying is true to that point, but what was divulged clearly had to have come from a member of this committee.

Again, I trust members to make sure that it simply doesn't happen again.

Mike.

[Mike Allen, Conservative, Tobique—Mactaquac, NB]

Mr. Chair, thank you very much for this. About five years ago, we had a draft report in natural resources that was leaked. I think that was very inadvertent, and I don't think anybody really intended for that to happen the way it did. This might have happened just the way that did. Hopefully, for another five or six years nothing else will happen.

I would just appreciate caution on the part of all members of committee to make sure that when we are out talking, we do consider that some of these meetings are in camera and that the details of those in camera meetings are not shared.

I agree with Mr. Julian. People knew the motion was on the table, because it was read in public, but the details certainly weren't. I'd just appreciate everybody keeping that in mind.

[The Chair, Conservative, Leon Benoit]

That was exactly my point, Mr. Allen. Thank you. We have to trust that things that are discussed in camera stay in camera.

Let's get to the business we're here to discuss today.

As witnesses today we have, first of all, from Unifor, Lana Payne, Atlantic director. Welcome.

We have by video conference from Halifax, Nova Scotia, from the Maritimes Energy Association, Barbara Pike, chief executive officer. Welcome to you.

As an individual, we have Susan Dodd, assistant professor of humanities and an author from University of King's College, Nova Scotia. Welcome to you.

Thank you all for being available today. There was a fourth witness who was supposed to be with us by video conference today who is ill and couldn't be here. I certainly wish them a speedy recovery.

We will go with presentations of up to seven minutes in the order that witnesses are listed on the agenda, starting with Lana Payne, Atlantic director of Unifor.

Go ahead, please, with your presentation.

[Lana Payne, Atlantic Director, Unifor]

Thanks, everybody, for having us here. We really appreciate the opportunity to present on Bill C-5.

I would like to give apologies, because our presentation is only now at our translation department. We will send it electronically so that folks can have it, although I did bring the English version for your translation department.

Today, as already mentioned, I am here representing Unifor, Canada's largest energy union. My remarks, I would add, are supported by both the Newfoundland and Labrador and Nova Scotia federations of labour, which were both active in their provinces with respect to consultations over the last decade dealing with an offshore oil and gas safety regime.

Over 20,000 of Unifor's more than 300,000 members work in the energy sector across Canada, including over 700 workers in Newfoundland and Labrador's offshore oil industry on both the Hibernia and Terra Nova platforms.

It is an industry, as you in this room will know, that has known its share of tragedy over the years: the sinking of the Ocean Ranger drill rig in February 1982, and the perishing of 84 workers; and in March 2009, the crash of Cougar flight 491, with the loss of 17 workers.

The joint federal-provincial commission of inquiry report into the Ocean Ranger disaster noted that “the shock wave created by the loss was felt particularly throughout” our province. It also noted, “In that tightly-knit maritime community there were few who did not discover a link, direct or indirect, to one of those lost in the tragedy.”

Similar words and sentiments were repeated following the crash of flight 491. Perhaps this is why workplace safety in the Newfoundland and Labrador offshore is such a matter of public concern as well as worker concern.

Unifor is very pleased that we finally have, with the federal enactment of this bill, real safety laws for our offshore that can be enforced rather than the guidelines that were in place for the last two decades. A safety regime tailored to the unique challenges posed by working in the offshore is a positive step, but there is still substantial room, in our opinion, for improvement with respect to building a responsive, proactive, and preventative occupational health and safety culture in the Newfoundland and Labrador offshore oil industry.

First and foremost, it's quite unfortunate that the legislation does not address what we believe is still critically needed in our offshore, an independent, powerful, stand-alone authority in charge of safety and the environment, as was recommended by Commissioner Robert Wells, who I believe you may have heard from last week as a witness.

In this regard, Canada is still far behind industrialized oil economies such as Norway, the U.K., and Australia. Even the United States has made a move to separate safety and environmental enforcement from the management of the offshore oil and gas industry with the creation of the Bureau of Safety and Environmental Enforcement.

