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Archive for June, 2023

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.

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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.

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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?

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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

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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.

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