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As posted on 9/10/2025 (prior to PHMSA’s assertion of jurisdiction): Given that the Sable pipeline will carry OCS production, it would seem to fundamentally be an interstate line (Federal jurisdiction), as it was when owned by Plains. Could DOT reverse the 2016 letter agreement? That is conjecture for the attorneys and courts to consider.

A new Bloomberg Law article explains PHMSA’s position after a challenge by the California AG:

PHMSA said state-based hurdles are preempted by federal authorizations in the emergency permit notice letter the agency sent to Sable last year. Because the pipeline originates on the Outer Continental Shelf, the system automatically comes under federal oversight, the agency said.

A law professor adds the following:

The administration is invoking interstate commerce to classify the pipeline as a federal issue, “arguing that this is between a place in a state and outside that state,” said Hannah Wiseman, a professor at the Penn State Dickinson Law.

They are claiming this under their interpretational authority, as opposed to the actual language of the Pipeline Safety Act,” she said.

The language of the law only assigns PHMSA jurisdiction over oil operations that run outside or between state lines, but here the agency is arguing the pipeline’s start point is on the OCS, not at the onshore processing facility, she said.

Not mentioned in the article but pertinent:

  • In PHMSA’s favor, the onshore pipeline was initially under their jurisdiction.
  • In California’s favor, a court approved Consent Decree clearly identifies the California Fire Marshal as the sole oversight authority.

Meanwhile, Kruti Shah cleverly summarizes the Santa Ynez Unit story in a series of posts on X. Click on the post below to get the full thread. Great read for Sable/SYU followers:

Important and long overdue:

Thirty years ago, when industry majors shied away from exploration offshore Israel, Noble Energy (then Samedan) boldly stepped forward and partnered with the Delek Group to explore the Eastern Mediterranean.

Exploration success was accompanied by national security, legal, and regulatory challenges. Nonetheless, Israel’s gas production has grown rapidly and is expected to exceed 3 bcf/day in 2026, which is > current gas production in the Gulf of America.

Chevron is now the main operator in Israel, having purchased Noble’s assets in 2020. The company has taken another major step by signing an MOU with Syrian Petroleum Co. and Qatar-based Power International Holding. The document is not currently accessible online, but appears to be substantive based on press reports.

The agreement focuses on preliminary cooperation for exploring and developing offshore oil and gas resources offshore Syria. It’s noteworthy that the MOU will only remain in effect for two months, after which “formal contracts and operational work are expected to follow.”

Having done some work for Noble Energy in the 2010s, I’m very impressed by the progress that has been made given the geopolitical challenges.

Production at Chevron’s Leviathan, a giant gas field offshore Israel

The EIA’s Eastern Mediterranean overview is attached.

This video reports on the United Oil and Gas geochemical exploration program. At the 3 minute mark, Jamaican Energy Minister Daryl Vaz does a good job of expressing optimism about Jamaica’s prospects while downplaying expectations and warning about uninformed rumors.

More difficult to understand is why the Jamaican govt granted 3 license extensions to a company that doesn’t have the financial strength to drill an exploratory well. Would it not have made more sense for the govt to deal directly with stronger companies that want full ownership, not just a share?

In Jamaica’s defense, there may be good reasons for extending United. However, as reported by the Jamaica Observer, United’s financial condition must be a concern:

“The company is also operating under financial constraints. It currently has no producing assets and remains reliant on equity raises and a successful farm-out to fund future activity, according to its latest annual report. That reality makes low-cost, high-information work programmes particularly important.”

Jarrod Agen is Deputy Assistant to the President and Executive Director, National Energy Dominance Council. A question about Sable Offshore’s Santa Ynez Unit project was raised at a Foundation for Defense of Democracies (FDD) event on “The State of American Energy Dominance.” See the Bloomberg blurb and X post below. The full event video is here.

Superhot geothermal is exciting because of the unlimited potential, universal availability, Star Wars drilling technology, and the dynamics of supercritical fluids.

There are still hurdles to clear, and commercial power generation is 5+ years away, but the promise is tantalizing.

