What Does $19 Billion Buy?

I see in the Washington Post that two members of Michigan's Congressional delegation have proposed more than doubling the current federal purchase subsidy for electric vehicles to around $19 billion. They would do that by increasing the numbers of vehicles from each manufacturer eligible for the $7,500 EV tax credit from 200,000 to 500,000, over ten years. Although I firmly believe that EVs and other advanced vehicles represent an important and inevitable part of our national energy strategy and future vehicle fleet, it's worth considering what this $19 billion would buy, in terms of the outcomes we really care about. After all, putting EVs on the road is not an end in itself. As the article's title in the print edition suggested, this looks like a pricey plan.

The two main factors behind the government's support for electric vehicles are concerns about energy security and greenhouse gas emissions. At least on these metrics and even with the most optimistic assumptions--that EVs will displace average cars rather than efficient hybrids and that they will be recharged from zero-emission sources of electricity--the $7,500 per car benefit looks expensive. If the average EV were driven 10,000 miles a year for 10 years, which seems reasonable in light of the range limitations of current models and the uncertainty surrounding battery life, then each car would save 4,000 gallons of fuel and avoid CO2 emissions on the order of 40 tons during its life. So from an energy security perspective taxpayers are paying the equivalent of $79 for each barrel of oil saved, or from an emissions perspective $188/ton. The former is nearly the current cost of oil, while the latter is ten times the estimated cost of emissions credits used by supporters of the last unsuccessful cap & trade bill.

Aggregating the oil savings attributable to these EVs over the roughly 2.5 million cars implied by the $19 billion figure gets us to the equivalent of 66,000 barrels per day once they're all on the road. That is only about a tenth of the domestic oil production that the latest industry estimate suggests we stand to lose by 2019 if the implementation of new rules for deepwater drilling results in significant delays in obtaining permits and beginning new deepwater exploration and production projects. I understand that this isn't exactly an apples to oranges comparison, but I have a hard time seeing why the same energy security considerations involved in the current EV push wouldn't apply at least as much to ensuring that the federal offshore permitting process is as streamlined as we can make it, consistent with the complexity and risks of these projects, and that the agency issuing permits has a large enough budget to hire a technically qualified staff sufficient to the task.

To the extent that subsidies are necessary to make today's electric vehicles attractive to ordinary consumers, our elected representatives should be focused on making sure those subsidies are as smart and responsive as possible. Paying the same subsidy as today for an EV produced in 2020, when we are frequently assured that battery and other costs will be much lower, makes no sense and invites inefficiency. Instead of more than doubling subsidies just when the current ones--along with generous manufacturing grants, tax credits, loans and loan guarantees--are succeeding in getting carmakers into the EV game, Congress should now be thinking about how to phase them out. We must avoid creating the kind of subsidy addiction that the ethanol industry has exhibited since its start in the late 1970s. We might have been able to afford that kind of approach once, but no longer, particularly when around 40% of the $19 billion in question here will result in new federal debt.

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Sputnik State of the Union

Energy didn't feature as prominently in last night's State of the Union Address as it has in some years, including last year's speech. Rather than making it a primary focus area, the President seemed to mention it more as an example of his broader innovation and competitiveness agenda. That's probably a good thing, because the administration's persistence in pitting conventional energy against renewables reflects the muddle in which US energy policy remains. We're desperately worried that China is getting ahead of us in renewable energy, yet we don't seem to notice that China is hardly treating oil and gas as yesterday's energy. I suspect that from China's perspective, their focus is not especially on renewable energy or clean energy but on cheap energy, which is what their economy needs to grow. I wouldn't think we're so different in that regard.

I won't waste time dissecting the President's suggestion to strip the oil & gas industry of its tax benefits in order to fund a new or expanded clean energy innovation effort. If the administration couldn't make that happen when its party dominated both houses of Congress by large majorities, then this idea is simply dead on arrival in an era of divided government. The best way to address those subsidies, along with the much larger per-barrel subsidy for ethanol, is through the kind of tax reform that would make all US industries more competitive globally. So I was pleased to hear the President suggest simplifying the tax code and reducing the corporate income tax.

