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The attached letter to the General Accountability Office (GAO) asserts that there were “deeply entrenched ethical issues and conflicts of interest within the former Minerals Management Service (MMS),” and implies that these issues were among the factors contributing to the tragic Macondo well blowout.

I retired from MMS shortly before the Macondo well blew out on April 20, 2020, and testified before the Senate Energy and Natural Resources Committee on May 11, 2010. My comments on MMS employee ethics still stand and are reiterated below:

I also want to express my disappointment in certain media comments directed at my former MMS colleagues. These comments have not only been ill-informed and unsubstantiated, but malicious. Without hesitation, I can tell you that MMS regulatory personnel–inspectors, engineers, scientists, and others–are 100% committed to their safety and pollution prevention mission. MMS inspectors are themselves exposed to risks every day when they fly offshore and inspect facilities. MMS personnel have repeatedly made personal sacrifices to support the regulatory mission. After Ivan, Katrina, Rita, Gustav, and Ike, MMS employees worked to restore oil and gas production essential to our economy, even when their personal lives had been disrupted by the onshore impacts of these hurricanes. These personnel work under strict ethics standards, and despite a few isolated and highly publicized incidents that occurred more than four years ago, conduct themselves with the highest degree of professionalism. While a critical review of the entire offshore regulatory regime is necessary and appropriate, unsubstantiated accusations and personal attacks are not.


The comprehensive Chief Counsel’s Report, National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling, was the only inquiry to consider whether ethical lapses were a contributing factor to the blowout. In the “Regulatory Observations” chapter, the Chief Counsel addressed ethics concerns directly (p. 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.

This blog closely followed the Macondo blowout. I have read all of the investigation reports and many of the court documents. I also served on the defense team for Bob Kaluza, the BP Well Site Leader who was fully acquitted after being shamefully prosecuted in the wake of the blowout. My thoughts on the Macondo tragedy are summarized in a six part series.

Because of the false ethics narrative and scapegoating of MMS, experts who should have been directing the well control efforts, were pushed to the back of the bus shortly after the blowout began. Had that not been the case, I believe the top kill operation would not have been aborted in late May and the well would have been killed 48 days sooner, reducing the oil spill volume by at least 2.4 million bbls. (See the analysis by Dr. Mayank Tyagi and his colleagues at LSU.) Also, keep in mind that the USCG Incident Commander almost required BP to resume flow from the well after the capping stack successfully shut-in the well on 7/15/2010, and would have likely done so were it not for forceful input from an engineer from the former MMS.

The consolidation of BOEM and BSEE into a single bureau makes sense. As I previously commented:

This is an excellent step that many OCS program veterans have been advocating. In addition to the inefficiencies associated with overlapping and intertwined BOEM and BSEE responsibilities, the associated regulatory fragmentation is a significant safety risk factor.

The primary OCS functions including leasing, resource evaluation, economic analysis, permitting, inspection and enforcement, investigations, environmental assessment, spill response preparedness, promulgation of regulations, technology assessment, research,and decommissioning, are inextricably linked, cannot be effectively segmented, and should not be stovepiped.

Finally, with regard to the reorganization planning questions posed at the end of the attached letter, perhaps GAO should first consider the abrupt, unplanned termination of MMS. At a 2011 Ministerial Forum in Washington, an international offshore safety expert criticized that rash decision noting – “It took 87 days to stop the blowout, but only 30 days to get rid of the regulator.”

On July 13, 2024, a Vineyard Wind (VW) turbine blade shattered and spread debris on Nantucket beaches and throughout the region.

In VW’s own words:

“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.

Unsurprisingly, VW has found their contractor GE Renewables to be solely responsible for this troubling incident. However, as lessee and operator VW bears ultimate responsibility for all lease activities including the work of contractors, project design and management, fabrication and installation oversight, selection of the certified verification agent, and incident response.

Meanwhile, the Federal ( BSEE) investigation report has still not been issued. That report should provide an independent assessment of concerns discussed on this blog including quality control, regulatory departuresdebris recovery, and environmental impacts. The investigation is significant, not only for VW, but for other offshore wind projects planned or under construction, in the US and worldwide.

