The MMS is on

record as not allowing long-term gas flaring or reinjection into the formation.

[What is long-term? How long?--RSB] [On-record is not for enforcing. Note no regulation cited.--RSB]

Flaring oil field gas for up to one year may be permitted for

economic reasons, with justification, if there is an approved plan of action to eliminate the flare.

hIn some instances, an extended well test may be

necessary to confirm the development potential. A well test could last for several days to a

month. For an extended test, the actual producing time (well flowing) is typically less than

one-half the total test time. Significant data are gathered about the system from the pressure

build-up stage of a well test. Oil recovered as part of the well test will be stored and reinjected,

burned, or transported to shore for sales or disposal; gas is normally flared during the test. The

MMS has limits for the duration of allowable flaring and burning operations.

Gas Conversion and Transportation. One of the major issues facing deepwater

development is the disposition of produced natural gas. The MMS has stated publicly that

flaring will not be allowed on the OCS, and has further mandated that reinjection of produced

gas would not be permitted unless there are plans for future recovery. Production systems

such as an FPSO or non-storage floating production systems that employ shuttle tankers for

the transport of oil would require the installation of a pipeline to transport gas to shore. Major

deepwater gas discoveries that occur more than 70 miles from infrastructure could remain

undeveloped because of the technical and economic challenges. [means associated gas from oil wells will be flared--70 miles is nothing, see Kuwait plumes) (Note: 70 miles is considered

a practical limit on the basis of the record-setting distance for Shell’s Mensa subsea

development located in the Mississippi Canyon area of the GOM; Mensa is a subsea