Innovation and tax reform will indeed be crucial if the US wants to be a leader in clean energy technology, not just as the favored beneficiary of today's version of our periodic debate over industrial policy--picking winners--but as one part of a more robust and competitive US manufacturing sector. However, it's myopic to compare ourselves to China on infrastructure and clean energy innovation while ignoring China's full-court press to meet its rapidly growing demand for oil and gas. China doesn't have an offshore drilling moratorium or "permitorium"; instead it has focused on offshore drilling as a primary means for expanding its domestic production and limiting its oil imports, which a few years ago eclipsed those of Japan as the world's second largest, behind our own. Chinese companies are investing in oil & gas projects, joint ventures and acquisitions all over the world, because China recognizes that oil wasn't just the dominant fuel of the 20th century; it remains a key energy source in the 21st. And for those worried about China's lead in renewable energy, exemplified by the news that its wind power capacity surpassed that of the US last year, I recommend Michael Levi's article in Foreign Policy.

On a more positive note, President Obama seemed to signal his support for moving the debate on a national renewable energy standard toward encompassing all clean energy. His remarks suggested that this would include not just nuclear power--by far our largest source of low-emission energy today--but also natural gas and clean coal. With those inclusions, the goal he suggested of generating 80% of our electricity from "clean energy sources" by 2035 could be the most achievable energy goal his administration has put forward since taking office. With coal's share of electricity generation currently at 45%, it would require increasing the contribution from nuclear, renewables and natural gas by just under half--or less with some help from efficiency and conservation. Not easy, but not impossible, either, as long as we build enough new nuclear power plants to more than replace the ones that will likely have been retired by then.

Whether or not this is truly "our generation's Sputnik moment", the speech's recurring theme exhorting us to "win the future" was perhaps a bit too reminiscent of another presidential speech centered on a different kind of "WIN". Ensuring that this initiative doesn't share the fate of that earlier one in the Ford Administration might just depend on making sure that in an environment of tightening purse strings, the government's investments in new energy are focused on making clean energy cheap enough to compete without unsustainable subsidies. In the meantime, while we're waiting for that effort to bear fruit, it's worth recalling that America's conventional energy industry is still one sector in which we don't have to catch up with anyone else, unless we deliberately set out to hamstring it.

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The Regulatory-Ethanol Complex

The US Environmental Protection Agency has a problem, and that problem is ethanol. Last Friday the EPA expanded its previous waiver on ethanol in gasoline to allow blends of up to 15% to be used in cars built in model year 2001 and later, compared to the earlier threshold of model year 2007. Because it did this just three months after granting the initial waiver, it's not clear how much additional testing was actually done, despite the agency's obligatory reference to "sound science". This step is a further indication that EPA is presiding over a failed biofuel mandate created by Congress in the expectation that a massive cellulosic biofuel industry would spring forth at their command, in parallel with a massive upsurge in sales of the 85% ethanol/15% gasoline blend, E85. None of that has happened, and for now the corn ethanol industry is the only horse that EPA has left to ride in this race. Until these waivers were issued, that horse was rapidly running out of track on which to run.

It's not that EPA loves corn ethanol. In fact, the first draft of its RFS2 renewable fuel standard incorporated an emissions-measurement basis that was distinctly unfavorable to older conventional ethanol facilities. That was subsequently toned down, after reinterpreting the science relating to "indirect land use impacts". Unfortunately for EPA, however, corn ethanol is the only avenue for continuing to comply with the annually escalating biofuel mandate set in the Energy Independence and Security Act of 2007, unless they want to flood the US with Brazilian cane ethanol. Oilseed-based biodiesel remains a niche product, and the US biodiesel industry is half-dead after the EU imposed anti-dumping tariffs as punishment for biodiesel exports to Europe that were subsidized by a $1.00 per gallon US biodiesel tax credit--a credit that lapsed at the end of 2009 but was reinstated retroactively as part of the Lame Duck Congress's tax deal.

