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Archive for 2022

Here is a good article, endorsed by Elon Musk among others, about the foreseeable problems NASA is facing with the Space Launch System rockets. SLS rockets use hydrogen which, at super-chilled temperatures and high pressures, easily oozes out of any available opening. Space X Raptor engines are fueled with methane (imagine that) which Musk and his engineers think is the best combination of high efficiency and ease of operation. Methane is also easier to produce on Mars where Musk hopes to develop a self-sustaining city.

In light of their respective frontier exploration accomplishments, space exploration and deepwater production are sometimes compared. In that spirit, NASA’s inspector general estimates the Artemis campaign will cost $93 billion between 2012 and 2025, $4.1 billion for a single launch. Each Artemis launch will thus cost approximately as much as developing and producing a 100 million barrel deepwater oil field in the Gulf of Mexico. And, of course, the Artemis program is fully funded by the government, while deepwater oil and gas development is not only privately funded but is an important source of government revenue.

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Link to the press release.

To the extent that these numbers are honored and adhered to, attached is the OPEC+ production table (1000’s of BOPD). Note that Russia and Saudi Arabia have identical quotas – 11,004,000 BOPD.

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An important figure in the history of the US offshore program passed away last week. Gerry Rhodes was a petroleum engineer with an attorney’s gift for understanding laws and regulations. Among other leadership roles in the offshore regulatory program, Gerry was Chief of the Minerals Management Service’s Branch of Rules, Orders, and Standards in the 1990’s.

Gerry was among the first in the Federal government to fully understand the financial responsibility risks associated with the decommissioning of offshore facilities and the urgent need to update requirements for the plugging of wells and removal of platforms. The enormity of this challenge is described in the 1991 Forbes article pasted below. Despite sharp divisions within the offshore industry and the resulting political pressure, Gerry succeeded in finalizing regulations (including this 1995 rule) that are the basis for the current financial responsibility programs in BOEM and BSEE. Without Gerry’s resolve, subsequent financial assurance challenges and government outlays would have been far greater.

RIP Gerry. You were a true gentleman, a dedicated father and grandfather, and a diligent and highly accomplished colleague.

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The U.S. Court of Appeals for the D.C. Circuit ruled that BOEM “unreasonably refused to consider possible deficiencies in environmental enforcement” in their Supplemental EIS for Sales 250 and 251. The court found that BOEM did not adequately consider a 2016 Government Accountability Office (GAO) report that was critical of BSEE’s oversight of offshore activities.

More positively, the court chose not to vacate the sales or the EIS:

Moreover, vacatur would be highly disruptive for the lessees. They have paid millions of dollars to obtain their leases and have acted for some four years in reliance on them—including by investing substantial additional sums and by executing contracts with third parties. Moreover, any redo of the lease sales “would be tainted by prior publication of [the] lessees’ proprietary valuation of the leases” following the original sales.

Comments:

  1. How many GAO reports on BSEE or MMS have not been critical of some processes or procedures? None that I can recall.
  2. It’s unreasonable to expect BOEM to consider every GAO or other external criticism of the regulatory program in their EIS’s.
  3. All of the GAO recommendations in the subject report were process related and were closed (implemented) several years ago.
  4. The court exercised good judgement in declining to vacate the sale. Per the decision, the case will be remanded to BOEM for further consideration of the GAO report.

 

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7 cadets ordered off Coast Guard Academy campus over vaccine status. “They were escorted to the gate like they were criminals or something,” the lawyer, Michael Rose, told the newspaper.

Even those of us who are fully vaxed acknowledge the vaccines’ uncertain efficacy and risks, and the many issues with the CDC guidance and Covid protocols. Military personnel must comply with orders, but questionable orders should be revised as new information becomes available.

Regulators know that regulations, policies, and practices cannot be static. As we learn, we update and improve. Enforcing outdated guidance is just a power play, and demonstrates rigidity not competence. The Coast Guard understands all of this, so their decision to evict the cadets is especially disappointing.

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GoM oil production for June increased (see chart below) with King’s Quay and Spruance contributing to the uptick. Other anticipated 2022 startups are not yet producing.

The EIA production forecast for 2022 is proving to be pretty accurate. Kudos to them. However, BOEM’s 2022 forecast of 1.9 million bopd is not achievable and concerns about the intermediate and longer term persist. Unfortunately, BOEM’s highly optimistic forecast for 2022 and beyond, along with unrealistic expectations regarding the energy transition, have significant policy implications. This stunning quote from the 5 year leasing plan explains why so few lease sales were proposed:

BOEM’s short-term (20-year) production forecast for existing leases shows steady growth from 2022 through 2024 and declining thereafter (see Section 5.2.1). The long-term nature of OCS oil and gas development, such that production on a lease can continue for decades makes consideration of future climate pathways relevant to the Secretary’s determinations with respect to how the OCS leasing program best meets the Nation’s energy needs.

5 Year Leasing Program, p.3

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OEUK statement

It’s disappointing that this statement was even necessary. Under the circumstances, the need for new UK offshore licenses would seem to be obvious and undeniable.

“The European energy sector right now is cracking at the seams. Without the contribution of UK oil and gas resources, that crack would be a gaping hole.” 

Mike Tholen, OEUK

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Per legislation signed by the President on Aug. 16, 2022:

(b) LEASE SALE 257 REINSTATEMENT.—
(1) ACCEPTANCE OF BIDS.—Not later 30 days after the date of enactment of this Act, the Secretary shall, without modification or delay
(A) accept the highest valid bid for each tract or bidding unit of Lease Sale 257 for which a valid bid was received on November 17, 2021; and
(B) provide the appropriate lease form to the winning bidder to execute and return.

The Department of the Interior has been silent on their implementation of this provision. We are particularly interested in:

  1. how the 94 carbon sequestration bids will be handled
  2. whether any bids will be rejected on fair market value grounds

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Dept. of Justice announcement

In addition to the penalty and reimbursement elements of the plea agreement, there are two Amplify commitments that may be of particular interest to BOE readers:

  1. New leak detection system for the pipeline: More information on the leak detection improvements for this low pressure oil pipeline would be helpful.
  2. Notification to regulators of all leak detection alarms:
    • Which regulators? DOT? BSEE? State? All?
    • Real time reporting or periodic compilations? With real time reporting for every alarm, the distinction between the pipeline operator and regulator(s) would be blurred and new organizational and competence risks would be added. The probability of communications errors and delayed decisions would increase, and the operator would no longer be accountable for bad decisions.

Also, given that the investigating agencies have still not issued their report on the October 2021 spill and no action has yet been taken against the shipping companies that caused the pipeline rupture, the congratulatory Coast Guard, EPA, FBI, and DOT quotes in the announcement seem rather premature and self-serving.

Two final thoughts:

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GUILDFORD, UK — Alpha Petroleum Resources, Energean UK and Orsted Hornsea Project Four will consider repurposing the Wenlock gas platform in the UK southern North Sea, which is nearing the end of its productive life.

One possibility is to reuse the facility as an artificial nesting site to offset the impact on certain bird species of offshore wind developments in the area.

Black-legged kittiwakes have set up nests on various North Sea platforms, according to Orsted’s recent surveys. Repurposing an existing platform as an artificial nesting structure is seen as an alternative to building a new artificial nesting structure to support the local development of the Hornsea Four offshore wind farm.

Offshore Magazine

See our Rigs-to-Reefs+++ page!

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