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Archive for 2023

Per Bloomberg, DOE says they could begin refilling the reserve this fall “if the price is right.” What if it isn’t?

Keep in mind that the maximum refill rate is 685,000 bopd. A complete refill at the maximum rate would thus require 533 days, not counting acquisition, operational, and maintenance delays. Filling the reserve to its 727 million barrel capacity was a 28 year process.

Lastly, when will DOE conduct the strategic SPR review called for by the General Accountability Office (GAO) in 2018, well before DOE began rashly withdrawing oil to moderate prices? DOE concurred with GAO’s priority recommendation for periodic strategic reviews of the SPR that would be submitted to Congress. DOE told GAO that they “would complete a SPR Long-Term Strategic Review by the end of fiscal year 2021–5 years from the last review in 2016.” That review has still not been completed.

Update: Yesterday, members of Congress asked GAO to evaluate DOE’s management of the SPR and conduct an audit of the SPR modernization program.

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The Gulf rig count is up to 20, the highest since 2019, as the total US rig count falls by 7 to 748.

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Dr. Malcolm Sharples, a leading marine engineer and offshore safety advocate, brought this Supreme Court’s decision and the resulting regulatory confusion to my attention.

It turns out that the SOCTUS decision about this houseboat…..

has created regulatory uncertainty for floating production facilities like this:

In a 7-2 decision, the court ruled that a gray, two-story home that its owner said was permanently moored to a Riviera Beach, Florida, marina was not a vessel, depriving the city of power under U.S. maritime law to seize and destroy it.

Reuters

The floating production facilities are still subject to Coast Guard regulation and inspection pursuant to separate authority under the OCS Lands Act. The extent to which Coast Guard approval and inspection practices will change is not entirely clear. The Coast Guard will issue new certificates of inspection for these floating facilities, and new policy guidance is being developed.

Attached are answers that the Coast Guard provided to questions from the Offshore Operators Committee.

This may be a good warmup for an upcoming post on regulatory fragmentation.

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That would appear to be the case now that the US Court of Appeals for DC dismissed litigation challenging the sale.

Meanwhile, challenges to Cook Inlet Sale 258 (humble as it was with only one bid) and GoM Sale 259 continue. It’s a great country (if you like endless litigation)!

In addition to Lease Sale 257, the IRA also required Interior to offer three other lease sales in Alaska and the Gulf that it previously declined to hold. Lease Sale 258, in Alaska’s Cook Inlet, was held in December but received only one bid. Earthjustice is challenging that sale. Earthjustice is also challenging Lease Sale 259, in the Gulf of Mexico, which was held in March. Lease Sale 261, also in the Gulf, will be held by September of this year. 

EarthJustice

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The Supreme Court will hear a case that could significantly scale back federal agencies’ authority, with implications for regulations affecting the US offshore program. The court could overturn a precedent known as the “Chevron doctrine” that instructs judges to defer to federal agencies when interpreting ambiguous federal laws.

Few Supreme Court doctrines have been stretched more by regulators and lower-court judges than Chevron deference, which says judges should defer to regulators’ interpretations when laws are supposedly ambiguous. The High Court agreed Monday to give Chevron a much-needed legal review.

WSJ

About the Chevron doctrine:

One of the most important principles in administrative law, the “Chevron deference” was coined after a landmark case, Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 468 U.S. 837 (1984). The Chevron deference is referring to the doctrine of judicial deference given to administrative actions. In Chevron, the Supreme Court set forth a legal test as to when the court should defer to the agency’s answer or interpretation, holding that such judicial deference is appropriate where the agency’s answer was not unreasonable, so long as Congress had not spoken directly to the precise issue at question. 

Cornell Law
Market Chess

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According to EIA data for 2001-2021, Gulf of Mexico flaring and venting volumes peaked in 2001 at 21.6 bcf, 2.25 times the volume flared or vented in 2022 (ONRR data for 2022). However, gas production in 2001 was 5.05 tcf, 6.4 times higher than in 2022. The % of the produced gas that was flared or vented in 2001 was thus 0.4%, less than 1/3 the 2022 rate of 1.22%.

Points to consider:

left axis: gas produced in millions of cubic feet; right axis: % flared or vented

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From ONRR OGOR B data:

20212022
OWG flared59196987
OWG vented14051638
GWG flared311213
GWG vented548722
total flared and vented81839559
total gas prodution791,983784,238
% flared or vented1.031.22
OWG=oil well gas; GWG=gas well gas; all volumes are in MMCF

Observations:

  • Of the 784 bcf produced, 9.6 bcf (1.2%) were either vented or flared (vs. 1.03% in 2021). With the exception of 2020 (1.3%), this is the highest % of gas flared/vented from 2015-2022.
  • The % of gas produced that is flared or vented is trending upward (first chart below).
  • Both the gas flaring and venting volumes were higher in 2022 (vs. 2021) despite lower gas production.
  • Assuming oil-well gas (OWG) production of 600 bcf (final 2022 volume not yet available), approximately 1.4% (8.6/600) of the OWG was flared or vented.
  • 2022 OWG flaring volume increased by 18% vs. 2022 despite nearly identical total oil production
  • A very large increase in OWG flaring in December skewed the 2022 data (921 million cu ft vs 522 million in November, see 2nd chart below). OWG vented and gas-well gas (GWG) vented also spiked in December (third chart). Were these spikes associated with production startups, major compressor issues, administrative/accounting corrections, or other issues?
  • Although total venting increased by 407 million cu ft (21%) in 2023 vs. 2022, the overall venting trend is still favorable (last chart).
  • The previously noted inconsistencies in flaring data sets remain a concern.
  • Kudos to ONRR for posting the flaring/venting data.
  • More regulator/industry transparency on flaring episodes is needed, particularly in light of the PNAS paper and the June 2022 Inspector General Report.

related:

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More red ink.

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Per EIA, February production averaged 1.832 million bopd vs. 1.911 in January.

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Industry consultancy Rystad Energy estimates Guyana will be pumping 1.7 million barrels per day by 2035, which is higher than other major offshore basins including the Gulf of Mexico, ranking the country as the world’s fourth largest offshore oil producer. 

OilPrice.com

The GoM is currently producing >1.8 million bopd. If Rystad/OilPrice intended to say that Guyana production will exceed GoM production in 2035, that could be the case. However, sustained GoM production in 2035 could easily be >1.7 million bopd with proper resource management by government and industry. In fact, BOEM’s latest forecast (table below) calls for production >1.8 million bopd in 2031, the last year in their forecast.

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