The central problem relates to the so-called blend wall, the annual quantity of ethanol that can be accommodated in gasoline under the previous 10% blending limit. With US gasoline sales having dropped in 2008, rather than continuing on their path of 1-2% annual increases, and still not recovered to their former level, the entire US gasoline pool can only absorb 13.9 billion gallons per year of ethanol. As a practical matter, the blend wall is probably a billion gallons lower than that, given the challenges of getting ethanol to the remotest corners of the country. By coincidence, the RFS target for 2011 after backing out the renewable diesel requirement is roughly 13 billion gallons. The production capacity of the US corn ethanol industry already stands at 14 billion gallons per year, with more ethanol plants under construction or expansion.

Accommodating all that extra ethanol would have been easy if E85 had taken off as planned. However, if Minnesota's E85 statistics are any indication, E85 sales appear to have declined since 2008. In the absence of E85 demand, the EPA's waivers have the effect of moving the blend wall and giving the ethanol industry more headroom to grow. In theory, this would also have been needed to make room for cellulosic ethanol, but so little of that is being produced that EPA has had to scale back its quota for that category two years in a row, with a further adjustment in 2012 a virtual certainty.

Expanding the waiver to cover earlier car model years was crucial to making it useful. The first round didn't encompass enough cars--and thus enough annual fuel volume-to make it likely that refiners, distributors and retailers would incur the cost and risks of introducing it into the market. Going back to 2001 adds roughly another 90 million cars and light trucks and includes some of the highest car-sales years in US history. As a result, the broader waiver now probably covers about half of the 240 million light-duty vehicles on the road in the US.

The consequence for consumers will be higher taxes, in several forms. First, there's the tax associated with paying for fuel that has less value, due to ethanol's lower energy content, yet carries the same pump price. At current gasoline prices a gallon of E15 is worth about 5.5 ¢ less than the E10 blend most of us are buying today. Then there's the indirect tax associated with the higher maintenance and repair expenses that some motorists are likely to experience. Despite the EPA's reassurances about having tested E15, the focus of their testing was explicitly on emissions, not on performance and longevity. And finally there's the tax or debt we'll incur for the ethanol blenders credit that will be paid out on the incremental ethanol volumes facilitated by the waiver. That could eventually amount to an extra $3.2 billion per year, unless the current Congress finally ends this redundant subsidy that has been in place for more than thirty years.

Although it is probably best viewed as a marriage of convenience, for now the EPA and the corn ethanol industry are joined at the hip, forming a sort of regulatory-industrial complex. For political reasons EPA can't afford to abandon its partner, because the administration is fully committed to the RFS2 biofuel targets as part of its broader approach to energy security and emissions--even though corn ethanol does little or nothing to reduce the latter. Until and unless E85 takes off, the only real alternative to the E15 waivers would be to admit that the 2007 biofuel standards were unrealistically ambitious and must be suspended pending the arrival of so-called drop-in fuels--synthetic hydrocarbons derived from biomass sources such as algae, cellulose or sugar cane. Drop-ins could provide the same renewables energy benefits as ethanol, but without the latter's blending, fuel economy and logistical disadvantages. In the meantime, I will not knowingly fuel either of my family's 2004 model cars with E15, as long as I have a choice.

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Fueling the World's Growth

Several articles led me to what is apparently BP's first-ever public long-term energy forecast, "BP Energy Outlook 2030", which was released earlier this week. It's a fascinating document on several levels, and it builds on the reputation established by the BP Statistical Review, an annual compendium of historical energy data and trends. The figure that I've already seen cited in a number of places is that BP expects fossil fuels to contribute just 64% of the growth in energy over the next twenty years, compared to 83% in the last twenty. A quick internet search revealed many other tidbits that reporters and bloggers have picked up on, including a very interesting comparison of future energy security trends among China, the EU and US. I could spend hours detailing the observations that intrigued me, but I'll focus on just a few.

