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A New York Times article suggests that the consolidation of BOEM and BSEE into the Marine Minerals Administration will weaken environmental oversight. It will not. On the contrary, regulation is likely to be strengthened as resources shift from inter-bureau coordination and redundancy management to the primary safety and environmental protection missions.

I recommended a BOEM-BSEE merger in the comments I submitted to DOI last July. No doubt others have made similar recommendations. Nonetheless, I was surprised when the consolidation was announced and quickly expressed my support for the decision.

Given the challenges associated with Federal reorganizations, agency heads often opt for the status quo. I’m pleased that the current DOI leadership team, with whom I disagree on some issues, chose to merge the bureaus.

Quotes from the NYT article followed by my comments:

NYT: The Trump administration is creating a new office that critics say could weaken the environmental oversight of oil drilling and seabed mining in territorial waters.

Comment: The functional overlap and associated uncertainty that permeates the offshore regulatory regime is a weakness, not a strength. Virtually every element of the regulatory program requires coordination between the two bureaus. This includes plan and permit approvals, decommissioning and financial assurance, spill response plans, lease stipulations, assignments, pipeline regulation, environmental reviews, enforcement actions, and geologic data collection and review. Note the list of MOUs that are intended to coordinate BOEM and BSEE redundancy. The documents often do more to confuse than clarify. For example, see the MOU entitled “Environmental and NEPA.”

Multi-bureau organizational complexity is not in the best interest of safety and environmental protection. Overlapping responsibilities, coordination challenges, and “turf” issues distract the technical staff from their important risk management duties, the work they are good at and enjoy doing. BSEE and BOEM should be overseeing the offshore industry, not each other.

NYT: The new agency, the Marine Minerals Administration, will be formed by reunifying two offices that had been split up after the 2010 Deepwater Horizon oil spill in an effort to increase environmental oversight of the energy industry and prevent future oil disasters. After the split, the Interior Department’s oil-leasing activities were separated from environmental regulation and financial management. (emphasis added)

Comment: The assertion that the leasing and environmental regulation were separated is false. The leasing bureau (BOEM) was assigned lead responsibility for the review and approval of the fundamental operational planning documents – Exploration Plans, Development and Production Plans, and Development Operations Coordination Documents. This includes the environmental reviews pursuant to NEPA.

NYT: The move is “worrisome because it has the potential of bringing things back where they were, where there was this inherent conflict of interest between promotion of offshore oil and gas, and oversight safety,” according to Donald Boesch, emeritus professor at the University of Maryland Center for Environmental Science.

Comment: None of the investigations of Macondo provided evidence that conflicts of interest contributed to the blowout. On the contrary, the Chief Counsel for the National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling, reported as follows (page 261):

In recent years various bodies have concluded that certain MMS offices and programs have violated ethical rules or guidelines. In the wake of the Deepwater Horizon disaster, some questioned whether ethical lapses played any role in causing the blowout. The Chief Counsel‘s team found no evidence of any such lapses.

Also, keep in mind that prior to the Macondo blowout, 25,000 wells had been drilled in US Federal waters over the previous 25 years without a single well control fatality, an offshore safety record that is unprecedented in the U.S. and internationally. 

For some reason, the NYT did not mention the offshore wind program. Perhaps the NYT should have looked at the relationship between the offshore wind industry and BOEM, most notably the decommissioning financial assurance and fabrication and installation report waivers.

NYT: The new bureau will also take on oversight of the Trump administration’s plans to lease waters in U.S. territories to deep-sea mining companies. The first of these sales, according to the spokeswoman for the Interior Department, are likely to happen next year.

Comment: DOI’s marine minerals program is decades old and is a priority for the current administration. Reorganization should not affect the MMA’s capability to oversee these activities.

From the BBC: Three stowaway baby rabbits have been rescued after being discovered on a drilling rig in the North Sea.

The unexpected visitors were shipped from Aberdeen to the Valaris Norway, about 93 miles (150km) off the coast of Lincolnshire. It is believed they hopped into a container in Dundee, which was taken by road to Aberdeen, before travelling on the offshore ship Aquarius to Ithaca Energy’s Cygnus field.

Rigs-to-Rabbits will be a nice addition to our Rigs-to-Reefs list.😉

EIA estimates that China added an average of 1.1 million barrels per day of crude to their strategic inventories in 2025. Wow! If accurate, that’s a massive SPR operation – equivalent to storing ~60% of the total daily oil production in the Gulf of America or offshore Norway! See the video at the bottom of this post.

How much of that oil was imported from Iran?

Meanwhile, US weekly SPR withdrawals have exceeded 4 million barrels over the past two weeks. Presumably that pace will continue consistent with the DOE announcement.

dateUS SPR: bbls (1000s)
3/6415,422
3/13415,422
3/20415,442
3/27415,064
4/3413,325
4/10409,181
4/17405,045

The big picture – US SPR:

Looking up towards Platform Gilda from a depth of 100 feet, juvenile bocaccio rockfish swirl around the anemone-covered crossbeams (photo by Dr. Milton Love) 

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.

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.

Renaissance operations being acquired by 1947 Oil and Gas

California Superior Court Judge Donna Geck denies Sable’s motion to lift the preliminary injunction.

Judge Geck’s ruling

(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!

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

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:

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.

Deepwater Horizon Memorial, New Orleans

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.

Decommissioning financial assurance regulations are instrumental in ensuring both environmental and fiscal responsibility.“- .natural resource management students

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.