December 10, 2010
Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 7010
100 F Street, N.E.
Washington, D.C. 20549-7010
| Re: | ATP Oil & Gas Corporation |
| Comment Letter Dated December 7, 2010 |
| Registration Statement on Form S-4; File Number 333-169880, filed October 12, 2010 (the “Registration Statement”) |
Ladies and Gentlemen,
Set forth below is the response of ATP Oil & Gas Corporation (“we,” “ATP” or the “Company”) to the comment of the staff of the Securities and Exchange Commission (the “Staff”) in the comment letter of the Staff dated December 7, 2010.
General
| 1. | We note your response to comment 3 in our letter dated November 5, 2010. Please discuss further the resources that you have allocated to address any environmental harm, including the amount of money you are prepared to spend on such efforts, how the money would be spent, the number of employees that will be involved, and any equipment that you own. |
Response: Regarding the amount of money required and how it would be spent, we will dedicate any and all resources available to us to address any environmental harm we cause. The money, personnel and equipment to be committed to such an effort will be dictated by the extent of the incident and the related environmental risk. We are prepared to utilize all available cash and, if necessary, to seek additional liquidity through additional financing sources and asset sales. In the event of any environmental harm caused by us, our direct sources of funds would be supplemented by applicable insurance coverage.
ATP has available to it the resources of the service providers listed below (the “Contracted Providers”), as documented in our Gulf of Mexico Regional Oil Spill Response Plan (“Response Plan”) on file with the BOEM:
ATP Oil & Gas Corporation | 4600 Post Oak Place | Suite 200 | Houston, TX 77027 | www.atpog.com |
Securities and Exchange Commission
Response to Comment Letter Dated December 7, 2010
Description | Contracted Provider | |
Spill Management Team | O’Briens Oil Pollution Service, Inc. | |
Equipment Provider | Clean Gulf Associates | |
Storage Equipment Provider | National Response Corporation | |
Dispersant/Aircraft | Airborne Support, Inc. | |
Response Personnel | Marine Spill Response Corporation | |
Regarding employees and equipment, we employ the industry practice of utilizing the specialized equipment and highly trained employees of third-party service providers because of the infrequent nature of environmental incidents. Our agreements with the Contracted Providers provide immediate access to their personnel and equipment on a 24-hour per day basis. In the event an incident caused by us results in environmental harm, all of our employees would also be available for our response. Our offshore response strategy is built around the oil spill containment and recovery equipment provided by Clean Gulf Associates and supported by Marine Spill Response Corporation. The following table, also derived from our Response Plan, lists equipment directly owned by Clean Gulf Associates that would be available for use in the event of an incident caused by us:
Item Description | Amount | |||
Skimming Vessels | ||||
HOSS Barge (43,000 Bbls/day) | 1 | |||
46' Skimming Vessel (5,000 Bbls/day) | 4 | |||
Marco Skimmer (3,588 Bbls/day) | 3 | |||
Egmopol (3,000 Bbls/day) | 2 | |||
Skimmer Equipment | ||||
Fast Response Unit (3,770 Bbls/day) | 5 | |||
Fast Response Unit (3,400 Bbls/day) | 4 | |||
Rope Mop (77 Bbls/day) | 1 | |||
Foilex Skim Package (TDS 150) | 3 | |||
4 Drum Skimmer (Magnum 100) | 2 | |||
2 Drum Skimmer (TDS 118) | 2 | |||
Boom | ||||
42" Auto Boom (ft) | 25,000 | |||
Beach Boom (ft) | 10,000 | |||
Storage | ||||
Oil Storage Barge - 249 Bbl | 4 | |||
Tanks - 100 Bbl (Secondary) | 8 | |||
Tanks - 100 Bbl (Primary) | 9 | |||
Dispersants | ||||
Exxon Corexit 9527 (330 Gal. Totes) | 4 | |||
Exxon Corexit 9500 (Gal.) | 29,040 | |||
Exxon Corexit 9527 (Gal.) | 4,180 | |||
Dispersant Spray System | 2 | |||
Trailers | ||||
Wildlife Rehabilitation Trailer | 1 | |||
Wildlife Support Trailer | 1 | |||
Support Equipment | ||||
Bird Scare Guns (set of 12) | 10 | |||
Expandi Boom Roto-Pac Unit | 3 | |||
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ATP Oil & Gas Corporation | 4600 Post Oak Place | Suite 200 | Houston, TX 77027 | www.atpog.com |
Securities and Exchange Commission
Response to Comment Letter Dated December 7, 2010
In addition to the contracted resources listed above, we have identified and documented within our Response Plan over 130 resource providers with equipment, support services and supplies available to assist us in our response.
In responding to the comment received from the Staff by letter dated December 7, 2010, ATP acknowledges that: (i) ATP is responsible for the adequacy and accuracy of the disclosure in its Exchange Act filings; (ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to ATP’s Exchange Act filings; and (iii) ATP may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
We trust that our response above adequately address the Staff’s comments on this filing. If you have any questions or comments, please call me at 713-403-5514.
Sincerely, |
ATP Oil & Gas Corporation |
/s/ Albert L. Reese Jr. |
Albert L. Reese Jr. |
Chief Financial Officer |
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ATP Oil & Gas Corporation | 4600 Post Oak Place | Suite 200 | Houston, TX 77027 | www.atpog.com |