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Comments on BSEE’s downhole commingling rule

Posted in energy policy, Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , , , , , , on September 18, 2025| Leave a Comment »

The table below captures the shorter public comments and provides links to the longer ones. They are listed in the order they were posted on Regulations.gov.

commentersummary/link
anonymousI recommend under no circumstance that we allow the onsite worker to approve the commingling of bore holes because there is extreme significant safety and environmental hazards that exist.
The best alternative is to have an environmental engineer and environmental scientist approve any commingling
Our Children’s Trust…your regulatory proposal is inconsistent with the federal law, the best available science on protecting the health and lives of children, and the legal mandate that agency decision-making does not deprive children of their fundamental constitutional rights…
E.P. DanenbergerSee BOE post
anonymousI support updating the regulations to align with the One Big Beautiful Bill Act, but I encourage BSEE to ensure that safety standards and environmental protections remain the highest priority in all commingling approvals. Clear guidance for industry compliance and transparent public reporting would also strengthen confidence in this rule.
Ananda FosterRegulations need to catch up with technology and we have not had a chance to do that yet. If you allow them on throttle access, they will destroy it. We all rely on the ocean, how can you do this to your own constituents?
APISupports direct final rule
bp AmericaSupports direct final rule

Legislatively dictating well construction, completion, or operational approvals is a redline for me, and I continue to strongly believe the downhole commingling rule should be published as a draft for public review and comment.

The only industry comments are from API and bp America. Both support the direct final rule, and I respect their position. My main quarrel is with the legislative action that put us in this position.

I have had many disagreements with API members over the years, but the dialogue has always been professional. Technical and policy disagreements are healthy for the OCS program, and I will continue to raise potential issues and concerns on this blog.

With regard to bp, I have been impressed by their commitment to the Gulf of America, as summarized in this excerpt from their comments:

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California delegation challenges BSEE’s SYU production announcement

Posted in California, energy policy, Offshore Energy - General, Regulation, tagged , , , on September 17, 2025| Leave a Comment »

John Smith shared the attached letter from Senators Adam Schiff and Alex Padilla, and members of the California congressional delegation. The letter questions BSEE’s inexplicable announcement about the resumption of Santa Ynez Unit (SYU) production. That announcement boasted:

“This is a significant achievement for the Interior Department and aligns with the Administration’s Energy Dominance initiative, as it successfully resumed production in just five months.“

BSEE’s announcement, which has not been explained and is still featured on their homepage, served only to further complicate the resumption of production from the SYU, which has reserves in excess of 500 million barrels.

Schiff-BSEE-Sable-letter-final 091525Download

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SB 237 passes easily

Posted in California, energy policy, Offshore Energy - General, Regulation, tagged , , , on September 14, 2025| Leave a Comment »

What’s next for Sable Offshore?

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Newsom’s California compromise sacrifices the SYU (Sable) to boost Kern County drilling.

Posted in California, drilling, energy policy, Offshore Energy - General, tagged , , , , , , , on September 12, 2025| Leave a Comment »

California Senate Bill 237, the compromise oil legislation supported by Gov. Newsom, Assembly Speaker Rivas, and Senate President McGuire, opens up Kern Co. drilling in exchange for pipeline safety measures that will doom the Santa Ynez Unit (SYU) if Sable fails to restart production by Jan. 1.

Particularly intriguing is the the list (below) of SB 237 supporters and opponents. The Western States Petroleum Assoc. (WSPA), is aligned with the unions for onshore drilling and against the SYU. Note that Exxon is a prominent WSPA members! Exxon assigned the SYU to Sable and is on the hook for massive decommissioning costs if production is not resumed. Perhaps Exxon has a backup plan for the SYU?

Also note that all of the environmental groups are aligned against SB 237. Compromise is not in their playbook.

