I believe the OOC is the world’s oldest trade association for the offshore oil and gas industry. The OOC was formed in 1948, five years before the enactment of the OCS Lands Act and just one year after the first Gulf of Mexico well was completed out of sight of land.

For much of their history, OOC had just a single, part-time employee. The organization has matured, but still operates in the same efficient manner, relying on subject matter experts from their member companies. Since the days of the OCS Orders, the OOC has consistently provided informed comments on operating regulations. As a regulator, I had issues with some of their comments over the years, but the dialogue was (almost😉) always polite and professional.

Congratulations to the OOC for the support they have provided for US offshore energy! Although many have had important roles, these former OOC representatives come immediately to mind for their contributions to offshore safety: John Rullman, Steve Brooks, Mark Witten, Sandi Fury, Dave Wisch, Ken Arnold, Charlie Williams, Phil Smith, Peter Velez, Allen Verret, Wanda Parker, Cort Cooper, Charlie Duhon, Jodie Connor, Craig Castille, Susan Hathcock, and Pat O’Connor. Many of these retired safety leaders, and current OOC Executive Director Evan Zimmerman, were recipients of MMS Offshore Leadership Awards.

Just as I was lamenting the absence of scientific surveying in the Atlantic, my former colleague Renee Orr brought this NOAA announcement to my attention. Researchers from the University of Texas Institute of Geophysics and Lamont-Doherty Earth Observatory, with funding from the National Science Foundation, propose to conduct seismic surveys in the Blake Plateau area of the South Atlantic (map below).

The proposed study would acquire two-dimensional (2-D) seismic reflection and seismic refraction data to examine the structure and evolution of the rifted margins of the southeastern United States, including the rift dynamics during the formation of the Carolina Trough and Blake Plateau.

The survey will lead to a better understanding of “the interaction between tectonic and magmatic processes that led to continental breakup and the onset of seafloor spreading in the central Atlantic Ocean 200 million years ago.” The investigators are particularly interested in the “stratigraphy of sediments that formed during and after rifting, the degree of crustal stretching at the continental margins, crustal faults that formed during extension of the margin, and the geometry of lava flows that were placed on the crust before the start of seafloor spreading.”

While not a primary purpose, the research should improve our understanding of the relationship between productive oil and gas fields offshore Africa and US analogs. Paul Post and his BOEM team estimated that the US Atlantic could contain >20 billion BOE (link to the latest report).

NOAA has conducted a detailed review of the proposal and made a “preliminary determination that the impacts resulting from this activity are not expected to adversely affect any of the species or stocks through effects on annual rates of recruitment or survival.”

Rick was one of the first Americans on Utah Beach during the D-Day invasion, helped to protect the endangered American Bald Eagle, and was an offshore energy (green hydrogen) pioneer. More about Rick.

The Supreme Court has decided to allow the 9th Circuit decision on offshore well stimulation to stand.

From a regulatory and technical standpoint, the 9th Circuit decision is highly questionable. The limited well stimulation operations offshore California were conducted 9-31 years ago and were carefully reviewed and monitored. No fluids were released or escaped to the marine environment.

During the Obama administration (and under the capable leadership of Directors Brian Salerno and Abigail Ross Hopper), BSEE and BOEM conducted a Programmatic Environmental Assessment (EA) and issued a Finding of No Significant Impact (FONSI) from the use of specific well stimulation treatments in oil and gas activities on the Pacific OCS. The 9th Circuit decided that wasn’t enough and the SCOTUS chose not to review their decision.

Given the current state of Pacific offshore operations, the court decisions will have little or no effect on well activity now or in the foreseeable future. If the BSEE well permitting site is up-to-date, there have been no Pacific well operations in the past 3 years. For the 2 years prior to that, the only well operations were for plugging and abandonment purposes. Therefore, the main concerns are the decision to require an EIS prior to any future well stimulation operations, and perhaps more importantly, the implications of the decision on offshore operations elsewhere.

