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A Bell 212 helicopter is in the news following the crash that killed Iran’s President and Foreign Minister. Given the difficult weather conditions and mountainous terrain, the crash was most likely an accident.

As noted in this vintage newsletter (p. 8), we flew to Georges Bank drilling rigs in the early 1980’s in a Bell 212 contract helicopter, owned and operated by Petroleum Helicopters Inc (PHI).

The Bell 212 was chosen by the USGS aviation expert because of its range, reliability, and IFR capabilities that enabled flying in limited visibility. Because of difficult fog conditions on Georges Bank, drilling rigs were sometimes not visible until we were descending to land.

For the most part, the offshore industry has replaced Bell 212 helicopters with newer models, but the 212 was in use for many years and had an excellent performance record.

PHI Bell 212 prepares to land at a platform in the Gulf of Mexico, 1974, Vertiflite.

Florida HB 1645 (attached) was signed by Gov. DeSantis on 5/15/2024. The bill boosts natural gas, prohibits offshore wind turbines, and deletes references to climate change and greenhouse gases in state law. Given the State’s support for traditional energy sources, is it time to renew the dialogue about exploration and production in the Eastern Gulf of Mexico (EGOM)?

HB 1645 prohibits offshore and coastal wind development (p. 30), acknowledges that natural gas is critical for power resiliency, prohibits zoning regulations that restrict gas storage facilities and gas appliances (p.8), and relaxes permitting requirements for pipelines <100 miles long.

Given Florida’s energy preferences as expressed in this legislation, the State could assist regional energy planners by better defining its position on oil and gas leasing in the EGOM. What limits, in terms of lease numbers and minimum distances from shore, would best improve Florida’s energy supply options while further minimizing environmental risks?

As illustrated on the map below, the petroleum geology of the EGOM and Florida’s preferences are likely aligned in that the best prospects for oil and gas production are in deep water and more than 100 miles from the State’s coast. Does Florida support a 100 mile buffer?

The 4/20/2010 Macondo blowout was a tragic failure that has been, and will continue to be, discussed at length on this blog. We should also acknowledge that prior to Macondo 25,000 wells were drilled on the US OCS over a 25 year period without a single well control fatality, an offshore safety record that was unprecedented in the U.S. and internationally. We should also applaud recent advances in well integrity and control, including the addition of capping stack capabilities that further reduce the risk of a sustained well blowout.

Florida’s independent thinking on energy policy is commendable. That independence is contingent on importing petroleum products and natural gas from elsewhere in the Gulf region. Securing that supply over the intermediate and longer term should be a priority for Florida. In that regard, EGOM production is an important consideration.

The DrillMAX has exited Bulls Bay and is en route to the Orphan Basin, where Exxon will drill a high potential exploratory well. As of this morning at ~1000 GMT, the drillship was headed north at 7.7 kts (see map).

On Constitution Day, best wishes to our Norwegian friends!

This JL Daeschler photo was taken in Stavanger harbor in 2003. JL’s wife Debra, a Petrodata Marine editor, is pictured in the foreground. The rig in the background is the Maersk (now Noble) Innovator, a large jackup capable of operating in water depths to 492 ft. The legs are 674 ft (Washington Monument = 555 ft).

In the attached supplement to his comments on BOEM’s financial assurance rule for offshore oil and gas facilities, decommissioning specialist John Smith raises concerns about reliance on cost data submitted by operators. John contrasts operator estimates for platforms in California state waters with estimates provided by independent consultants.

As summarized below and explained in the attachment, the more realistic independent estimates were 2-3 times higher than the operators’ “high end” estimates.

Nord Stream AG has responded to their insurers’ a goverment did it, so we don’t have to pay” defense. Nord Stream’s full response, courtesy of Swedish engineer Erik Andersson, a leader in seeking the truth about the the pipeline sabotage, is linked.

Key excerpts from the Nord Stream AG filing (p.5):

(a) On their proper construction, in the context of Exclusion 2.i as a whole, the words “destruction of or damage to property by or under the order of any government or public or local authority” relate only to destruction or damage that arises out of or is related to the confiscation, nationalisation or requisition of therelevant property (and/or attempts thereat). In the premises, those words do not apply to the Damage.

(b) Alternatively, in the event that the Defendants establish that the Damage does constitute destruction of or damage to property by or under the order of any government, then it is therefore covered by the Deliberate Damage clause because it would have been “loss, damage, liability, cost or expense caused or inflicted by order of any governmental or regulatory body or agency” and Exclusion 2(i) to Section I does not apply: paragraphs 8 and 9.2 above are repeated.