The mere fact of BP's releasing such a forecast seems noteworthy. Perhaps it's aimed at increasing transparency under a new CEO, as Mr. Dudley suggests in his introduction, or maybe the folks who've been creating such documents internally finally convinced management that they had at least as much PR value as the venerable Statistical Review. Their approach to the report also reminds us just how different BP's culture is from that of its UK (and Dutch) arch-rival Shell, which has long preferred scenario planning to conventional forecasting. Both have their uses, though for deep insights I also prefer scenarios and use that technique with my clients. I suggest having a look at Shell's latest publicly-available pair of scenarios looking out to 2050 for another perspective on future energy. The current edition morphs a previous version's theme of "TINA" (There Is No Alternative) into "TANIA" (There Are No Ideal Answers). Amen. And now back to BP's point of view.

The report's projection concerning how energy growth is likely to be satisfied over the next two decades is a classic half-full/half-empty proposition. On the half-full side I consider it a remarkable indication of the success of renewables and the expansion of global interest in nuclear power--it's really only a "renaissance" in the US, never having waned in many other places. The idea that the combination of these sources could be viewed in a serious base-case projection as providing more than a third of incremental energy growth would have lacked credibility not very long ago, for reasons the charts on page 10 of the report should make clear. However, I have no doubt that many will find such a projection altogether too faint-hearted, believing that we surely ought to be able to dispense with these dirty fuels entirely within two decades or less. Well, the first step toward living without oil and coal (and maybe even gas) is being able to cover 100% of future energy growth from other sources. BP makes a coherent argument that we are not yet at that point, even in the more aggressive "policy case" results they present later in the report.

From the perspective of long-term emissions reductions and future energy transformation, two other sets of figures in the outlook look more promising. First is the lengthy discussion of energy efficiency and the accelerating reduction in the energy intensity of GDP that's woven all through the document. That is the main reason why, in a view that is distinctly not a low-growth scenario, total energy demand grows by just 39% and not some much higher value. The other key point is that BP sees 57% of that growth being focused on electricity, rather than transportation fuels. Since we have many more effective low-emission options for making electricity than transportation fuels, the opportunity to reduce emissions in the future will expand significantly, even if in the short run coal is merely losing market share, while its use still increases in absolute terms.

BP's detailed projections for oil and biofuels, along with the growth of China, deserve an entire posting of their own, and perhaps I'll come back to them in the next week or two. In the meantime the last item I wanted to highlight concerns energy security, which has been such a prevalent theme in US politics and public discussion for so long. As I read the chart on page 72--and to the extent I accept its assumptions--I would not trade (energy) places with the EU or China for all the tea in the world, despite all the recent talk of US decline and Chinese ascendancy.

With regard to Europe we see the inevitable consequences of the peaking and decline of the North Sea oil and gas resources. Already more dependent than the US for imports of both oil and gas at this point, Europe will need a generation for its massive focus on renewables to stem the steady rise of its energy import dependence. China's situation is entirely different, as its explosive growth outruns the steady increases in its oil and gas production. If you want to understand why China hasn't abandoned coal and suddenly seems so interested in nuclear and renewables, this picture is worth the proverbial thousand words. Of course the US trajectory is hardly a given. Skim through the report's other charts to see how much that pleasant outcome of greatly improved energy independence depends on shale gas (page 54), fuel economy gains (page 30) and biofuels (page 40). And note that BP suggests that most of the latter will come from "first generation" sources--corn and sugar cane--in this timeframe.

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Displacing More Oil from Power Generation

Increasing the US contribution of wind and solar power, geothermal energy, and even nuclear power would have virtually no effect on our oil imports or energy security, because we use so little oil for power. However, a pair of articles reminded me that this logic doesn't necessarily apply elsewhere. On Monday the Financial Times described the rapid growth of electricity demand in the Middle East, much of it fueled by oil that might otherwise be exported. Saudi Arabia apparently burns up to a million barrels per day of oil for power generation in the summer. And last week Fast Company highlighted the potential of large fuel cells to replace the diesel engines that generate power aboard tankers and other ships. As oil prices again approach $100 per barrel, with the possibility of even higher prices ahead when the entire global economy has returned to normal growth, these situations represent golden opportunities to save large quantities of oil for other uses for which its nearest substitutes still cannot replace it at scale.