The U.K. moved in this direction after the Piper Alpha disaster and subsequent public inquiry by Judge Cullen. An explosion and fire on the U.K. platform in 1988 killed 167 men. It is still considered the world's worst offshore oil disaster. It raised the issue of competing or conflicting regulatory mandates and what we today call regulatory capture.

The inquiry recommended that the responsibility for enforcing safety should be removed from the department of energy and placed with the health and safety executive, because having both production and safety overseen by the same agency was viewed as a conflict of interest. This has now become the standard in most oil-producing countries or industrialized ones.

In 2005, Australia, also heeding the advice of Justice Cullen, created the National Offshore Petroleum Safety Authority, an independent offshore safety agency. In 2012 they added environment to its responsibilities.

In June of this year, the head of the Australian safety and environmental agency, Jane Cutler, noted that the Piper Alpha disaster and inquiry and recommendations by Lord Cullen have had a huge impact on safety regulation and enforcement in her country.

She noted, “An entrenched industry and regulatory culture is very difficult to change even when faced by clear evidence of the need to improve the human and organizational aspects of their safety programs. There is resistance to change even when there is a clear opportunity to refocus regulatory programs to emphasize the role of human, organizational and management influences on offshore safety.”

She said that as we move forward we must ensure that “safety and environmental management are treated with the same degree of seriousness as profit and loss”.

Norway is perhaps the world leader with respect to offshore safety and the environment and in its involvement of all stakeholders in developing and implementing a world-class safety culture for the offshore oil industry. In 2004 it created the Petroleum Safety Authority. In both phase one and phase two of his inquiry report, Commissioner Wells was very clear about the need for such an independent safety authority. He said, “Vigorous oversight and prompt action can avert accidents and prevent injury and loss of life.”

Commissioner Wells was also very clear about the importance of communications and engagement with workers and the public with respect to safety in the offshore oil industry. It's been three years since the release of his report and still the full spirit and intent of his recommendations have not been implemented.

I can share some examples with you about this, but I don't think my seven minutes are going to allow for time, so if someone wants to use their question in that regard, I can certainly fill in.

There are two examples I would raise with respect to that point.

First is the July 2011 near crash, the severity of which was not reported to workers or to the people of Newfoundland and Labrador by the regulator or the operators. At that time the helicopter carrying crew offshore came within 38 feet of crashing in the ocean. It had dropped 152 metres in 32 seconds. Workers and the public only found out about the severity of this incident just this fall, two years after it occurred, and only because of the investigation by the Transportation Safety Board. It is also thought that this incident may have had a different result had the near crash occurred at night. You're probably aware that we still do not have night flying in the Newfoundland and Labrador offshore. This is also an issue that I could speak to in any questions you might have.

Recommendation 12 of the Wells inquiry dealt with the issue of night flying, something that has been banned since February 2012 in the offshore of Newfoundland and Labrador and Canada. He did not recommend a return to night flights, but rather recommended that criteria be worked out for cases when night flying might be imperative or during an emergency. This was not exactly the direction that was given to the offshore helicopter implementation committee at the time when Commissioner Wells filed his report. Instead, quite a large caveat was allowed around recommendation 12.

Unifor believes that an independent safety and environmental authority would respond to such cases in a different and more proactive role and fashion. In our opinion, an independent, proactive, and vigilant safety and environmental authority would begin to restore the faith of workers in the role of a regulator in protecting and acting to improve safety in the offshore oil industry. It would avoid the very real danger of regulatory capture.

There are two other points I would like to raise.

The first deals with the issue of right to refuse, which is in proposed section 205.05 in clause 45 of Bill C-5. The language in Bill C-5 is very important and quite strong. We advocated improving this given the dangers in the offshore, but we do raise a matter of concern. That is, in Bill C-4, which I know your committee does not deal with, there have been changes made to the federal labour code with respect to the right to refuse. We are quite concerned that this could impact on this legislation. We would encourage you to keep the language that is currently in this bill, because it is a lot stronger than what we've seen in Bill C-4. Hopefully, you will not make amendments to that part of the bill.