Keep in mind that the lengthy and complex National Commission, BOEMRE, Chief Counsel, and NAE reports on the 2010 Macondo blowout were published 6 to 17 months after the well was shut-in.

United’s massive Walton-Morant license is the size of 896 Gulf of America lease blocks! That’s half the total number of active Gulf leases!

United O&G 2025 Financial Summary:

  • Loss after tax: ($1.25m) (2024: $2.44m loss)
  • Group cash balances at 31 December 2025: $1.7m (2024: $0.8m)

“The company currently has no revenue and is operating at an annual loss and shows a current net liability as at 31 December 2025. Its only funding options are through warrant exercises, a Jamaican farmout deal covering back and future work program costs, or equity financing.”

The company’s future is dependent on finding a partner to fund an exploratory well. In that regard, United’s optimism has yet to result in a farmout deal after years of trying. The discovery risks seem comparable to those of other prospective frontier wildcats. So why have they been unable to find a partner? Are their terms unreasonable?

This outsider continues to wonder why United has been granted multiple license extensions, the latest through 1/31/2008. Does the govt have that much confidence in a company that is dependent on finding a partner to fund an exploration well? Should the Govt of Jamaica have allowed the license to expire and negotiated directly with larger companies? Was the govt concerned about administrative or political constraints associated with re-offering the massive license area?

I have been following this story for 5 years, and am still hopeful for a positive outcome for Jamaica.

Lease sale Big Beautiful Gulf 3 (BBG3) will be held on 8/12/2026. The Final Notice of Sale is attached.

Given the rather tepid BBG1 and BBG2 results and the high sale frequency, robust bidding is not expected. Nonetheless, the BBG bidding patterns and tract evaluations have been interesting, most notably BOEM’s rejection of LLOG’s bid for Keathley Canyon 828, an expired lease block in the their Buckskin field.

Keathley Canyon 828 is not among the blocks listed for sale at BBG3. Per the Notice of Sale (p. 4), “any lease blocks whose high bids were rejected and not appealed in the immediately preceding Big Beautiful Gulf lease sale, are expected to be included as eligible for lease.” Can we therefore assume that either the KC 828 bid rejection or the prior lease expiration is being appealed?

The legislatively mandated BBG lease terms are attractive – 10 years and 12.5% royalty for deepwater blocks. A more recent legislative directive requires (wrongly in my opinion) the approval of downhole commingling requests. This accelerates the return on investments in deepwater, high pressure reservoirs. Such commingling has presumably contributed to record Gulf oil production in 2025. The longer term concern is the impact on ultimate oil and gas recovery.

Meanwhile, the Gulf rig count and well start numbers continue to disappoint. Baker Hughes (7/2/2026) lists only 4 active rigs in the deepwater Gulf – one each in the Alaminos and Mississippi Canyon areas and two in the Green Canyon Area. BSEE’s borehole file lists only 15 new deepwater exploratory well starts YTD.

Launch from the Ocean Odyssey, a semi-submersible drilling rig modified by the Sea Launch consortium

The Bureau of Ocean Energy Management today announced the publication of a Request for Information to explore the potential use of the Outer Continental Shelf for offshore space launch and re-entry activities.

“The Outer Continental Shelf presents a significant opportunity to support the future of America’s space economy. Offshore launch, re-entry, and recovery infrastructure could expand operational flexibility, increase capacity, reduce constraints on growing launch demand, and strengthen the nation’s commercial and national security space capabilities. With approximately 3.2 billion acres under federal jurisdiction, BOEM is uniquely positioned to help evaluate this emerging opportunity,” said Acting BOEM Director Matt Giacona. “This Request for Information is an important first step in assessing how offshore development could support the next era of U.S. space leadership.”

Rigs-to-Rockets is one of the alternative OCS uses promoted on this blog. Sea Launch was the first company to launch rockets from a converted semi-submersible drilling rig (photo above).

Kudos to BOEM for this initiative. Their Federal Register Notice is attached.

Six months after the year ended, the Office of Natural Resources Revenue (ONRR) has completed their precise, to the barrel, production accounting. BOEM was correct2025 was a record OCS oil production year by a considerable amount. Total OCS production, nearly 714 million bbls, exceeded the 2019 record by 14 million bbls. EIA data still favor 2019 by a slight margin.