In the attached paper, John Smith and Robert Byrd summarize the daunting decommissioning challenges facing California offshore operators:

  1. Large, deep-water structures.
  2. Lack of decommissioning infrastructure and services locally.
  3. High HLV mobilization costs.
  4. Jones Act restrictions.
  5. Limited onshore processing and disposal options.
  6. Air quality compliance costs.
  7. Site clearance and debris removal requirements.
  8. Environmental and space use operating constraints.
  9. A complex regulatory framework and risk of litigation.
  10. An unworkable reefing law and lack of a State approved artificial reefing program.

Does the regulatory framework prevent you from doing what the regulations require? Catch-22?

All we know at this point is that a Woodside contractor died during work activities at noon today (AWST).

The North Rankin complex is in 135 km offshore from Dampier on the northwest coast of Australia and is in 125 m of water.

More to follow.

North Rankin complex

This CBC story, which includes excellent video interviews, was brought to my attention by Newfoundlander Howard Pike, an engineer and offshore safety leader.

Rigs-to-Removal (carbon)?

We know a lot about Rigs-to-Reefs, and the importance of active and reefed platforms in providing the habitat, shelter, and food that is necessary to increase biodiversity and productivity. However, the carbon reduction potential of artificial reefs has received little attention.

The linked CBC story is particularly interesting in that it includes interviews with artificial reef researchers who are assessing the carbon capture aspects. To date the results are encouraging:

As for the impact on climate change, the researchers say they have found some evidence that an artificial reef could hold more carbon compared to a natural reef.

Platform Houchin

For those who have been following the saga of Platforms Hogan and Houchin, decommissioning specialist John B. Smith brought this update to my attention:

Platforms Hogan and Houchin: These platforms are currently being manned, monitored and maintained as part of an agreement between BSEE, BOEM, DOI Solicitors Office, and the three predecessor lessees as they await a decision on the predecessors’ appeal to the IBLA. BSEE estimates an approximately $5 million deficit in financial assurance to decommission 21 orphaned sidetrack wells associated with these platforms.



  • Although the status of the decommissioning account for these platforms has not been disclosed, permanently abandoning these 21 wells will be costly. if the over/under is an additional $5 million, bet on the over.
  • After the wells are plugged, the platforms have to be removed at great cost to someone (hopefully not the taxpayer), and when will the matter of who pays finally be resolved?
  • BSEE estimated decommissioning costs of $74.3 million in 2014. What are the current estimates?
  • When will the 9/20/2020 Inspector General report that found significant irregularities in the use of the decommissioning escrow funds be made publicly available?

BOEM has accepted 76 of the Sale 259 bids to date including 18 of the 29 legitimate (non-CCS) bids for shelf leases.

Interestingly, none of Exxon’s 69 high bids for shelf leases have been accepted to date. Given that the Exxon bids were for tracts that are presumably considered “nonviable” from an oil and gas production standpoint, those bids should have been accepted by now were they deemed to be valid.

Perhaps BOEM, to their credit, is planning to reject the CCS bids as they may when an unusual bidding pattern has been identified. It is now quire clear (unlike in the immediate aftermath of Sale 257) that Exxon was seeking to acquire these leases for carbon sequestration purposes. That is not allowed given that both Sales 257 and 259 were oil and gas lease sales. As similarly noted for Sale 257:

  • Sale 259 was an oil and gas lease sale. The Notice of Sale said nothing about carbon sequestration and did not offer the opportunity to acquire leases for that purpose. Therefore, the public notice requirements for CCS leasing (30 CFR § 556.308) were not fulfilled.
  • Because there was no draft or final Notice of Sale for CCS leases, interested parties and the public did not have the opportunity to consider and comment on CCS leasing, tract exclusions, bidding parameters, and other factors.
  • 30 CFR § 556.308 requires publication of a lease form. No CCS lease form was posted or published for comment.
  • CCS operations were not considered in the environmental assessments conducted prior to the sale.
  • No evaluation criteria for CCS bids have been published.

Meanwhile, the decision on Green Canyon Block 777 will also be of interest, given that a higher Sale 257 bid for this block was rejected.

Finally, there was a second bid (red block below) from Focus Exploration for one of the blocks Exxon bid on (blue). Will that lower bid, which was presumably for oil and gas exploration purposes, be accepted if the Exxon bids are rejected?