My final point deals with proposed section 205.118, which is the establishment of an advisory council for the offshore oil and gas industry. It refers to a stakeholder advisory council.

We would strongly urge that both the federal and provincial governments ensure that the union representing workers offshore be invited to recommend their own representatives to this committee. This will ensure accountability.

We would also suggest that these worker representatives report back to the workplace safety committees on the council's initiatives and activities. These and other matters do not necessarily require a legislative amendment, but could be achieved in the mandate of the advisory council.

It has been our experience that such a body could provide a proactive approach to safety oversight in the offshore, similar to the tripartite structures in other oil jurisdictions, such as Norway. The Norwegian Petroleum Safety Authority notes that collaboration between employers, unions, governments, and workers are important cornerstones in efforts to establish and develop health and safety in their industry: “From an ethical perspective, it is crucial that people exposed to risk participate in decision-making processes which affect such exposure.”

How workers are currently engaged in the offshore needs to change. While we have seen some small steps in this regard, with the new management at our regulator, it is essential that structures with clearly defined roles and responsibilities be put in place to ensure an ongoing, proactive safety dialogue.

In conclusion, we are pleased that we finally have this safety regime for workers of the offshore oil industry, but we do believe that a stand-alone, powerful, and independent safety and environmental authority is not only necessary but also essential in advancing safety in the Newfoundland and Labrador offshore oil and gas industry.

Thank you.

[The Chair, Conservative, Leon Benoit]

Thank you, Ms. Payne.

Now, by video conference from Halifax, Nova Scotia, from the Maritimes Energy Association, we have Barbara Pike, chief executive officer.

Go ahead, please, Ms. Pike. You have up to seven minutes.

[Barbara Pike, Chief Executive Officer, The Maritimes Energy Association]

Good afternoon, Mr. Chair and honourable members of the committee. It is a pleasure and an honour to be presenting to your committee today on this important piece of legislation.

The Maritimes Energy Association is an independent not-for-profit industry organization. We represent businesses that provide goods and services to the energy sector onshore and offshore, renewable and non-renewable, in eastern Canada, and predominantly in the three maritime provinces.

While operators and producers are members of the association, our core membership is the hundreds of local companies that employ thousands of people and inject hundreds and millions of dollars into our local economies. We appreciate the opportunity to provide on their behalf the association's perspective on Bill C-5, which has become known as the offshore health and safety act.

Maritimes Energy supports the offshore oil and gas industry and encourages its continued development under a robust regulatory regime. We applaud the Canada-Nova Scotia Offshore Petroleum Board and the Canada-Newfoundland and Labrador Offshore Petroleum Board for the work both do and the strict standards to which the boards hold the offshore industry.

It should be noted that safety does come first for the oil and gas industry. This is not about having a safety plan ready or collecting dust on a shelf in your office. It is about a culture of safety. It is a mantra in the industry. Every meeting starts with a safety moment. Every incident is reported. Every trend is tracked. It's not lip service; it is a mantra: safety does come first.

The Maritimes Energy Association supports Bill C-5. It formalizes offshore occupational health and safety legislation, providing clarity around what government agencies are responsible for what.

The legislation establishes a hierarchy of responsibility that makes operators ultimately responsible for all activities related to their operations with regard to occupational health and safety. It requires that operators share this OSH information with their contractors, who are our members. It grants the CNSOPB and the C-NLOPB the authority to disclose to the public information related to occupational health and safety. This adds to the principles of openness, transparency, and accountability for our offshore regulatory regime.

The bill formalizes the right of a worker to refuse work they believe constitutes a danger to themselves or others, and protects them from retaliation. As well, it covers the requirement for occupational health and safety committees.

These amendments clarify jurisdictional uncertainties. The boards will have clear authority under the accord acts to enforce all occupational health and safety requirements.

Maritimes Energy is also supportive of the formation of the advisory council, which will include representatives from industry, government, and employees to provide advice on matters related to occupational health and safety for our members.