The 16+ million barrel difference between the 2025 ONRR and EIA OCS production totals is much larger than any such differential in recent years and warrants an explanation. Below are the 2025 OCS totals (first table) and the 2019 to 2025 Gulf totals (2nd table). As indicated in the second table, all other differentials between ONRR and EIA were <2 million bbls, and only the 2024 differential was >1 million bbls.

2025 OCS total – ONRR2025 OCS total – EIA2025 Gulf only – ONRR2025 Gulf only – EIA
713,673,419697,020,000708,803,859692,634,000
Table 1

Gulf oil production (bbls)ONRREIA
2019692,681,301692,831,000
2020609,704,101610,064,000
2021623,586,734623,167,000
2022632,639,739631,900,000
2023680,868,936680,400,000
2024656,217,605654,223,000
2025708,803,859692,634,000
Table 2

The Piper Alpha fire (July 6, 1988) was the worst disaster in the history of offshore oil and gas operations and sent shock waves around the world. Eight months later another interactive pipeline-platform fire killed 7 workers at the South Pass 60 “B” facility in the Gulf of Mexico. A US Minerals Management Service task group reviewed the investigation reports for both fires and recommended regulatory changes with regard to:

  1. the identification and notification procedures for out-of-service safety devices and systems,
  2. location and protection of pipeline risers,
  3. diesel and helicopter fuel storage areas and tanks,
  4. approval of pipeline repairs, and
  5. location of ESD valves on pipelines.

Paul Schneider and I wrote a paper on the task group’s findings and that paper was published in Offshore Operations Post Piper Alpha (Institute of Marine Engineers,1991). The proposed regulations that followed summarized these findings and can be be found at this Federal Register link.

Lord Cullen’s comprehensive inquiry into the Piper Alpha tragedy challenged traditional thinking about regulation and how safety objectives could best be achieved, and was perhaps the most important report in the history of offshore oil and gas operations. Per Cullen:

Many current safety regulations are unduly restrictive because they impose solutions rather than objectives. They also are out of date in relation to technological advances. Guidance notes lend themselves to interpretations that discourage alternatives. There is a danger that compliance takes precedence over wider safety considerations and that sound innovations are discouraged.

Cullen advocated management systems that describe the safety objectives, the system by which those objectives were to be achieved, the performance standards to be met, and the means by which adherence to those standards was to be monitored. He called for safety cases that describe major hazards on an installation and provide appropriate safety measures. Per Cullen, each operator should be required in the safety case to demonstrate that the safety management systems of the company and the installation are adequate to assure that design and operation of the platform and its equipment are safe.

Full Piper Alpha Inquiry – 2 parts.

The Declaration of Independence is worth reading, if you haven’t done so in a while. The signers did not know if this radical idea would last one year, 10 years, or 100 years. They certainly did not imagine that what they were declaring would last for 250 years, and that the citizens of the country they created would be celebrating what they declared every year for so many years.

IN CONGRESS, July 4, 1776.

The unanimous Declaration of the thirteen united States of America,

When in the Course of human events, it becomes necessary for one people to dissolve the political bands which have connected them with another, and to assume among the powers of the earth, the separate and equal station to which the Laws of Nature and of Nature’s God entitle them, a decent respect to the opinions of mankind requires that they should declare the causes which impel them to the separation.

We hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness.–That to secure these rights, Governments are instituted among Men, deriving their just powers from the consent of the governed, –That whenever any Form of Government becomes destructive of these ends, it is the Right of the People to alter or to abolish it, and to institute new Government, laying its foundation on such principles and organizing its powers in such form, as to them shall seem most likely to effect their Safety and Happiness. Prudence, indeed, will dictate that Governments long established should not be changed for light and transient causes; and accordingly all experience hath shewn, that mankind are more disposed to suffer, while evils are sufferable, than to right themselves by abolishing the forms to which they are accustomed. But when a long train of abuses and usurpations, pursuing invariably the same Object evinces a design to reduce them under absolute Despotism, it is their right, it is their duty, to throw off such Government, and to provide new Guards for their future security.–Such has been the patient sufferance of these Colonies; and such is now the necessity which constrains them to alter their former Systems of Government. The history of the present King of Great Britain is a history of repeated injuries and usurpations, all having in direct object the establishment of an absolute Tyranny over these States. To prove this, let Facts be submitted to a candid world.

