Posted in Uncategorized | 5 Comments »
Dr. Jeremy Claisse, Cal Poly Pomona: “The oil and gas platforms off the coast of California are the most productive marine habitats per unit area in the world.”
Dr. Milt Love, UCSB: “Even the least productive platform was more productive than Chesapeake Bay or a coral reef in Moorea.”
John Smith has made the case for reefing California platforms. He is now proposing a change in the regulations that could facilitate such partial removals of offshore structures. His full proposal is attached.
As background John notes:
“In contrast to the Gulf of Mexico (GOM), where more than 600 decommissioned platforms have been converted to artificial reefs, the State of California does not have reefing legislation considered workable by industry, nor does it have an approved or State funded artificial reefing program which is a prerequisite under MMA (formerly BSEE and BOEM) OCS oil and gas regulations (30 CFR § 250.1730) for waiving platform removal requirements which allows conversion of the structure to an artificial reef.“
He further informs that “operators of the platforms have not expressed any serious interest in reefing OCS platform jackets because they consider the California Marine Resources Legacy Act unworkable in its present form due primarily to its liability provisions, inequitable 80% cost-savings sharing requirement, and the requirement for the first reefing applicant to fund the setup costs for the artificial reefing program.“
John’s proposal is intriguing because it allows qualified 3rd parties to accept title and liability for reefed structures. This would create interesting business opportunities. A company, consortium, nonprofit, or entrepreneur could, for a fee, acquire submerged structures and obtain insurance or other financial protection in accordance with their business plan. Reef preservation and enhancement studies, and other marine research could also be conducted at the sites. Marine ecosystems would be protected, and the cost and efficiency of decommissioning operations would be significantly improved.
“So, you disconnect the jacket… you kill all the fish. There’s an awful lot of animals that die,” said Dr. Love. As our world has become dependent on fossil fuels, so too have these millions of animals become dependent on the structures that pump them from beneath the sea floor. “As a biologist, I just give people the facts, but I have my own view as a citizen, which is I think it’s criminal to kill huge numbers of animals,” said Dr. Love.
John’s proposal warrants serious consideration.
Posted in California, decommissioning, Offshore Energy - General, Regulation, rigs-to-reefs | Tagged Calfornia, decommissioning, Jeremy Claisse, John B Smith, Milt Love, offshore platforms, proposed regulation change, reef effect | Leave a Comment »
1947 Oil and Gas is a great name choice given that the first offshore oil well beyond the sight of land was completed in 1947 (see photo). The numeric name choice is reminiscent of historically important team names like the San Francisco 49ers and the Philadelphia 76ers.
The name is especially fitting given that 1947’s first acquisition, Renaissance Offshore, operates entirely on the Gulf shelf (map below). Renaissance is a significant shelf producer ranking 19th among all Gulf operators in both oil (791,572 bbls) and gas (1,335,009 mcf) production in 2025. Renaissance ranked 6th in oil production and 7th in gas production among companies that focus on the shelf.
A challenge for 1947 will be improving Renaissance’s compliance and safety record:
- In 2025, Renaissance was one of only four companies that operated more than 10 shelf platforms and had INC/facility inspection ratios >1.0.
- Renaissance has averaged 0.93 violations (INCs) per inspection since 1/1/2020, trailing only Cox legacy Array in INC frequency.
- In 2019, a worker fell to his death at the Renaissance Eugene Island 331 B platform. BSEE’s investigation found that Renaissance failed to maintain all of its walking and working surfaces in a safe condition, that supervisors failed to promptly correct or prevent employees from accessing the uncorrected and uncontrolled walking and working surface hazard area, and that Renaissance and its contractors failed to follow the agreed upon terms and conditions within their respective Safety and Environmental Management Systems (SEMS) bridging arrangements. (Renaissance incurred a seemingly modest $105,292 civil penalty for this incident. There is no public information on any settlement with the victim’s family.)
“Between 2012 and 2014 Renaissance grew substantially with the acquisition of sixteen Gulf of Mexico producing fields, fifteen of which are operated and most are 100% owned.” 1947’s financial strength is unclear. Hopefully, BOEM will verify that satisfactory decommissioning financial assurance arrangements are in place before any lease assignments are approved.
