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The comment period for BOEM’s proposed revisions to decommissioning financial assurance requirements closes on Friday, May 8th.

John Smith’s comments have been officially submitted to Regulations.gov, and are attached for your convenience. Nice work by John.

My comments are being finalized and will be submitted and posted soon.

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An apology letter from the California Coastal Commission (CCC) to SpaceX was part of a lawsuit settlement. SpaceX alleged political bias in the commission’s 2024 decision to deny increased Falcon 9 launches at Vandenberg Space Force Base, based on comments about Elon Musk’s political views and SpaceX’s labor practices.

Excerpt:

“In 2024, the Commission reviewed consistency determinations by the U.S. Space Force for SpaceX’s Falcon 9 launch program at Vandenberg Space Force Base. During that review, some Commissioners made negative comments about SpaceX’s labor practices and its Chief Executive Officer’s political views. The Commission acknowledges that these political comments were irrelevant to the Commission’s consistency review and were improper, and the Commissioners apologize for those comments.”

AI confirms my suspicions that formal CCC apologies are highly unusual 😉

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Update: Another EIA revision to Gulf of America oil production for Dec. 2025 (1.994 to 1.985 million bopd) means that 2019 retains the production record by the narrowest of margins – 1.898 to 1.897 million bopd. Stay tuned because this may not be the final word 😉.

Per EIA, Feb. 2026 production dipped a bit to 1.931 million bopd (chart below).

Meanwhile, California OCS oil production for FEB continued at about 10,000 bopd. This number may increase a bit for March, and more for April data when the first Sable sales are included. A big increase, by as much as 500%, should be apparent in the June report barring a court ordered shutdown.

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Sable’s updated PowerPoint presentation is attached.

Also, the 2025 compensation package for Sable CEO Jim Flores is attracting attention. Flores received $76 million in total compensation. The bulk of his pay came from more than $69 million in stock awards, alongside a $1.3 million salary and a $3.9 million bonus. 

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Looking up towards Platform Gilda from a depth of 100 feet, juvenile bocaccio rockfish swirl around the anemone-covered crossbeams (photo by Dr. Milton Love) 

Dr. Jeremy Claisse, Cal Poly Pomona: “The oil and gas platforms off the coast of California are the most productive marine habitats per unit area in the world.” 

Dr. Milt Love, UCSB: “Even the least productive platform was more productive than Chesapeake Bay or a coral reef in Moorea.

John Smith has made the case for reefing California platforms. He is now proposing a change in the regulations that could facilitate such partial removals of offshore structures. His full proposal is attached.

As background John notes:

In contrast to the Gulf of Mexico (GOM), where more than 600 decommissioned platforms have been converted to artificial reefs, the State of California does not have reefing legislation considered workable by industry, nor does it have an approved or State funded artificial reefing program which is a prerequisite under MMA (formerly BSEE and BOEM) OCS oil and gas regulations (30 CFR § 250.1730) for waiving platform removal requirements which allows conversion of the structure to an artificial reef.

He further informs that “operators of the platforms have not expressed any serious interest in reefing OCS platform jackets because they consider the California Marine Resources Legacy Act unworkable in its present form due primarily to its liability provisions, inequitable 80% cost-savings sharing requirement, and the requirement for the first reefing applicant to fund the setup costs for the artificial reefing program.

John’s proposal is intriguing because it allows qualified 3rd parties to accept title and liability for reefed structures. This would create interesting business opportunities. A company, consortium, nonprofit, or entrepreneur could, for a fee, acquire submerged structures and obtain insurance or other financial protection in accordance with their business plan. Reef preservation and enhancement studies, and other marine research could also be conducted at the sites. Marine ecosystems would be protected, and the cost and efficiency of decommissioning operations would be significantly improved.

So, you disconnect the jacket… you kill all the fish. There’s an awful lot of animals that die,” said Dr. Love. As our world has become dependent on fossil fuels, so too have these millions of animals become dependent on the structures that pump them from beneath the sea floor. “As a biologist, I just give people the facts, but I have my own view as a citizen, which is I think it’s criminal to kill huge numbers of animals,” said Dr. Love.

John’s proposal warrants serious consideration.