He has refused his Assent to Laws, the most wholesome and necessary for the public good.
He has forbidden his Governors to pass Laws of immediate and pressing importance, unless suspended in their operation till his Assent should be obtained; and when so suspended, he has utterly neglected to attend to them.
He has refused to pass other Laws for the accommodation of large districts of people, unless those people would relinquish the right of Representation in the Legislature, a right inestimable to them and formidable to tyrants only.
He has called together legislative bodies at places unusual, uncomfortable, and distant from the depository of their public Records, for the sole purpose of fatiguing them into compliance with his measures.
He has dissolved Representative Houses repeatedly, for opposing with manly firmness his invasions on the rights of the people.
He has refused for a long time, after such dissolutions, to cause others to be elected; whereby the Legislative powers, incapable of Annihilation, have returned to the People at large for their exercise; the State remaining in the mean time exposed to all the dangers of invasion from without, and convulsions within.
He has endeavoured to prevent the population of these States; for that purpose obstructing the Laws for Naturalization of Foreigners; refusing to pass others to encourage their migrations hither, and raising the conditions of new Appropriations of Lands.
He has obstructed the Administration of Justice, by refusing his Assent to Laws for establishing Judiciary powers.
He has made Judges dependent on his Will alone, for the tenure of their offices, and the amount and payment of their salaries.
He has erected a multitude of New Offices, and sent hither swarms of Officers to harrass our people, and eat out their substance.
He has kept among us, in times of peace, Standing Armies without the Consent of our legislatures.
He has affected to render the Military independent of and superior to the Civil power.
He has combined with others to subject us to a jurisdiction foreign to our constitution, and unacknowledged by our laws; giving his Assent to their Acts of pretended Legislation:
For Quartering large bodies of armed troops among us:
For protecting them, by a mock Trial, from punishment for any Murders which they should commit on the Inhabitants of these States:
For cutting off our Trade with all parts of the world:
For imposing Taxes on us without our Consent:
For depriving us in many cases, of the benefits of Trial by Jury:
For transporting us beyond Seas to be tried for pretended offences
For abolishing the free System of English Laws in a neighbouring Province, establishing therein an Arbitrary government, and enlarging its Boundaries so as to render it at once an example and fit instrument for introducing the same absolute rule into these Colonies:
For taking away our Charters, abolishing our most valuable Laws, and altering fundamentally the Forms of our Governments:
For suspending our own Legislatures, and declaring themselves invested with power to legislate for us in all cases whatsoever.
He has abdicated Government here, by declaring us out of his Protection and waging War against us.
He has plundered our seas, ravaged our Coasts, burnt our towns, and destroyed the lives of our people.
He is at this time transporting large Armies of foreign Mercenaries to compleat the works of death, desolation and tyranny, already begun with circumstances of Cruelty & perfidy scarcely paralleled in the most barbarous ages, and totally unworthy the Head of a civilized nation.
He has constrained our fellow Citizens taken Captive on the high Seas to bear Arms against their Country, to become the executioners of their friends and Brethren, or to fall themselves by their Hands.
He has excited domestic insurrections amongst us, and has endeavoured to bring on the inhabitants of our frontiers, the merciless Indian Savages, whose known rule of warfare, is an undistinguished destruction of all ages, sexes and conditions.

In every stage of these Oppressions We have Petitioned for Redress in the most humble terms: Our repeated Petitions have been answered only by repeated injury. A Prince whose character is thus marked by every act which may define a Tyrant, is unfit to be the ruler of a free people.

Nor have We been wanting in attentions to our Brittish brethren. We have warned them from time to time of attempts by their legislature to extend an unwarrantable jurisdiction over us. We have reminded them of the circumstances of our emigration and settlement here. We have appealed to their native justice and magnanimity, and we have conjured them by the ties of our common kindred to disavow these usurpations, which, would inevitably interrupt our connections and correspondence. They too have been deaf to the voice of justice and of consanguinity. We must, therefore, acquiesce in the necessity, which denounces our Separation, and hold them, as we hold the rest of mankind, Enemies in War, in Peace Friends.