These amendments are long overdue, but let me be clear: over the years that these amendments were being negotiated, the safety of offshore workers remained the top priority of both offshore boards. The safety of offshore workers is and always will be a top priority.

Safe operations for workers and for the environment outweigh all other considerations. Both boards have done that, even with legislation that dates back to the 1980s, legislation that obviously does not reflect today's reality. Through guidelines, through conditions on authorizations, and through sheer will, the boards have regulated Canada's east coast offshore industry. Ours is a regulatory regime that does reflect best practices, latest technologies, and most important, lessons learned.

That has not always been easy with the existing accord acts, which require that any amendments be approved by provincial and federal governments. These amendments are such an example.

While we celebrate their introduction and support their passage, we also note that they've been 13 years in the making. It has not been an easy process with the two boards and so many provincial and government departments at the table. It was a lengthy process.

Through those years, the two boards stayed focused. Through such techniques as conditions on authorizations, staff ensured that the latest advances in occupational health and safety were applied. Passage of the bill will strengthen the way the two boards already administer and enforce offshore safety activities for our members.

In closing, I want to reiterate the Maritimes Energy Association's support for Bill C-5. The amendments provide greater clarity for who is responsible for regulating offshore occupational health and safety. It strengthens our regulatory regime.

Safety is the priority of the oil and gas industry. That industry includes the operators, the supply chain, and the regulators. The responsibility for safety rests with those in the workplace: the operator, the contractor, the supervisor, and the worker, everyone in the workplace.

The regulator's responsibility is to see that those who have that responsibility are exercising that responsibility. It is not the job of the regulator to take on the job and guarantee safety.

Like the onshore, Bill C-5 provides clarity for our members working in the offshore. It enforces the requirement that the information needed by our members to exercise their responsibility is provided.

It gives to the boards the regulatory responsibility to ensure that we all—workers, contractors, and operators—make offshore occupational health and safety the top priority.

Thank you for your time, and for your invitation to present to you today.

[The Chair, Conservative, Leon Benoit]

Thank you, Ms. Pike, from the Maritimes Energy Association.

Finally, we have here as an individual today, Susan Dodd, assistant professor of humanities, from the University of King's College, Nova Scotia.

Go ahead, please, with your presentation, for up to seven minutes.

[Dr. Susan Dodd, Assistant Professor of Humanities and Author, University of King's College, Nova Scotia, As an Individual]

Thank you.

I am actually a professor in the foundation year program at the University of King's College, in Halifax. My field of study is social and political philosophy.

I am the author of a book on the aftermath of the Ocean Ranger disaster. At the moment, I'm collaborating with Dr. Mélanie Frappier, from the history of science and technology program at King's, on a textbook for Oxford University Press. That book is called Engineering in Canada: Results, Risks, and Responsibilities. We're using Canadian case studies to provide engineering students with an introduction to their professional code of ethics.

My work on occupational health and safety developed by accident, quite literally. My oldest brother, Jim, was one of the 84 men who died on the Ocean Ranger. It still gets to me, it's amazing.

Anyway, as you know, in the wake of that disaster, the Government of Canada and the Province of Newfoundland conducted a long inquiry, first, into the causes of the loss, and second, into the appropriate regulatory organization for the Canada-Newfoundland offshore.

In those days, one of the biggest problems was turf wars between Ottawa and St. John's. Chief Justice Hickman's decision to house the permit-granting function with the occupational health and safety regulatory function was deliberate. When I interviewed him for the book on the Ocean Ranger, he was really clear that he thought those groups should be under the same organization in order to prevent what he saw as one of the main political causes of the Ocean Ranger disaster, and that was fragmentation among bureaucracies, among the power holders.

More importantly, and I often need to reiterate this point, the cause of the Ocean Ranger disaster was not the weather. It was a lack of political will to regulate in 1982.

Both Newfoundland and Canada wrongly assumed that the oil companies would self-regulate, that they would comply with the rules that covered them when they operated in American jurisdictions, and those companies did not.