Posted in Gulf of Mexico, Offshore Energy - General, Regulation | Tagged 1947, BOEM, BSEE, compliance, Eugene Island 331, fatality, Gulf of America, oil and gas companies, Renaissance Offshore, safety, shelf production | Leave a Comment »
California Superior Court Judge Donna Geck denies Sable’s motion to lift the preliminary injunction.
(1) For the reasons set forth herein, the motion of real parties in interest Sable Offshore Corp. and Pacific Pipeline Company to dissolve or modify the preliminary injunction issued in this case is denied.
(2) The application of petitioners for issuance of an order to show cause why real parties should not be found in contempt and to enter additional orders is continued to May 22, 2026.
The Judge concluded:
- The court is mindful that there are many moving judicial and administrative parts relating to the restart of the Las Flores Pipelines. (understatement of the year candidate? 😉)
- Sable has not persuaded the court that the DPA (Defense Production Act) Order renders compliance with Federal Consent Decree unnecessary.
- The Federal Consent Decree requires approvals from the OSFM (Office of the State Fire Marshal), which in turn must comply with state procedures in granting such approvals.
- Sable has not met its burden to show that the preliminary injunction should be dissolved or modified. Sable’s motion will therefore be denied.
On May 22, Judge Geck will consider whether Sable should be held in contempt for not complying with the preliminary injunction.
If you haven’t been keeping up 😉:
- Subsequent to Judge Geck’s preliminary injunction, the Pipeline and Hazardous Materials Safety Administration (PHMSA – a simpler agency name is long overdue!) asserted that the Las Flores Pipelines constitute an interstate pipeline subject to PHMSA’s exclusive jurisdiction.
- PHMSA issued their own approvals and an emergency special permit.
- The PHMSA approvals are the subject of proceedings in the Ninth Circuit Court of Appeals, which has not issued a final ruling.
Undaunted, Sable reports (4/20/2026):
- The 40 wells currently online at Platform Harmony and Platform Heritage are producing an average of 750 gross barrels of oil per day per well. Once all 74 production wells on these two platforms are online, Sable expects the average production per well to be approximately 700 gross barrels of oil per day.
- Sable expects Platform Hondo to come online in June 2026 with an estimated fully ramped production rate of approximately 10,000 gross barrels of oil per day.
Hence, Sable production is estimated to reach ~60,000 bopd in June, which is about 6 times total California OCS production prior to the Sable restart!
Posted in California, energy policy, Offshore Energy - General, pipelines, Regulation | Tagged consent decree, DPA, injunction, Judge Geck, Las Flores Pipeline, OSFM, PHMSA, Sable Offshore, Santa Barbara, Santa Ynez Unit | Leave a Comment »
Jason’s message, pasted in full below, is important for all who are associated with offshore oil and gas operations, in the US and internationally.
Be The Difference
On the Outer Continental Shelf, BSEE (or MMA) annually oversees ~70 million manhours of offshore personnel, production of >650 million barrels oil, and activities on ~1300 platforms and 75-90 rig / rig units. We all have a profound respect for the men and women who work offshore and put their lives on hold for 14-28 days to deliver much needed OCS production to meet the US demand, and that could not be clearer today.
Last month, Lou Holtz, a legendary coach and person passed away, and it reminded me of the rules of life he lived by and often promoted to others – 1) Do the right thing, 2) Do the best you can, and 3) Always show people you care.
Since February, BSEE has lost two great engineers, Tom Meyer and Bobby Nelson, who were both men of conviction. Tom and Bobby made a difference in all of us as they constantly worked with integrity, moral clarity, and high standards, choosing to act based on principles rather than preference or ease. While at BSEE, I have no doubt both of these men acted from internal motivation to adhere to their principles, not based on external applause or convenience. During their careers, both Tom and Bobby personified Lou Holtz’s rules of life.
