Archive for November, 2022

The comment (pasted below) by the trade associations asserts that BSEE ignored the requirements of the National Technology Transfer and Advancement Act (NTTAA).


  • BSEE and its predecessors (MMS and the Conservation Div. of USGS) have been incorporating industry standards since 1969, 27 years prior to the enactment of the NTTAA (1996).
  • 127 standards are currently incorporated into the BSEE regulations. Does this imply ignoring the NTTAA?
  • The keystone of the BOP regulations, API Standard 53, is cited in 250.730, the very section of the rule that is under discussion. Seven other industry standards are cited in that section of the rule. Does this imply ignoring the NTTAA?
  • Regulators cannot cede their authority to standards development organizations. If a standard is outdated or deficient, the regulator must address the issues of concern.
  • Deviations between provisions in the regulations and API Standard 53 are expected and specifically provided for in 250.730 as follows: “If there is a conflict between API Standard 53 and the requirements of this subpart, you must follow the requirements of this subpart.
  • For years, the production safety system regulations specified different leakage rates for surface and subsurface safety valves than those allowed in the API standards. An MMS research project addressed and helped resolve these differences.
  • While essential to safety and regulatory programs, standards are not a panacea; nor is the standards development process without weaknesses. One need only consider the case of the delayed cementing (zonal isolation) standard to appreciate both the importance of standards and the potential weaknesses in the development process.

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Iran 0 USA 1

Can we dedicate the victory to the Iranian “journalist” who aggressively questioned Tyler Adams yesterday (see clip below)? Great response from Tyler who is nothing but class on and off the field. A great captain.

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Q    Does the President think there’s some benefit to the climate to drill oil in Venezuela and not here?

MR. KIRBY:  No, it has nothing to do with a benefit to the climate, Peter.  Again, there are 9,000 unused permits here in the United States on federal land that oil and gas companies can and should take advantage of.  Nine thousand.  And we’re talking about one there in Venezuela.

Oh no, not the 9000 permits response yet again!

Can someone please help the White House staff understand the difference between leases and permits, and the process that is followed in exploring for and producing oil and gas? Perhaps this will help.

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On Thanksgiving …

Grateful for my family and friends, and the many outstanding energy professionals I have had the privilege of working with!

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I recommend we Nationalize the Oil and gas industry. I think the government is the right entity at this time to seize all the assets and infrastructure of the cartels. The resources mostly on public lands and water, belong to the USA anyway. It is time we transition more rapidly to renewables to break the leverage of the cartels on governments, and people, to stop wars and profiteering.

People are paying high prices and cartels like API, Exxon, Sinclair are making record profits from American’s purses. All the while escaping the costs of oil spills and leaks, and denying responsibility for climate change disasters and their costs.

Anonymous WCR commenter (0010)

Diverse input on proposed regulations is healthy and desirable. However, comments should not be posted at Regulations.gov unless (1) the commenter is identified and (2) the comments include at least one sentence about the regulation being proposed.

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Per Regulations.gov. BSEE received 30 comments on the proposed revisions to the Well Control Rule, 25 of which have been posted. The other comments were presumably deemed inappropriate for posting per the guidance at Regulations.gov.

Two of the responses were submitted collectively by 8 industry trade associations. Only 3 operating companies commented and their comments largely echoed the trade association responses. Only 2 drilling contractors responded independently. Four service and engineering companies commented.

Three environmental organizations, a group of Atlantic states, a government watchdog, and a law school provided comments.

Three individuals and 4 anonymous or unknown parties commented.

Below is a list of the respondents preceded by their comment identifiers. More to follow.

  • 0003 Foley Engineering
  • 0004 Frank Adamek
  • 0005 Anonymous
  • 0006 Project on Government Oversight (POGO)
  • 0007 E.P. Danenberger
  • 0008 Chevron
  • 0009 B. Mercier
  • 0010 Anonymous
  • 0011 Anonymous
  • 0012 Foley Engineering (2nd comment)
  • 0013 HMH (?)
  • 0014 NYU School of Law
  • 0015 Beacon Offshore
  • 0016 Shell
  • 0017 Diamond Offshore
  • 0018 7 industry trade associations: API, IADC, IPAA, NOIA, OOC, EWTC, USOGA
  • 0019 NOV (service company)
  • 0020 NRDC
  • 0021 Oceana
  • 0022 Transocean
  • 0023 Louisiana Mid-Continent Oil & Gas Association
  • 0024 Kinetic Pressure Control Limited
  • 0025 Attorneys General of Maryland, Connecticut, Maine, Massachusetts, New York, and North Carolina
  • 0026 Ocean Conservancy
  • 0027 Rigscope International

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On September 14, 2022, BOEM announced that 307 high bids from Lease Sale 257 in the Gulf of Mexico were accepted. BOEM also announced that one high bid was rejected for not providing the public with fair market value. BOEM has not identified the rejected bid.

Per BOEM’s Lease Area Block Online Query file, 306 Sale 257 leases were effective on Oct. 1, 2022. A comparison of these data with the sale results identified 2 Sale 257 leases that have not been awarded:

leaseblockhigh bidder(s)bidcomments
G37261GC 70BHP$3.6 millionlone bid; 7th highest
bid in sale
G37294GC 777BP (75%),
Talos (25%)
$1.8 million2 bids; next highest
$1.185 million

So one of these 2 bids was rejected and the other has lease not yet been awarded for some reason (or perhaps there has been a clerical/IT issue).

Which bid was rejected? I would guess it was the BHP bid even though that bid was the 7th highest bid in the entire sale. The fact that this bid was $2.5 to $3 million higher than the other 7 BHP bids (all of which were accepted) tells us that the company valued this tract highly. Perhaps BOEM, which has all of the geologic data, thought the value was even higher, which is why the bid may have been rejected.

There was another bidder (Chevron) for the BP/Talos tract, so the competition makes it less likely that the bid would have been rejected.

Ironically, the 94 carbon sequestration bids, which made something of a mockery of the lease sale, could not be rejected on fair market grounds. The bids exceeded the minimum required, and the tracts have little or no value from an oil and gas production standpoint. A competitive process would be require to repurpose these leases for carbon sequestration.

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