Based on Department of Energy data the US generated just 0.9% of our electricity from petroleum and its products in the last year, with more than a third of that fueled by petroleum coke, a low-value solid byproduct of oil refining. The 43.5 million barrels of petroleum liquids used in power generation in 2009 represented only 0.6% of the 6.9 billion barrels the US consumed that year. When you break that sliver down by location, much of it is used for either backup generation or on islands or other remote locations. In other words, the remaining potential to displace oil from power generation in the US is very small and not necessarily well-suited to the intermittent renewable energy technologies now in favor. (That should change as electric vehicles enter the fleet by the millions, but that prospect remains some years off, at least.)

That situation isn't representative of the world as a whole, however, with oil accounting for almost 5% of global electricity generation in 2007. It was even higher on a regional basis, at 7% outside the countries of the OECD and 35% in the Middle East. Globally this amounted to 5 million bbl/day, or nearly 6% of total oil demand. That might not sound like much, until you consider that a drop in demand of around 3 million bbl/day from the first quarter of 2008 to the first quarter of 2009 contributed to a decline in oil prices--ignoring the mid-2008 spike to $145/bbl--of roughly $50/bbl. The price of oil is truly determined by the last few million bbl/day of supply and/or demand. You don't need to be worried about Peak Oil to see the oil used globally for power generation as potentially low-hanging fruit for redeployment, and as a significant emissions-reduction opportunity.

The best candidates to displace that oil vary by country and region. For countries with a lot of natural gas, like the big producers of the Middle East, a switch to that fuel seems like an obvious choice. However, much of the world's natural gas outside North America, including most LNG on long-term contracts, is priced based on oil, so the savings probably wouldn't be as large as they would be here. Even for oil exporters like Saudi Arabia, it might still make more sense to burn the residual fuel from the country's many large refineries, instead of importing LNG (or developing more of its own gas) and investing in the refining hardware to turn that residuum into gasoline, diesel and jet fuel. That might explain why the Kingdom is pursuing nuclear power to cover much of its future generating capacity growth. Renewables have also been capturing a foothold in the region, particularly in projects like Masdar City.

Finally, the large-scale marine fuel cell opportunity described in Fast Company would target a segment where oil has a near monopoly, outside of military fleets: shipboard power. And while these molten carbonate or solid-oxide high-temperature fuel cells would still consume fossil fuels to auto-generate the hydrogen they use, their high efficiencies would reduce overall oil consumption in shipping. If it proves possible eventually to use even larger fuel cells as the basis for electrifying vessel propulsion, as the article speculated, then oil savings would be much more substantial. Global consumption of bunker fuel by ships amounts to roughly 3.7 million bbl/day, or around 4% of total oil demand. And the environmental benefits of such a switch would go beyond greenhouse gases to include significant local air pollution benefits, particularly in ports.

None of this represents new thinking, but rather an extension of some of the strategies by which the developed world of the time adapted to the high oil prices of the twin oil crises in the 1970s. Still, it's easy to forget that that the quantity of oil tied up in the sectors mentioned above exceeds the output of the entire North Sea at its peak. If oil prices hadn't buckled under the weight of the financial crisis and recession a couple of years ago and instead remained on their previous trajectory, I imagine we'd already be well down the path of freeing up more of this oil. Recent price trends suggest that the primary motivation for doing so could be about to return.

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Commodity Cycles and Renewable Energy Costs

It's an article of faith for many that the costs of renewable energy sources will continue to decline, even while the costs of many other forms of energy increase. This view is supported by the impressive experience with both wind turbines and solar photovoltaic (PV) installations over the last couple of decades. The latest survey of US solar cost trends from the Lawrence Berkeley National Laboratory (LBNL) showed that between 1998 and 2009, the capacity-weighted average cost of PV installations fell by more than 30%, from $10.80/Watt to $7.50/W, with another drop of roughly $1/W occurring during 2010. However, it's important to think about what's behind these trends when assessing their future progression. Continued cost declines are subject to many uncertainties, not the least of which is the current rising tide of commodity prices as the global economy recovers.