The lesson of the Ocean Ranger disaster is that the kind of regulatory regime in place is less important than the government's expression of political will. If there is no will to enforce regulations, then we risk setting up our people and our environment for deadly exploitation. This is definitely what we learned at Westray, as well, because if the existing legislation had been enforced at Westray, that explosion and those deaths would not have happened.

Within companies, the first priority, the raison d'être of the organization, is to maximize pay for shareholders. This is not hostility or antipathy; it's a matter of priorities. Government's job is to ensure that the collective goods of the electorate are enhanced by, not just protected from, corporate activity. The regulatory needs of the offshore in Canada changed with time, obviously.

In 1982, one of the most pressing problems was a combination of thoughtlessness about occupational health and safety, a combative relationship between federal and provincial authorities, and a deadly naïveté about the professionalism of rig operators.

The New Orleans-based operator of the Ocean Ranger, Ocean Drilling and Exploration Company, was one of the most experienced rig operators in the world in 1982. Even the most cursory glance at Chief Justice Hickman's report will show you that ODECO was negligent by any common-sense use of that term.

ODECO's deadly mismanagement of the Ocean Ranger was possible only because the Province of Newfoundland and the Government of Canada were preoccupied with fighting over anticipated revenues, and they were naively confident that the so-called experts in the industry would perform professionally.

This dynamic will certainly repeat itself if government is once again complacent about its regulatory responsibility. It is worth remembering that although ODECO no longer exists, it and its fleet were purchased by Diamond Offshore Drilling, which still uses the name “Ocean” in the names of their vessels.

The well owner was Mobil Oil, so I'm glad to see how clearly Bill C-5 points to the responsibility of the owners to ensure that the rig operator behaves professionally in relation to safety.

Today, one of the central problems that this bill seems to address is clarity around functions and the need to keep regulations up to date in the changing industry.

I have given a lot of thought to what I could add to your discussion that...[Technical difficulty—Editor]

First, the regulatory structure will be exactly as effective as the political will that supports it. Where there is no political will, that is, where it is assumed that corporations are best left to their own expert judgment, there can be no effective regulation. That is where disaster begins.

The fact that this bill does not implement recommendation 29 from the Wells commission seems to me to be potentially a red herring. If the political will to regulate is communicated, safety will be respected. A stand-alone safety division would be effective only if it had resources and a commitment from government to prosecute when appropriate. Simply creating the office will not do the trick. It would require an investment.

Second, failure to regulate leads not only to loss of life and destruction of the environment, but also to the public's losing confidence in the legitimacy of government. This happened to an extent after the Ocean Ranger loss, certainly after the Westray disaster, in the States after the Deepwater Horizon disaster and the oil spill, and we're seeing the same kind of dynamic after the Lac-Mégantic disaster. These events are also political disasters.

Third, I would like to see a fines system that earmarks revenues for research and development. When I interviewed John Crosbie for the book, he said, “We still don't know how to get those men off those rigs.” That was a sort of typically gendered statement, but anyway....

Industry does not have an internal motivation to study evacuation systems. Government needs to take that on, and in this case I would say in partnership with Memorial and Dalhousie engineering schools. We can't leave research and development simply to industry. They have different priorities than the good of the public. We need independent researchers working on evacuation and rescue technologies.

Fourth, the advisory council might, in cooperation with governments, business, and universities, convene a conference on regulation every three years. Having a regularized conference would help Canada keep up with changing industry and international standards. We could invite regulation experts from Europe as well as from the U.S.A. We might use Hickman's conference that he conducted after the Ocean Ranger as a model for that.

I would love to see governments consider local, by which I mean provincial, hiring and training requirements. The training would have to go with it, right? Otherwise things like the Ocean Ranger disaster happen.

My sixth and final point is a question. It goes back, I think, to the spirit of the recommendation on the Wells commission around the independence of safety regulators. The question is this: Does Bill C-5's clarification of the roles of the various officers entail an increase in the number of government officers responsible for regulating work on the rigs? It seems to me that investment in regulatory personnel would be a real expression of political will to regulate safety in the offshore.

Thank you.

[The Chair, Conservative, Leon Benoit]

Thank you, Ms. Dodd, from the University of King's College in Nova Scotia.

