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Archive for the ‘decommissioning’ Category

Background: On February 12, 2024, the bankruptcy court approved the sale of certain Cox Operating assets to Natural Resources Worldwide LLC (NRW), a company that “does not mine, drill, or produce minerals, has no operations, and conducts business solely in an office environment.”

NRW contracted with Array Petroleum to operate the former Cox Assets. Array subsequently sued NRW, asserting that NRW received $78,000,000 in revenue, but disbursed only about $48,000,000 to pay Array’s invoices and those of the subcontractor.

The court filing claimed that NRW failed to pay Array $2.5 million, the subcontractors $10.7 million, and the United States $12 million. A large share of the subcontractor costs were probably for well operations given that 21 Array workover applications were approved in 2024 and 2025. The $12 million due to the Federal government is reportedly for royalty payments. Were any revenues set aside for decommissioning liabilities?

Array’s lawsuit was dismissed by the court on January 3, 2025, after a joint motion to dismiss was filed by the defendants. Information on the reasons for the dismissal is not publicly available.

Old platforms: According to BOEM records, Array operates 154 platforms previously owned by Cox. These platforms are in the Ship Shoal, South Marsh Island, and West Delta areas of the Gulf of America. Most are >30 years old and four are more than 70 years old (see chart below). 41 are classified as major structures including 15 of the 26 platforms installed in the 1950s and 1960s. 44 are manned on a 24 hour basis. 79 have helidecks. Massive decommissioning liabilities loom.

Violations: NRW/Array ranks 37th out of 42 companies in GoA oil production (2025 YTD) and 36th out of 42 companies in gas production, but leads the pack in Incidents of Noncompliance (INCs):

  • Array accounted for nearly half of all GoA INCs issued in the first half of 2025 (chart below).
  • Array was issued 9 times more warning INCs (311) than any other operator. Apache was second with 34.
  • Array had more component shut-in INCS (46) than any other operator. W&T, another operator of Cox legacy platforms, was second with 32.
  • Array had more facility shut-in INCs (6) than any other operator. W&T was again second with 5.
  • Array averaged 2.0 INCs/facility inspection vs. a combined average of 0.3 INCs/facility inspection for all other operators.
violation typewarningscomponent shut-insfacility shut-ins
Array311466
all others21116449

Lessons that should have been learned from the Cox, Fieldwood, Black Elk, Signal Hill, and other bankruptcies dating back to the Alliance Operating Corp. failure in 1989:

  • There are many small and mid-sized companies that are responsible operators. Their participation in the OCS program should be encouraged. However, others have demonstrated, by their inattention to financial and safety requirements, that they are not fit to operate OCS facilities.
  • The growth of Fieldwood, Cox, Signal Hill, and Black Elk was in part facilitated by lax lease assignment and financial assurance policies. 
  • Operating companies should have to demonstrate that they can operate safety and comply with the regulations before they are approved to acquire more properties.
  • Despite ample evidence of the importance of compliance and safety performance in determining the need for supplemental financial assurance, BOEM’s 2024 rule dropped all consideration of these factors.,
  • Expect the ultimate public cost of the Cox bankruptcy, in terms of decommissioning liabilities and the need for increased oversight, to be large.
  • The Federal govt (Justice/Interior) should strongly oppose bankruptcy court asset sales that increase public financial, safety, and environmental risks.

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Linked below is a new Rigs to Reefs film (“Steel to Sanctuary”). Note the commentary on permitting complexity and regulatory fragmentation.

Not mentioned in the film are the extraordinary efforts of the Mineral Management Service’s Villere Reggio in establishing the Rigs to Reefs program. Villere (pictured below), has a most interesting family history as summarized in the caption. See p. 3 of this issue of MMS Today for the complete article.

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Sharing pictures from John Smith’s excellent decommissioning presentation at the Western States Petroleum Assoc. luncheon in Santa Barbara in May. You can view or download the presentation here.

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Thialf: a character in Norse mythology who was Thor’s servant.

The Heerema Thialf, a semi-submersible crane vessel (SSCV), is a rather massive presence in coastal waters. The vessel is 661 feet long and 470 feet high, with a lifting capacity of up to 14,200 metric tons, and is the second-largest of its kind.

The Thialf, which set a world record in 2000 by lifting the 11,883-metric-ton Shearwater topside structure in the North Sea, will be driving piles for 54 Vestas 15 MW wind turbines and a substation structure that are part of Equinor’s controversial Empire Wind project.

John Smith tells me that the Thialf is one of the heavy lift vessels being considered for removing California offshore oil and gas platforms. The vessel is too large for the Panama Canal and would have to make the trip around South America or across the Pacific, depending on where it was last working.

The Thialf’s day rate has not been disclosed, but is likely greater than $500k. Equinor claimed to be losing $50 million/week when the project was paused. Thialf costs were presumably a significant chunk of those losses.

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John Smith’s excellent decommissioning presentation at the recent Western States Petroleum Assoc. luncheon in Santa Barbara is attached. John used an amended version of Bob Byrd’s OTC powerpoint, adding slides on the proposed California Marine Legacy Act amendments.

For those who have been following the Santa Ynez Unit story, Harmony, Heritage, and Hondo are the platforms in that unit. Platform Harmony, where production resumed on the date of John’s presentation (5/15), is in 1198′ of water and is one of the world’s largest offshore structures.

