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Archive for the ‘energy policy’ Category

A long-time colleague is very familiar with Judge Lamberth, a Reagan appointee, and thinks highly of him. Orsted has a lease contract, and no matter where you stand on offshore wind, you have to have a compelling case to halt a project that is in the advanced stages of development. Judge Lamberth ruled that the govt doesn’t have such a case. Per the judge:

  • The govt presented insufficient evidence to support alleged permit noncompliance and national security concerns.
  • The govt acted in an “arbitrary and capricious” manner.
  • “If Revolution Wind cannot meet benchmark deadlines, the entire project could collapse.”
  • “There is no doubt in my mind of irreparable harm to the plaintiffs.”

Projects under development will be difficult to pause or stop. The Administration should focus on requiring sufficient decommissioning financial assurance, monitoring and mitigating project impacts, making incident data publicly available, issuing the report on the Vineyard Wind blade failure (finally!), and improving the availability of dispatchable power (i.e. natural gas and nuclear).

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Judge Royce Lamberth granted an injunction allowing Orsted to resume work on the Revolution Wind project. BOEM halted work on the project one month ago.

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Gov. Newsom and Danish Foreign Minister Lars Løkke Rasmussen

As is the case for most MOUs, the attached 8/22/2025 agreement between California and Denmark is long on promotion and short on substance. No funds are obligated and there are no work commitments.

The MOU made sense for Gov. Newsom in that he strengthened his green credentials by aligning with the country that is the spiritual leader for climate activists.

The benefits for Denmark were unclear, but the risks should have been apparent. The White House is fundamentally opposed to the climate and energy objectives identified in the MOU. Ørsted (50.1% govt owned) and other Danish business interests are very much dependent on decisions made by the US Federal govt.

Work on Ørsted’s Revolution Wind project has been halted by Interior Secretary Burgum. His decision is being challenged in court, but no matter what the outcome, offshore wind development will be difficult for Ørsted and other foreign companies going forward. The Secretary has broad regulatory authority under the OCS Lands Act, under which there is no such thing as “a fully permitted project.”

Meanwhile, California’s green status has taken a hit with the passage of S 237, which pragmatically authorizes new onshore drilling.

Lastly, as the chart below illustrates, Orsted’s problems didn’t begin in 2025.

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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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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.

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What’s next for Sable Offshore?

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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

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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.

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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. ☹

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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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