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California Superior Court Judge Donna Geck denies Sable’s motion to lift the preliminary injunction.

Judge Geck’s ruling

(1) For the reasons set forth herein, the motion of real parties in interest Sable Offshore Corp. and Pacific Pipeline Company to dissolve or modify the preliminary injunction issued in this case is denied.

(2) The application of petitioners for issuance of an order to show cause why real parties should not be found in contempt and to enter additional orders is continued to May 22, 2026.

 The Judge concluded:

  • The court is mindful that there are many moving judicial and administrative parts relating to the restart of the Las Flores Pipelines. (understatement of the year candidate? 😉)
  • Sable has not persuaded the court that the DPA (Defense Production Act) Order renders compliance with Federal Consent Decree unnecessary.
  • The Federal Consent Decree requires approvals from the OSFM (Office of the State Fire Marshal), which in turn must comply with state procedures in granting such approvals.
  • Sable has not met its burden to show that the preliminary injunction should be dissolved or modified. Sable’s motion will therefore be denied.

On May 22, Judge Geck will consider whether Sable should be held in contempt for not complying with the preliminary injunction.

If you haven’t been keeping up 😉:

  • Subsequent to Judge Geck’s preliminary injunction, the Pipeline and Hazardous Materials Safety Administration (PHMSA – a simpler agency name is long overdue!) asserted that the Las Flores Pipelines constitute an interstate pipeline subject to PHMSA’s exclusive jurisdiction.
  • PHMSA issued their own approvals and an emergency special permit.
  • The PHMSA approvals are the subject of proceedings in the Ninth Circuit Court of Appeals, which has not issued a final ruling.

Undaunted, Sable reports (4/20/2026):

  • The 40 wells currently online at Platform Harmony and Platform Heritage are producing an average of 750 gross barrels of oil per day per well. Once all 74 production wells on these two platforms are online, Sable expects the average production per well to be approximately 700 gross barrels of oil per day.
  • Sable expects Platform Hondo to come online in June 2026 with an estimated fully ramped production rate of approximately 10,000 gross barrels of oil per day.

Hence, Sable production is estimated to reach ~60,000 bopd in June, which is about 6 times total California OCS production prior to the Sable restart!

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The Case for Reefing California Platforms by John Smith

Environmental groups like the Environmental Defense Center and Get Oil Out continue to oppose converting the jackets of California oil and gas platforms to artificial reefs despite scientific studies (Claisse et al. 2014) showing “oil and gas platforms off the coast of California have the highest secondary fish production per unit area of seafloor of any marine habitat that
has been studied.

Another important factor environmental groups and the 2023 BOEM Programmatic EIS for Decommissioning failed to consider and acknowledge is the huge amount of air emissions that would be released by world-class heavy lift vessels like the Thialf or Balder Semi-submersible Crane Vessels (SSCVs) that would be required to safely and efficiently remove the large federal OCS platforms like Harvest, Hermosa, and Hidalgo (HHH). The HHH platforms are in waters depths ranging from 430-675 feet and have combined deck and jacket weights ranging from 20,000 – 25,000 tons. In comparison, the wrought iron structure of the Eiffel Tower weighs about 8,000 tons.

The SSCVs and accompanying Anchor Handling Tugs (AHTs) used to remove the HHH platforms will likely to be mobilized from distant locations like the North Sea or Gulf of America where they typically operate. Because SSCVs like the Thialf and Balder are too large to enter the Panama Canal, this would involve a 20,000 nautical mile roundtrip voyage around the tip of South America.

Three to four campaigns, and separate SSCV and AHT mobilizations and demobilizations, are projected to be required to fully remove the HHH platforms because the challenging oceanographic conditions offshore Point Arguello restrict heavy lift operations to a 150-day period between May and October.

Four campaigns by the SSCV and AHT would consume about 300,000 metric tons (mt) of marine diesel oil and release approximately 470,000 mt of CO2 and 11,000 mt of NOX emissions. To put these numbers into context, 470,000 mt of CO2 and 11,000 mt of NOX are:

  • the amount of CO2 emissions released by providing electrical power to 97,600 homes annually (the city of Santa Barbara has about 38,000 housing units).
  • the amount of CO2 emissions released by burning 1.1 million barrels of oil.
  • the amount of CO2 emissions released by 102,000 gasoline burning cars annually.
  • the amount of NOX emissions released by four large oil or coal-fired power plants annually.
  • the total annual NOX emissions in Santa Barbara County.