John Smith’s highlighted summary of SB 237 is attached. Here is the provision that would seem to doom Sable:

Clarifies in the Coastal Act that development associated with the repair, reactivation, or maintenance of an oil pipeline that has been idled, inactive, or out of service for five years or more requires a new CDP, as provided.

REGISTERED SUPPORT / OPPOSITION:
Support
Associated Builders and Contractors of California
Berry Petroleum Company, LLC
California Conference of Carpenters
California Independent Petroleum Association
California Resources Corporation and Subsidiaries
California state Pipe Trades Council
California State Association of Electrical Workers
City of Bakersfield
Consumer Watchdog
County of Kern
State Building & Construction Trades Council of California
Western States Petroleum Association

Opposition
Asian Pacific Environmental Network Action
California Environmental Justice Alliance Action
California Environmental Voters
Campaign for a Safe and Healthy California

Center for Biological Diversity
Center on Race, Poverty & the Environment
Central California Environmental Justice Network
Clean Water Action
Climate First: Replacing Oil & Gas
Communities for a Better Environment
Earthjustice
Leadership Council for Justice and Accountability
Physicians for Social Responsibility Los Angeles

Senate Bill 237 Summary (1)Download

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Will California Assembly Bill 1448 doom Sable and the Santa Ynez Unit?

Posted in California, energy policy, Offshore Energy - General, pipelines, Regulation, tagged , , , , , on September 12, 2025| Leave a Comment »

John Smith has highlighted the attached bill that could, if passed, further derail Sable’s plans to restart Santa Ynez Unit (SYU) production.

This provision appears to target Sable:

Section 3(b)(2): Repair, reactivation, and maintenance of an oil and gas facility facility, including an oil pipeline, that has been idled, inactive, or out of service for five years or more shall be considered a new or expanded development requiring a new coastal development permit consistent with this section.

The legislation would be effective on 1/1/2026 so perhaps Sable will already be producing. Sable may also explore the jurisdictional and interstate commerce issues touched on in this post.

This LA Times update adds to the confusion as to the implications for Sable.

AB 1448Download

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Comments on BSEE’s downhole commingling rule

Posted in energy policy, Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , , , , on September 9, 2025| Leave a Comment »

The attached comments were submitted to Regulations.gov on 9/8/2025.

Legislatively dictating downhole commingling approvals, as per Section 50102 of the One Big Beautiful Bill, is a reckless precedent from both technical and regulatory policy standpoints. 

This type of legislative maneuver compromises the integrity of the OCS oil and gas program and the companies that participate in it. Shaving the maximum royalty rate was one thing; mandating well completion approvals is quite something else. Disappointing. ☹

BSEE Direct Final Rule, Offshore Downhole ComminglingDownload

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JL reminisces about the Wood Group

Posted in energy policy, Offshore Energy - General, UK, tagged , , , , , , on September 5, 2025| Leave a Comment »

In 1991 Wood Group Production Technology (WGPT) received the Queen’s award for engineering innovation.

JL Daeschler, a pioneering subsea engineer who lives in Scotland, is saddened by the sale of the famous Wood Group engineering firm. After difficult financial losses, the Wood Group, headquartered in Aberdeen, has been sold at a cut-price to a Dubai based group.

Per JL: I knew Ian in the early North Sea development stage. He became Sir Ian Wood. We used to chat at various conferences in Houston, Stavanger, and Aberdeen. Ian was an energetic man, who had a friendly approach to our North Sea challenges. He was a true Aberdonian entrepreneur who employed 1000’s in offshore related disciplines worldwide.
The crystal glass above was a gift by a University student I sponsored who later worked for the Wood group. In 1991 Wood Group Production Technology (WGPT) received the Queen’s award for engineering innovation. We worked closely on the development of down hole pressure censors and temperature gauges in the 1980’s.

JL reports that oil & gas is a hot subject in Scotland, but political commentary dwarfs technical discussion. To fix the economy, the govt should look at where people are struggling, and energy costs are their no. 1 concern.