Sixteen years ago, to this day, a phone call took place from the Deepwater Horizon to BP’s onshore office. The phone call discussed the anomalies encountered in the negative pressure test, and it was between the Well Site Leader and the lead drilling engineer. BP drilling engineer, Mark Hafle, allowed the temporary abandonment operations on the Deepwater Horizon to proceed even though he told Donald Vidrine, the Deepwater Horizon well site leader, that “you can’t have pressure on the drill pipe and zero pressure on the kill line in a [negative] test that is properly lined up.” Furthermore, Hafle did nothing to investigate or resolve the pressure differential issue even though he remained in BP’s office until 10:00 p.m. the evening of April 20 and had access to real‐time well data (which he logged out of at 5:27:35 p.m.). Hafle’s failure to investigate or resolve the negative test anomalies noted by Vidrine was a possible contributing cause of the kick detection failure that resulted in the Macondo blowout and 11 fatalities (Jason Anderson, Aaron Burkeen, Donald Clark, Stephen Curtis, Gordon Jones, Wyatt Kemp, Karl Kleppinger, Jr., Blair Manuel, Dewey Revette, Shane Roshto, Adam Weise).
Every day your actions, no matter how small, have a profound impact on others at the platform, in the company, and in industry. If you know something is not right, something is not possible, or even if you have doubt, consider being the difference.
For the remainder of the year, I challenge all of us, as regulators, to urge individuals on our teams to use their personal strengths to influence change rather than waiting for others to take initiative – including yourself. Also, promote the idea that one does not have to follow the crowd and can take a unique, personal stance to improve the offshore workplace. Be the difference just like Tom and Bobby.
Be The Difference and do whatever it takes to ensure the people offshore return from work the same way they arrived.
Respectfully,
Jason P. Mathews
Petroleum Engineer
Field Operations – OSM
Posted in accidents, Gulf of Mexico, Offshore Energy - General, Regulation | Tagged Be the Difference, BSEE, Deepwater Horizon, Jason Mathews, macondo, offshore safety | Leave a Comment »
I am again sharing this touching tribute to the 11 men who lost their lives on the Deepwater Horizon on April 20, 2010. The video is introduced by country singer Trace Atkins, a former Gulf of Mexico rig worker. The video and Trace’s song serve as a memorial to the 11 Deepwater Horizon workers and others who have died exploring for and producing oil and gas around the world. Please take a moment to watch.
Macondo revisited series:
- Part 1: Tribute to the 11
- Part 2: Background Information & pre-Macondo BP
- Part 3: The delayed cementing standard
- Part 4: What might have been
- Part 5: Did the National Incident Command unnecessarily prolong the blowout?
- Part 6: The shameful prosecution of BP Well Site leaders Vidrine and Kaluza
Reiterating this proposal: Make April 20th International Offshore Safety Day to honor those who have been killed or injured, to recognize the many workers who provide energy for our economies and way of life, and to encourage safety leadership by all offshore operators, contractors, and service companies.
Posted in accidents, Gulf of Mexico, well control incidents | Tagged 11 men died, 16 years ago, blowout, Bob Kaluza, bp, cementing standard, Deepwater Horizon, Don Vidrine, macondo, Trace Atkins, transocean | Leave a Comment »
The Constance Gee letter (pasted below) is entertaining no matter where you stand on the Vineyard Wind debacle. A couple of quotes 😉:
It’s been a mess from the beginning and in a mess it will end, but the current “he said she said” over who owes more millions to whom is especially trashy.
Poor Vineyard Wind doesn’t have a clue how to service and maintain the 62 turbines they’ve hammered into the seabed 15 miles off our coast, and they are upset that GE Renewables won’t hand over the troubleshooting manual.
The Vineyard Wind Court filing is accessible here.
Posted in energy policy, Offshore Wind | Tagged Constance Gee, litigation, Vineyard Wind, wind farm graveyard | 2 Comments »
The first public comments on BOEM’s proposed revisions to the decommissioning financial assurance requirements have been posted. A good comment letter (attached) was submitted by natural resource management students at the University of Arizona. The students oppose the proposed revisions. Among their concerns (additional thoughts added in parentheses):
- Increased environmental risks. (Accidents, hurricanes, and other events may introduce decommissioning risks that require both immediate and longer term attention and financial resources. Such incidents typically increase decommissioning costs by orders of magnitude, and can even bankrupt financially sound companies. See “Sad End for Taylor Energy.”)