The rationale for continued cost declines that I encounter most often is based on volume: If we install more wind and solar capacity, costs will fall in a virtuous cycle, making subsequent installations cheaper and prompting even more of them. The underlying logic behind this argument derives from empirically observed "experience curves", in which cost components such as manufacturing fall by a set percentage for each doubling of cumulative output. The problem with these curves is that they tend to flatten out fairly quickly, delivering their maximum effect in the early years of a technology, when doublings are frequent. Then they slow significantly as the technology gains scale and the interval between doublings grows. A look at global wind turbine capacity shows that it doubled four times between 1996 and 2008. At the currently expected pace of additions, the next twelve years could produce just two or three doublings. And as the experience curve effect slows, other factors including commodity costs can overwhelm it.

We saw that a few years ago, when the boom economy stoked by the inflating global financial bubble drove up commodity and construction costs to such a degree that wind project costs stopped falling and began to rise. These pressures eased after 2008, mainly because the recession and financial crisis reduced overall demand for construction and raw materials, while the rapid growth of renewable energy equipment manufacturing, especially in Asia, led to overcapacity and stronger price competition. That probably accounts for much of the effect that LBNL saw in its solar trends in the last two years, rather than the sort of scientific and engineering improvements that drive experience curve effects.

So what is likely to happen as the economy rebounds and the slack that developed is taken up? We're already seeing the early results in higher prices of raw materials such as steel. And higher prices for oil and coal, which are important inputs in the extraction and processing of many other raw materials, should intensify the pressure already being felt from the demand in developing Asia. For renewables, this could be further complicated by tightening supplies of critical materials such as rare earth metals, Tellurium, Lithium and other key ingredients of electric motors, thin-film solar modules, and electric vehicle batteries. Toyota and other makers of hybrid and electric vehicles are working on ways to circumvent these materials, but the results might not come fast enough to prevent a crunch.

The renewable energy industry is counting on a return to economic growth to boost demand for electricity. Together with government-mandated renewable energy targets, that should translate into increased demand for equipment like wind turbines and solar panels. However, if the underlying source of that demand increases their material and construction costs just as governments are coming under increasing pressure to reduce subsidies for the industry, the result might be that the end-users of these products could see their effective costs go up for the first time in several years. That would be a rude shock for those who believe that these costs must inevitably fall as installations grow.

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The Commission Finds...

I've been skimming through the report of the presidential commission on the Deepwater Horizon accident. Lacking time to read every word, I'm finding it on the whole a moderate document. By that I mean that it will not satisfy either those who expected the commission to repudiate deepwater drilling entirely or those that harbored faint hopes that it might issue a blueprint for a rapid return to drilling incorporating the key learnings of the disaster. Instead, as a number of observers have pointed out, its findings point to a complex web of contributing factors--in the process implicating the entire industry--and its recommendations suggest a thicket of new regulations and added fees for oil & gas exploration in US waters.

Anyone awaiting gleaming insights and Ah-ha! moments such as those that exemplified the Rogers Commission's investigation of the space shuttle Challenger accident was bound to be disappointed. With no commissioner having direct knowledge of the theory and practice of offshore drilling in the way that the Rogers Commission included some of the leading lights of the US aerospace community at the time, there was no one to lead it to such results, only paid technical staff to carry out the guidance of a team led by professional politicians. That's not as bad as it sounds. Given the breakdown of what little trust existed for the oil & gas industry, a commission made up largely of experienced oil executives, petroleum engineers and geologists would have lacked credibility with governmental decision makers and the public. However, the composition of the commission surely presaged the outcome of its work.