We, therefore, the Representatives of the united States of America, in General Congress, Assembled, appealing to the Supreme Judge of the world for the rectitude of our intentions, do, in the Name, and by Authority of the good People of these Colonies, solemnly publish and declare, That these United Colonies are, and of Right ought to be Free and Independent States; that they are Absolved from all Allegiance to the British Crown, and that all political connection between them and the State of Great Britain, is and ought to be totally dissolved; and that as Free and Independent States, they have full Power to levy War, conclude Peace, contract Alliances, establish Commerce, and to do all other Acts and Things which Independent States may of right do. And for the support of this Declaration, with a firm reliance on the protection of divine Providence, we mutually pledge to each other our Lives, our Fortunes and our sacred Honor.

The 56 signatures on the Declaration appear in the positions indicated:

Column 1
Georgia:
Button Gwinnett
Lyman Hall
George Walton

Column 2
North Carolina:
William Hooper
Joseph Hewes
John Penn
South Carolina:
Edward Rutledge
Thomas Heyward, Jr.
Thomas Lynch, Jr.
Arthur Middleton

Column 3
Massachusetts:
John Hancock
Maryland:
Samuel Chase
William Paca
Thomas Stone
Charles Carroll of Carrollton
Virginia:
George Wythe
Richard Henry Lee
Thomas Jefferson
Benjamin Harrison
Thomas Nelson, Jr.
Francis Lightfoot Lee
Carter Braxton

Column 4
Pennsylvania:
Robert Morris
Benjamin Rush
Benjamin Franklin
John Morton
George Clymer
James Smith
George Taylor
James Wilson
George Ross
Delaware:
Caesar Rodney
George Read
Thomas McKean

Column 5
New York:
William Floyd
Philip Livingston
Francis Lewis
Lewis Morris
New Jersey:
Richard Stockton
John Witherspoon
Francis Hopkinson
John Hart
Abraham Clark

Column 6
New Hampshire:
Josiah Bartlett
William Whipple
Massachusetts:
Samuel Adams
John Adams
Robert Treat Paine
Elbridge Gerry
Rhode Island:
Stephen Hopkins
William Ellery
Connecticut:
Roger Sherman
Samuel Huntington
William Williams
Oliver Wolcott
New Hampshire:
Matthew Thornton

Gulf of America lease map: 199 oil and gas leases were wrongfully acquired for carbon disposal purposes. At Sale 261, Repsol acquired 36 nearshore Texas tracts in the Mustang Island and Matagorda Island areas (red blocks at the western end of the map above). Exxon had acquired 163 nearshore Texas tracts (blue in map above) at Sales 257 (94) and 259 (69).

As expected, the carbon disposal era in Federal offshore waters is ending before it began, and rightfully so.

Energy Intelligence is reporting that Exxon is relinquishing “more than 160 leases” in nearshore Federal waters off Texas. The actual number of oil and gas leases that the company improperly acquired for carbon disposal purposes is 163 (map above).

The reason being cited for the lease relinquishments is that the Dept. of the Interior has shelved regulations for carbon disposal on the OCS. Kudos to the DOI officials responsible for that decision. Carbon disposal has the support of no one except the companies that hope to profit from it. Further, there is no scenario under which Interior could have allowed these wrongfully acquired oil and gas leases to be converted to carbon disposal leases.

Now that these carbon disposal leases are being relinquished, it would be nice to see Exxon start acquiring OCS oil and gas leases for their intended purposes. Exxon and Mobil are historic Gulf operators who were once important contributors to the success of the OCS program.

History of the Exxon and Repsol CCS lease acquisitions.

Per the preliminary EIA data for April, Gulf of America OCS facilities produced an average of 2.107 million bopd in April. This surpasses the previous record of 2.060 million bopd set in January.

Meanwhile, the Sable bump is now evident in the EIA’s Pacific OCS production data with a ~50% March-April increase from January-February. A bigger increase should be apparent when the May numbers are posted. How will Sable fare in the upcoming court battles?