And this is only the emissions released during mobilization and demobilization of the SSCV and AHT. If full removal is required, an additional 50 days of operational time by the SSCV and AHT is estimated to be required to remove the topside and jacket of each HHH platform. This could be reduced to about 15 days per platform if the jackets are converted to artificial reefs. Only one SSCV and AHT campaign may be required if the HHH jackets are reefed, compared to the four campaigns required for the full removal scenario. This would result in a 75 percent reduction in CO2 and NOX emissions.

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Background: By a 3-2 vote, the Santa Barbara County Planning Commission, acting under the direction of the Board of Supervisors (also by a 3-2 vote), passed ordinances to ban new onshore oil and gas wells and phase out old wells.

The quote:

“We keep discovering new oil and new techniques to recover it,” said Commissioner John Parke. “The only thing to stop the oil industry and the production of oil is legislation.”

Comments:

  • The first sentence is perceptive, acknowledging that resources are not really finite given the ingenuity of engineers and geologists.
  • The second sentence is disturbing. The Commissioner believes he is legally and morally entitled to terminate an industry that has been present in Santa Barbara County for >130 years. He believes the Commission can do so by a slim majority and without compensation to those whose property rights are being abrogated.
  • The 2 Commissioners voting against euthanizing the County’s oil industry represent Districts 4 and 5 (maps below) where most of the wells are located. In essence, South County Santa Barbara is terminating an industry that is important to North County.
  • Pertinent to the County’s action is a suit filed by John and Melinda Morgan, who inherited the mineral rights to two parcels in the Cat Canyon Field (District 4). They argue that a similar provision in CA Senate Bill 1137 amounts to an unconstitutional taking of their property.

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I’m attaching the complete comment letters from Sable Offshore and their main antagonist, California Attorney General Bonta, in response to PHMSA’s public notice and request for comments on Sable’s special permit application.

Summary of the California AG’s assertions:

“First, PHMSA is without authority to grant such a special permit because Lines CA-324/325 are intrastate pipelines and California regulators have sole regulatory oversight over any attempt to restart these Lines and issue state waivers. Second, California has vested interests in ensuring Lines CA-324/325 operate safely and PHMSA’s proposed special permit would dilute the higher state safety standards that were imposed on Sable and therefore it is inconsistent with pipeline safety. 49 C.F.R. § 190.341(d). Third, given the fact Line CA-324 already failed and caused a catastrophic oil spill in 2015 in Santa Barbara County, even if PHMSA had authority to issue a special permit (which it does not), a more robust environmental analysis needs to be performed. Fourth, PHMSA unlawfully invokes the Endangered Species Acts’s emergency consultation procedures and has given no indication that it will consult with the National Marine Fisheries Service, in violation of the Act. Finally, Secretary Wright’s March 13, 2026, order (“DPA
Order”) does not change anything about the propriety of the Application, because the DPA Order itself is unlawful.”

Summary of Sable’s position (screenshot):

You can sample the other public comments, some of which are quite good, by visiting the Regulations.gov docket.

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The EIA has revised Gulf of America oil production slightly downward for Nov. and Dec. such that we now have an absolute dead heat between 2025 and 2019. Production for both years averaged exactly 1.898 million bbls/day.

Because of the ~6 month lag in obtaining verified OCS production data from the Office of Natural Resources Revenue (ONRR), the monthly EIA reports are based on ONRR’s more timely sales of production data. The final sales and production numbers are typically very close. For the 2019 record OCS production year, both the EIA and ONRR report identical Gulf production of 1.898 million bopd.

Meanwhile, 2026 Gulf production (chart below) is off to a strong start – 2.019 million bopd in January. This is the third highest monthly oil production in the history of Gulf operations.

Finally, California OCS oil production, which has been hobbling along at ~10,000 bopd (2nd chart) will see a massive increase of up to 500% should Santa Ynez Unit production continue.

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