- Firms with lower credit ratings would no longer have to hold as much capital in reserve and would have a lower bar of entry into projects. (See comments by John Smith.)
- The possibility of cascading economic impacts in the event that bankruptcy does occur. (Which predecessors will be affected and how? What about contractors? How long will bankruptcy litigation delay resolution of claims? Will bankruptcy court asset sales increase public financial, safety, and environmental risks?)
- Taxpayers would be facing a portion of the risk. (Predecessors are only accountable for the facilities they installed, so holding predecessors liable doesn’t free the taxpayers from all financial risks.)
- The entire energy sector faces increased risks when operating companies fail. (Prominent failures damage the reputation of the industry and the OCS program, with implications for the economy and national security.)
Before relaxing financial assurance requirements, BOEM should consider the role that lax lease assignment and financial assurance policies had in the growth of Fieldwood, Cox, Signal Hill, Black Elk, and other failed companies.
Posted in decommissioning, Offshore Energy - General, Regulation | Tagged Black Elk, BOEM, Cox Operating, decommissioning, environmental risks, Fieldwood, financial assurance, natural resource management, regulations, Signal Hill, taxpayer risks, Univ. of Arizona | Leave a Comment »
The Case for Reefing California Platforms by John Smith
Environmental groups like the Environmental Defense Center and Get Oil Out continue to oppose converting the jackets of California oil and gas platforms to artificial reefs despite scientific studies (Claisse et al. 2014) showing “oil and gas platforms off the coast of California have the highest secondary fish production per unit area of seafloor of any marine habitat that
has been studied.”
Another important factor environmental groups and the 2023 BOEM Programmatic EIS for Decommissioning failed to consider and acknowledge is the huge amount of air emissions that would be released by world-class heavy lift vessels like the Thialf or Balder Semi-submersible Crane Vessels (SSCVs) that would be required to safely and efficiently remove the large federal OCS platforms like Harvest, Hermosa, and Hidalgo (HHH). The HHH platforms are in waters depths ranging from 430-675 feet and have combined deck and jacket weights ranging from 20,000 – 25,000 tons. In comparison, the wrought iron structure of the Eiffel Tower weighs about 8,000 tons.
The SSCVs and accompanying Anchor Handling Tugs (AHTs) used to remove the HHH platforms will likely to be mobilized from distant locations like the North Sea or Gulf of America where they typically operate. Because SSCVs like the Thialf and Balder are too large to enter the Panama Canal, this would involve a 20,000 nautical mile roundtrip voyage around the tip of South America.
Three to four campaigns, and separate SSCV and AHT mobilizations and demobilizations, are projected to be required to fully remove the HHH platforms because the challenging oceanographic conditions offshore Point Arguello restrict heavy lift operations to a 150-day period between May and October.
Four campaigns by the SSCV and AHT would consume about 300,000 metric tons (mt) of marine diesel oil and release approximately 470,000 mt of CO2 and 11,000 mt of NOX emissions. To put these numbers into context, 470,000 mt of CO2 and 11,000 mt of NOX are:
- the amount of CO2 emissions released by providing electrical power to 97,600 homes annually (the city of Santa Barbara has about 38,000 housing units).
- the amount of CO2 emissions released by burning 1.1 million barrels of oil.
- the amount of CO2 emissions released by 102,000 gasoline burning cars annually.
- the amount of NOX emissions released by four large oil or coal-fired power plants annually.
- the total annual NOX emissions in Santa Barbara County.
And this is only the emissions released during mobilization and demobilization of the SSCV and AHT. If full removal is required, an additional 50 days of operational time by the SSCV and AHT is estimated to be required to remove the topside and jacket of each HHH platform. This could be reduced to about 15 days per platform if the jackets are converted to artificial reefs. Only one SSCV and AHT campaign may be required if the HHH jackets are reefed, compared to the four campaigns required for the full removal scenario. This would result in a 75 percent reduction in CO2 and NOX emissions.