While some politicians are belatedly vowing to maximize North Sea production, that will be difficult given the loss of operators, rigs, ships, installation and pipeline vessels, shipyards, and experienced workers. The infrastructure in Aberdeen is back to 1970 levels, and it’s difficult to build back what has been destroyed.

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Are New England Wind 1 and 2 COP approvals next on the chopping block? It appears so.

Posted in energy policy, Offshore Wind, Regulation, tagged , , , , on September 4, 2025| Leave a Comment »

See below. BOEM is reconsidering its approval of the Construction and Operations Plan (COP) for New England Wind 1 and 2. The operator, Avangrid (Spain), is also a partner in the troubled Vineyard Wind project.

If you are keeping score, the approval of these COPs is being reconsidered:

Other projects: Work has been stopped on the Revolution Wind project. Work was previously halted on the Vineyard Wind and Empire Wind projects, but has been allowed to resume. BSEE has still not published its report on the Vineyard Wind turbine blade failure that occurred on 7/13/2024. Other projects have been suspended by the owners at their own initiative (e.g. Atlantic Shores South, Gulf of Maine, Starboard Wind, Vineyard Wind 2, Beacon Wind). Meanwhile, litigation abounds!

Coastal Virginia Offshore Wind is the project with the most assured long-term future.

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Only 10 active rigs in the Gulf of America

Posted in drilling, energy policy, Gulf of Mexico, Offshore Energy - General, tagged , , , , , , , , , , , on September 3, 2025| Leave a Comment »

Deepwater Titan, Gulf of America

The latest Baker Hughes Rig Count Report shows only 10 rigs actively drilling in the Gulf. All are at deepwater locations – 7 in the Mississippi Canyon area, 2 in Green Canyon, and 1 in Alaminos Canyon. Per the BSEE borehole file, Shell accounts for most of the current MS Canyon wells and the Alaminous Canyon well. Beacon is also drilling in the MS Canyon, and the Green Canyon well appears to be a Chevron operation.

This current rig count, which has hovered between 9 and 12 all year, is troubling if you are concerned about long-term production. By comparison the Gulf rig count reached 22 last year and was 100+ during the 10 year period from 1994 to 2003.

Only Anadarko/Oxy, Beacon/BOE, BP, Chevron/Hess, Shell, and Talos have spudded deepwater exploratory wells in 2025 YTD. Arena and Cantium are the only shelf drillers – all development wells.

Technological advances and extensions of past discoveries have sustained Gulf production, but declines are certain over the longer term if drilling activity doesn’t increase. Oil price uncertainty is an issue, but that’s always the case. Semiannual lease sales are now legislatively required and the terms will be attractive, so those issues are off the table. Let’s see what the bidding looks like at the upcoming sale.

The decline in deepwater discoveries (BOEM data below) is particularly discouraging. Per BOEM, the last deepwater field discovery was in March 2023.

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Court filing points to likely reversal of SouthCoast Wind COP approval (ala Maryland Wind)

Posted in Offshore Wind, Regulation, energy policy, tagged , , , , , , on September 2, 2025| Leave a Comment »

The Construction and Operations Plan (COP) for the SouthCoast Wind project was approved during the last week of the Biden Administration. That approval has been challenged by the Town and County of Nantucket. Ocean Wind, a joint venture of EDP Renewables (Portugal) and ENGIE (France), is the leaseholder.

As is the case for Maryland Wind, a court filing (attached) indicates that DOI is reconsidering the approval of the SouthCoast Wind COP. Construction has not begun on this project.

A further deferral of Federal Defendants’ responsive pleading deadline in this case is needed because Interior intends to reconsider its COP approval and will therefore be moving for a voluntary remand of that agency action by September 18, 2025.

FEDERAL DEFENDANTS MOTION TO DEFER THE DEADLINE TO RESPOND TO PLAINTIFFS COMPLAINT Southcoast Wind September 2, 2025 (PDF)Download

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