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John Smith shared an outstanding paper (attached) that was presented by co-author Robert Byrd at the SPE Regional Meeting in Garden Grove, CA last week.  

 

John Smith: “My objective in writing the paper is to hopefully spur legislators to recognize the benefits of reefing and the legislative fixes required to facilitate reefing and the removal of aging infrastructure.  The California Department of Fish and Wildlife Habitat Lead was very complimentary of the paper and has distributed it to the Interagency Team which is developing a California Artificial Reefing Plan.”  

John adds: “They are in the process of creating a statewide artificial reef plan and you can sign up for updates and get more information. The California Artificial Reef Program (CARP) Plan won’t discuss the specifics of Rigs-to-Reefs but will be compliant with the National Fisheries Enhancement Act and National Artificial Reef Plan and meet the BSEE requirement of having an adopted state artificial reef plan. The intent is to add an addendum to the plan when resources become available to move Rigs-to-Reefs forward in California. You can check out the latest program update that further discusses the CARP Plan and Rigs-to-Reefs.”

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Coast Guard photo. Thanks to Lars Herbst for bringing this incident to my attention.

In what the Coast Guard is describing as an “uncontrolled discharge” (euphemism for blowout), an 82-year-old oil well has been spewing oil, gas, and water into the coastal marshes of southern Plaquemines Parish, Louisiana, for more than a week.

In hopes of future production, prior and current owners had elected not to permanently plug the well, apparently with the State’s acquiescence.

The well is currently operated by an affiliate of Spectrum Energy. Typical of these situations, the previous owner, Whitney Oil and Gas, was in bankruptcy.

The Coast Guard has taken over the response and has accessed the Oil Spill Liability Trust Fund.

We don’t need relaxed decommissioning and financial assurance requirements. We need a cooperative Federal, State, and industry effort to ensure that wells are plugged in a timely manner and that financial assurance is provided to protect the public interest.

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The U.S. Department of the Interior today (5/2/2025) announced its intent to “update” the Bureau of Ocean Energy Management’s 2024 Risk Management and Financial Assurance for OCS Lease and Grant Obligations Rule. 

Those who are concerned about minimizing the Federal government’s decommissioning risk exposure should closely monitor this process. Some companies and their political allies have sought to minimize the financial risks associated with plugging wells and removing facilities. As a result, it has been necessary to defend BOEM from unwarranted commentary about decommissioning issues and the financial assurance rule. Stay tuned!

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the early years

Remember that Chevron was once Standard Oil of California. The attached WSJ article discusses the ugly divorce after all these years.

Chevron tired of California’s attempts to dictate corporate strategy. Per Chevron CEO Mike Wirth:

“Putting bureaucrats in charge of centrally planning key segments of the economy hasn’t worked in other socialist states,” Wirth said in a Nov. 1 call with investors. “I doubt it will be any different in California.”

California wanted Chevron to commit to the State’s energy agenda:

Chevron has a future in clean energy in California. They can join us in our steady, long-term transition to a state powered by clean energy,” said Daniel Villaseñor, a spokesman for the governor’s office.

California wanted the interests of shareholders to be subordinate to the State’s carbon goals:

Newsom said Wirth had invested far more in shareholder payouts than in developing low-carbon energy.

Other State actions that contributed to the divorce:

  • accused Chevron and other companies of price gouging
  • accused Chevron, as a fossil fuel producer, of indirectly causing tragic fires
  • banning the sale of gasoline-powered cars by 2035
  • rules that increased gasoline prices
  • lawsuit alleging climate change deception

Not mentioned in the article are the costly challenges Chevron and others are experiencing in decommissioning offshore platforms.

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PNAS: “among the most productive marine fish habitats globally”

Secretarial Order No. 3418 identified energy policies and regulations requiring immediate Interior Dept. review. A policy decision that should be added to the list is BSEE’s Record of Decision (ROD) for the Programmatic Environmental Impact Statement on Pacific OCS Decommissioning.

Inexplicably, BSEE’s ROD designates the most environmentally harmful, unsafe, and costly alternative as the “preferred alternative.” The decision is contrary to the opinions expressed by the leading experts on the ecology of California offshore platforms, most notably Dr. Milton Love of the University of California at Santa Barbara.

Why did BSEE select alternative 1 (complete removal) when their $1.6 million EIS acknowledges that alternative 2 (partial removal) is environmentally preferable? Was their decision influenced by activists who support the alternative that is most punitive to the industry they despise?

The Interior Dept. needs to immediately review this decision so that stalled decommissioning projects can move forward in a manner that is most efficient and best protects “the most productive marine habitats per unit area in the world.”

beneath Platform Gilda, Santa Barbara Channel

On December 7, 2023, the Bureau of Safety and Environmental Enforcement (BSEE) issued a Record of Decision (ROD) recommending the full removal of California’s 23 offshore oil platforms in federal waters, following a Programmatic Environmental Impact Statement (PEIS) conducted to assess decommissioning options for platforms, pipelines, and other related infrastructure. However, upon close review, the PEIS and ROD appear to have reached misguided and detrimental conclusions due to critical oversights in their analyses.” Asher Radziner, Montecito Journal

More posts on California decommissioning

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