- Keeping the rule would result in net benefits over the next 10 years that are $65 million larger than what was estimated in the original cost-benefit analysis by the Bureau of Safety and Environmental Enforcement (BSEE).
- Because of a deregulatory provision in the rule, benefits to industry alone outweigh the costs by over $500 million. Repealing the entire rule would therefore harm industry.
- BSEE admitted that it underestimated the benefits from reducing oil spills, which could make it easy for the agency to argue that repealing regulatory provisions results in minimal forgone benefits.
- Calculating a defensible external benefits estimate may not even be possible without more research into how much the rule or its individual requirements reduce oil spill risk.