In the foreword to the document, which is probably all that many will ever read, I was reassured to see a broad recognition of the importance of petroleum to the US economy, the challenges involved in moving away from it, and the necessity of exploiting the resources of the Gulf of Mexico. The commission also pointed out that our conscious decision to focus offshore drilling in the Gulf and not elsewhere carries risks--a surprising admission considering that one of the commission chairs played a significant role in the establishment of that policy. However, I was disappointed at the sweeping indictment of the practices of the entire industry.

The commission was neither tasked nor staffed to investigate the entire US offshore drilling community. Such an undertaking would have required either years or a much larger effort. The parallel to the implication that because most of the industry uses the same contractors, then most of the industry must operate in a similarly risky manner would be as if the Rogers Commission had found that because most rockets and many aircraft were built with components from the same suppliers, most rockets and aircraft must be as risky as the shuttle proved to be. That logic is shaky, at best.

My own experience in the industry doesn't qualify me to pass judgment on the overall quality of the commission's investigation or the full implications of its technical and procedural recommendations. However, in my quick perusal of the document several points jumped out at me that seemed to reflect a limited perspective. I'll highlight two examples.

First, with regard to the risk of fatalities on offshore facilities, the report concludes that "From 2004 to 2009, fatalities in the offshore oil and gas industry were more than four times higher per person-hours worked in US waters than in European waters, even though many of the same companies work in both venues." This was backed up by a chart on page 228 comparing these statistics from several sources. Yet while every fatality is one too many, and no one should be complacent about them, I was astonished that it didn't seem to have occurred to the commission's staff to compare these accident statistics to the US industrial safety statistics, either overall or in similar industrial settings. In a brief Google search I turned up the "Census of Fatal Occupational Injuries Summary, 2009" from the Bureau of Labor Statistics of the US Dept. of Labor. Converting the average US fatal work injury rate of 3.3 per 100,000 full-time equivalent workers for 2009 (the year before Deepwater Horizon) to a comparable rate of 1.6 per 100 million manhours, it appears that offshore work is roughly three times as hazardous as the average of all work. When you consider that the latter reflects the contribution of tens of millions of service and government workers in categories for which highway accidents and homicides account for the largest share of risk, I'm not sure how much lower I'd expect the fatality rate to be for a group of people working long hours aboard facilities jammed with rotating equipment and heavy objects. The subject at least deserves a more thorough look than it was given here.

Then there's recommendation G2, which is the catch-all funding mechanism for all the extra regulatory work required to carry out the commission's other recommendations. I don't disagree that the agencies that monitor and issue permits for offshore drilling should be staffed with enough professionals of suitable experience and training to provide effective oversight and to minimize bottlenecks and delays in the permitting and oversight process. However, the idea that the industry should pay for this with added fees--based on a half-baked analogy to the telecommunications industry--ignores the enormous funding mechanism that's already in place in the form of the lease bonuses, rents and royalties collected by the government from these companies. In the previous fiscal year the agency formerly known as the MMS reported $2.3 billion in revenue from activity on the Outer Continental Shelf, after collecting $9.1 billion the year before. If the federal government has been spending these funds for other purposes, rather than allocating a sufficient portion to protect its investment, there's no guarantee that additional monies collected from the industry would be spent more wisely.

Ultimately, the questions of what happened on the Deepwater Horizon and who bears the blame are likely to be resolved in a court of law. It may be just as well that the commission didn't wait for all the evidence to be in to issue its findings. But they also can't be viewed in isolation. We live in a world in which OPEC seems to be quite content to sit on its ample spare production capacity and watch oil prices ratchet back up towards $100 per barrel and potentially higher, as the global economy recovers. The oil buried under the Gulf represents one our best hedges against OPEC's understandable satisfaction with the status quo. Yes, we need better response capabilities for future spills--some of which is already in the works--and yes, the industry must increase its focus on offshore safety and accident prevention. At the same time, we also need the industry to resume drilling absolutely as quickly as feasible under the new guidelines. The apparent lack of urgency on the part of the commission and administration to make that happen seems divorced from the broader context.

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