We will go directly to questions and comments. The seven-minute rounds will start with Mr. Trost, followed by Mr. Harris, and then Mr. Regan.

Mr. Trost, go ahead, please, for up to seven minutes.

[Bradley Trost, Conservative, Saskatoon—Humboldt, SK]

Thank you, Mr. Chair.

Thank you to all of our witnesses for being here today.

I'm going to start with a fairly general question before we start to get into more of the specifics that we've asked some of the other witnesses.

Fundamentally, what will change once this legislation is enacted? We've heard from other witnesses who have said that there already is good practice done, and this will add a little bit of clarity. It will add legal teeth. Others have said that not a whole lot will be changed.

Fairly briefly, because I do have other questions, would each of the three of you care to comment on what will change on day one once this legislation is proclaimed into law, from your perspective?

[The Chair, Conservative, Leon Benoit]

Go ahead, Ms. Payne.

[Lana Payne]

There are a couple of very new features in this legislation. One is the ability to put in place an independent safety officer, if need be, which is not there currently.

The implementation of the advisory council in a tripartite fashion I think is also a good step forward, as is the fact that workers have rights with real teeth now. I don't know if you're familiar with it or not, but before, they were only referred to as guidelines. While there was some practice adhering to them, I have to tell you that there was a lot of ambiguity about whose responsibility it was to implement and be in charge of enforcing them. This legislation also clears that up a little bit as well.

[The Chair, Conservative, Leon Benoit]

Thank you, Ms. Payne.

Ms. Dodd, go ahead, please.

[Dr. Susan Dodd]

I don't think I have anything further to add to that.

[The Chair, Conservative, Leon Benoit]

Ms. Pike.

[Barbara Pike]

Fundamentally, there won't be a lot of change. A lot of this has been implemented by the boards over the past number of years, but as was mentioned by Ms. Payne, the fact is that it now has some legal teeth, and particularly for workers, because they now have the right to refuse work and are protected from retaliation. I think that adds a measure of security for them in working in the offshore.

[Bradley Trost, Conservative, Saskatoon—Humboldt, SK]

My next question is predominantly to Ms. Dodd, but again, if other people want to comment, feel free to do so.

I understand very much your point when you were talking about how political will is necessary, and how that's probably more important than organizational structure. One of the things other witnesses have said is that this legislation provides for public accountability, for more public access to information. Do you believe that's an important part of implementing the political will that you were talking about? If so, why? If not, why not?

[Dr. Susan Dodd]

Absolutely, and for these workplaces, it's very much like coal mines, in the sense that they're invisible to the people who aren't out there, and one of the things that happens is that if regulation is lax, you wind up with a kind of ghost regulatory regime. People who aren't out there think things are safe, and the conditions can disintegrate to a point where workers are bullied and the situation is horrific. Access to information I think is absolutely crucial to safety.

[Bradley Trost, Conservative, Saskatoon—Humboldt, SK]

Does anyone else have a very brief comment?

[Barbara Pike]

I agree, particularly on the way the legislation is written. The boards, while they have perhaps wanted to be able to release information in the past, have been restricted in releasing it, because of the protection of information provided to them by a third party and what can actually be released through access to information legislation.

[Bradley Trost, Conservative, Saskatoon—Humboldt, SK]

Thank you.

[Lana Payne]

I hope that public accountability is improved through this legislation, because it's certainly needed.

[Bradley Trost, Conservative, Saskatoon—Humboldt, SK]

Thank you for your answers.

Ms. Pike, when you were talking about going through your list of things that are going to change, you mentioned that jurisdictional uncertainty will decrease. We've heard that before, but none of us here have really worked on the rigs—at least, I don't think any of us around here have—and we're not regulators.

I've flown in a lot of helicopters, and I was a mining geophysicist, but I never did anything offshore in my geophysics career. Can you give a concrete example of how jurisdictional uncertainty will decrease through this? Maybe I should have given you more warning on this, but can you give us something that we can understand and grasp as lay people, effectively, in understanding this?