If the insurers contend that one or more governments were responsible, shouldn’t they have to identify the government(s)? That would be nice. However, Erik doesn’t think the Nord Stream AG response puts the insurers in that politically difficult position. I agree. This case is about getting the insurers to pay for the damages, not identifying the responsible parties, something that the Swedes, Danes, and Germans have shied away from.

Last year, there were reports that a level 3 geomagnetic solar storm rendered GPS signals unreliable and caused the brief suspension of at least one drilling operation in Canada (tweet below).

This weekend’s solar storms were level 5, the highest category (see chart below), but there have been no public reports to date of suspended drilling operations.

Decommissioning Vindeby wind project, Denmark

BOEM’s “Rule to Streamline and Modernize Offshore Renewable Energy Development” is intended to “make offshore renewable energy development more efficient, [and] save billions of dollars. Unfortunately, the savings associated with relaxed decommissioning financial assurance requirements translates to increased risk for customers and taxpayers.

BOEM signaled their intentions on offshore wind (OSW) decommissioning three years ago when they granted a precedent setting financial assurance waiver to Vineyard Wind. Despite compelling concerns raised by commenters, the “streamlining” regulations have codified this decision.

Cape May County, New Jersey, was among the commenters objecting to BOEM’s departure from the prudent “pay as you build” financial assurance requirement. The County commented as follows (full comment letter attached):

“[e]nergy-utility projects are in essence traditional public-private partnerships where technical and financial risks are transferred to the private sector in exchange for the opportunity to generate revenues and profit. Under the proposed rule, the Federal government is instead transferring risks associated with decommissioning to the consumer rather than to the private sector.

Cape May added:

[w]hile BOEM believes that if a developer becomes insolvent during commercial activity that a solvent entity would assume or purchase control, the County believes this is a risky assumption as the most likely reason for default is that a constructed wind farm developer is unable to meet its contractual obligations set forth under a Power Purchase Agreement (PPA) because its energy production revenues are not in excess of its operating costs. A change of hands would not remove these circumstances or make the project profitable.”

Cape May and others also commented on the threat of premature decommissioning as a result of storm damage. In response, BOEM asserts that these risks have been addressed in the latest standard for North American offshore wind turbines (Offshore Compliance Recommended Practices: 2022 Edition (OCRP-1-2022)). However, design standards, particularly those for offshore facilities, are not static. The recommended practice for OSW is likely to change multiple times in the coming years as storm, operating, and turbine performance data are updated and analyzed. The design standard for Gulf of Mexico platforms has been repeatedly refined and improved and is now in its 22nd edition.

In their response to public comments on the decommissioning risks, BOEM repeatedly asserts that they can adjust the amount and timing of required financial assurance as they monitor a lessee’s financial health. Unfortunately, a company’s finances can change quickly and BOEM’s options will be limited when it does. Increasing the financial burden on a struggling company that is providing power to a regional power grid will not be a simple proposition.

Strong comments from Cape May County:

BSEE has a very good Safety Alert program that merits close attention. However, this amusing entry doesn’t qualify. Perhaps this alert was issued in response to a government-wide anti-scamming directive.

Safety Alert No. 483 (plus a few comments in parentheses):

Scam Alert: Suspicious Requests for Payment
The Bureau of Safety and Environmental Enforcement (BSEE) is issuing this Safety Alert to inform users about possible scams requesting payment of fines for violations. Be aware the documents you receive may appear to be printed on official government letterhead and could be used to justify requests for payments or loans. BSEE does require payment of fines for certain violations, but BSEE will never:

  • Request payment via phone or through any social media platforms.
  • Require a payment from an individual to exit an offshore facility. (Huh? How would this work? Would a BSEE inspector stand at the helideck and require payment before a worker boarded the helicopter? Seriously?)
  • Request any payment using a gift card. (“You violated an OCS safety regulation. Please make payment with a Target gift card.” 😀)
  • Demand any payment without prior notification.
  • Send letters containing spelling, grammar, and punctuation errors. (Yes, all regulations, notices, and other correspondence are in “plain English” and perfectly understandable. 😀 😀 😀)
  • Should BSEE require a payment for a civil penalty or a fine, the fine will be paid by the operator, not by an individual. BSEE will always send an initial notice to the operator and provide them the opportunity to engage with the BSEE Civil Penalty team.

According to rig locator data, the DrillMAX is moored in Bay Bulls, Newfoundland in preparation for transit to the site of Exxon’s high potential exploratory well in the Orphan Basin.