Gyroton millimeter wave drilling technology

On February 12, 2024, the bankruptcy court approved the sale of certain Cox Operating assets to Natural Resources Worldwide LLC (NRW), a company that had no prior offshore experience. NRW contracted with Array Petroleum to operate 154 Cox legacy platforms (per BOEM data). NRW is listed as the operator of just one platform.

In 2025, NRW/Array operations accounted for 486 incidents of non-compliance (INCs), 36.2% of the Gulf of America total. Array and NRW had INC/facility inspection rates of 2.1 and 7.0 respectively, well above the Gulf average of 0.42 and the top performers’ rates of 0.05 to 0.13.

In Array’s defense, their violations declined sharply in the second half of 2025. However, the number of inspections of their facilities declined even more sharply, so the INCs/facility inspection ratio actually increased in the second half.

For the 2025 data in the table below:W=warning, CSI=component shut-in, FSI=facility shut-in. The 3 numbers for Array in each box are full year 2025 data (top), first half 2025 (middle), and second half 2025 (bottom)

operatorWCSI
FSI
total INCs
Facility
Insp.
INCs/isp
Array352
311
41
93
46
47
6
6
0
451
363
88
218
184
34
2.1
2.0
2.6
NRW102413557.0

Three other companies had more than 10 shelf platforms and INC/facility inspection ratios >1.0: Greyhound Energy (23 platforms), Renaissance (21 platforms) and Sanare Energy (38 platforms).

operatorWCSIFSItotal INCs
facility insp
INCs/
fac.
insp
Greyhound Energy321033231.4
Renaissance Offshore2619347441.1
Sanare Energy6020282751.1

The table below provides 2025 oil and gas production through Oct (with Gulf of America rank) for the 5 companies mentioned in this post. In determining rankings, subsidiaries and affiliates were counted as a single company (e.g. Chevron, Unocal, and Hess counted as one company).

oil (bbls)oil rankgas (MCF)gas rank
Renaissance729,904191,220,43319
Array416,267211,197,91520
Sanare246,845251,763,55218
Greyhound182,65827280,42326
NRW101,11029104,02530
Tracts receiving bids in Sale BBG1

To date,BOEM has deemed 96 of the 181 BBG1 high bids to be acceptable. No high bids have been rejected. Although the sale was “beautiful but not big,” the bids were relatively strong on a per acre basis. The number of rejected bids may thus be quite low.

No bids were accepted during BBG1’s Phase 1 review. This means that none of the tracts receiving bids were determined to be nonviable as was the case for the 199 tracts that were improperly acquired for carbon disposal purposes in Sales 257, 259, and 261. (Unsurprisingly, neither of the acquiring companies has submitted an exploration plan for any of these CCS leases. The leases will likely expire without activity. Much to the dismay of the large and diverse group of opponents, the carbon disposal industry is focusing on onshore locations along the Gulf Coast.)

Meanwhile, a Cook Inlet lease sale is scheduled for March 4, and another Gulf of America sale will be held on March 11. Despite attractive terms, don’t expect either to be a banner “red jacket” lease sale. (See the John Rankin recognition below.)

More information on BOEM’s bid evaluation process.

Attached is John Smith’s updated Sable litigation table. John is a BOEM retiree who has been closely monitoring Sable’s legal and regulatory challenges. His summary:

“Sable Offshore Corp. is involved either directly or indirectly in no less than 12 lawsuits that have been filed by environmental groups, state and county regulatory agencies, and the Attorney General of California, all of whom are committed to stopping Sable from restarting Santa Ynez Unit (SYU) oil and gas production. All of the lawsuits are active and many are likely to result in prolonged judicial proceedings extending over several years. Will Sable have the will and financial resources to continue these legal battles indefinitely? – that’s a multi-million dollar question.”

Was 2025 the Gulf’s highest ever production year? We’ll find out in 3 weeks when EIA posts the December 2025 data.

November production dipped a bit putting the production record in doubt. December production had to average 1.993 million bopd to match 2019.

There are also typically small revisions for the prior two months, which could affect the outcome. It will be a nail-biter! 😉

Top 3 oil production years for Federal waters in the Gulf:

Top 3 Yearsave. daily production (1000’s of barrels)
20191898
2025 (through November)1889
20231864