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removal of the equipment and related DRR work is “required” in
each instance).
We note simply that specific language relating to oil
company DRR obligations is found in the TAPS right-of-way
agreements, but, as we have explained, is not found in the
language and provisions of the DL-1 Leases that relate to
fieldwide oil production facilities at Prudhoe Bay.
Neither the language of paragraph 36 nor the language of
paragraph 20 of the DL-1 Leases reflects fieldwide facility
and equipment dismantlement, removal, or restoration
obligations. As we have explained, paragraph 36 is written in
terms of a “privilege” of the oil companies to remove
equipment if they so choose or of an “option” of Alaska to
have the equipment removed if it so elects. Paragraph 20
refers only generally to waste and due diligence, to
preservation of the land, and to plugging abandoned wells.
Fixed obligations to dismantle, remove, and restore the
Prudhoe Bay fieldwide facilities and equipment are not
reflected in the language of paragraph 20.
Further, as we have found, and contrary to Exxon’s
experts, AOGCC regulations in effect during the years in issue
relate only to plugging, abandonment, and cleanup of oil well
sites and do not apply to, and do not establish, DRR
obligations of the PBU or of the oil companies to the
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