Posted in California, climate, decommissioning, energy policy, Offshore Energy - General, Regulation | Tagged air emissions, BOEM, California, decommissioning, HHS platforms, John B Smith, offshore platforms, reef effect | Leave a Comment »
Excerpt from p.3 of Vineyard Wind’s suit against GE Renewables (attached):
“As was widely reported in national and local news, in July 2024, one of the GER offshore blades collapsed and fell into the waters off Nantucket, necessitating a massive environmental cleanup, and a six-month construction hiatus during which GER performed a “root cause” analysis. That analysis concluded that 68 of the 72 GER blades installed at the Project (nearly all manufactured by GER in Gaspé, Canada) were also defective because they were inadequately bonded together, and were so poorly made that they were beyond repair. GER’s remediation plan required it to remove all of the blades and to replace all Gaspé blades with others manufactured at a different facility in Cherbourg, France.
Regulatory issues of concern:
- Nearly 2 years after the blade failure, all Vineyard Wind (VW) turbine blades have been installed, yet BSEE has still not issued their investigation report. The primary purpose of independent Federal investigations is to prevent recurrences at this or other projects in the US and worldwide. The investigation should assess the extraordinary VW blade defect rate.
- A global assessment of turbine blade failures should be considered. These failures are far too common.
- DNV was the Certified Verification Agent (CVA) for the VW project, and was thus required to verify the design, fabrication, and installation procedures. When will we hear from them?
- BOEM waived the requirement that the Facility Design Report (FDR) and Fabrication and Installation Report (FIR) be “received and offered no objections to” before beginning the fabrication of facilities. They did so to “allow Vineyard Wind to adhere to its construction schedule, maintain its qualification for the Federal Investment Tax Credit, and meet its contractual obligations under the Power Purchase Agreements with Massachusetts distribution companies.” Did BOEM’s commitment to promoting offshore wind and accelerating development influence their regulatory decisions?
- Dr. Edgar Gunter, founder of the University of Virginia’s Rotor Dynamics Lab, suggested the cause of the Vineyard Wind blade failure was not a material bonding problem, but rather “a classical torsional fatigue failure of the blade at the base.” Is there any merit to this assertion?
- Is the fragmented turbine blade symbolic of the regulatory regime?
Posted in accidents, Offshore Wind, Regulation | Tagged blade defects, BOEM, BSEE, CVA, DNV, Dr. Edgar Gunter, fabrication, GE Vernova, investigation report, litigation, regulatory fragmentation, Vineyard Wind, waivers | 1 Comment »
John Smith‘s excellent comments on the BOE post about the proposed revisions to decommissioning financial assurance regulations warrant a separate post. John’s comments are pasted below.
It’s clear the proposed rules have been designed to reduce financial burdens on OCS oil and gas operators, especially small independents. The proposed rules do this by:
- Waiving the requirement of the operator/lessees to obtain supplemental financial assurance to cover decommissioning obligations if jointly and severally liable predecessors are determined to have the financial capability to cover the obligations.
- Lowering the credit rating threshold BOEM uses for evaluating the financial health lessees and grantees from BBB- to BB- from S&P Global Ratings (S&P) or Baa3 to Ba3 from Moody’s Investor Service Inc.
- Revising the level of BSEE probabilistic estimates of decommissioning cost used for determining the amount of supplemental financial assurance required from P70 to P50.
I don’t see any rationale for lowering the credit rating threshold, which would apply to both current and predecessor lessees. A BB- and a Ba3 rating is considered “non-investment grade” or “junk,” meaning the company is more vulnerable to adverse economic conditions, such as a downturn in oil and gas prices. Current market estimates place the 3-year probability of default for a BB- rating at approximately 12.5% to 13%. Lowering the credit rating significantly increases the risks of default by lessees and transfers the risk to the federal government and taxpayers.
Reducing the BSEE probabilistic criteria for determining the amount of supplemental financial insurance required from P70 to P50 means there is a 50% chance BSEE cost estimates for decommissioning are underestimated further increasing risks borne by the federal government and taxpayer.
BOEM should reverse course and maintain the current credit rating threshold (BBB- and Baa3) and the P70 criteria.
Posted in decommissioning, Offshore Energy - General, Regulation | Tagged BOEM, decommissioning, financial assurance, higher default risk, John B Smith, lower amount, lower credit rating, predecessor liability, proposed regulations | Leave a Comment »
Bud's Offshore Energy (BOE) 