The CBD had challenged an April 2025 BOEM decision concludingthat Sable was not required to revise its development and production plan for the SYU. They sought a court order requiring a revised plan. This suit seemed to be a stretch, so its dismissal is not a surprise.
Per the Dept. of Justice, the court dismissed the lawsuit because the plaintiffs’ asserted procedural injury had no basis in the statute, was not traceable to any action by BOEM, and could not be redressed by an order of the court.(Other than that, it was just fine. 😉)
Among other problems the court identified with the plaintiffs’ case, they invoked a provision of the statute that governs “approval of a development and production plan,” not revision of an already-existing plan. It will be interesting to see the full decision so that we can better understand the context for that statement. Distinguishing revised plans in that manner could have significant policy implications.
For a full update on Sable litigation, see the section of their Quarterly Report beginning on p. 12.
BSEE (2020) estimates the cost of decommissioning these facilities to be $85 million (too low), and there is no collateral or third party guarantee.
The responsibility for decommissioning these platforms has yet to be settled. ConocoPhillips, Oxy, and Devon have appealed decommissioning orders from BSEE. The Interior Board of Land Appeals (IBLA) has yet to rule on those appeals. The appellants are funding some plugging operations and facility upgrades pending the IBLA decision.
Per BSEE’s borehole file, this is the current status of the Hogan and Houchin wells:
33 completed and not yet plugged; these wells were drilled between 1968 and 2010
43 temporarily abandoned (TA) wells plugged in accordance with 30 CFR § 250.1721
10 wells have been updated to TA status in the past 6 months (latest 3/22/2026), so some progress is being made
If you are interested in the Hogan/Houchin mess or decommissioning liability in general, I highly recommend that you look at Devon’s informative and rather compelling appeal to IBLA. Similar appeals were submitted by Oxy and ConocoPhillips.
Lease history (excerpted from the Devon appeal):
Lease OCS-P 0166 was issued effective January 1, 1967.
Phillips Petroleum Company (“Phillips”) (predecessor to ConocoPhillips), Cities Service Oil Company (predecessor to Oxy), and Continental Oil Company (predecessor to ConocoPhillips) were the initial lessees
Phillips was designated operator on January 25, 1967
February 28, 1983: Petro-Lewis Funds, Inc., obtained the 37.5% interest of the Continental Oil Company (which in 1979 had changed its name to Conoco Inc., now Conoco Phillips Company (“ConocoPhilips”)).
November 1983: Cities Service Oil Company assigned its 37.5% interest to Cities Service Oil and Gas Corporation (now OXY U.S.A. Inc).
July 2, 1987: the Minerals Management Service (“MMS”) approved two more assignments of the Lease. One, from PetroLewis Funds, Inc. to American Royalty Producing Company (“American Royalty”), was approved retroactively to December 31, 1984. The other, from American Royalty to Santa Fe Energy Company(“Santa Fe”), was approved retroactively to April 30, 1987.
April 1, 1988: Santa Fe transferred a 3.75% interest to Maersk Energy Incorporated, reducing Santa Fe’s share to 33.75%.
1991 Assignment to Signal Hill: MMS approved assignment of the lease to Signal Hill effective February 5, 1991. The assignment was approved without any provision under which the assignors agreed to be liable for decommissioning operations on the lease. MMS’s approval actually had the opposite effect, leaving such obligations to the assignee. The assignment was approved despite concerns within the MMS about the financial strength of Signal Hill and the technical competence of Pacific Operators Offshore Inc (POOI), the affiliate that would operate the facilities.
Comments:
The assignment to Signal Hill should have never been approved. The outcome was predictable.
The Devon, Oxy, and ConocoPhillips appeals are very strong and would seem to have a good chance of success. Perhaps that is why the IBLA decision is taking so long (nearly 5 years to date).
Given the uncertainty regarding this appeal, the absence of transparency about other potential decommissioning liabilities, and the uncertainties regarding the administration of predecessor liability, this is not the time to be relaxing financial assurance requirements and further exposing taxpayers to decommissioning risks.
This is the final day to comment on BOEM’s proposal:
The Platform Habitat fire was extinguished at 11:40 a.m. on 5/11/2026 after burning for 5 hours.
All 26 workers were safely evacuated from DCOR’s Platform Habitat. The big question now is the fitness of the structure for continuing well plugging/abandonment and platform decommissioning.
As indicated in the attached letter, BSEE had informed DCOR that their Pitas Point Unit leases (where Platform Habitat is located) expired on 3/15/2016 owing to the cessation of well operations 6 months prior. Following the Interior Board of Land Appeals (IBLA) May 7, 2021 affirmation of BSEE’s directive, DCOR was notified that they must permanently plug all wells within one year of the lease termination (i.e. one year after the 2021 IBLA decision). I’ll include the informative IBLA decision in a future post.
Although details have not been shared, it appears that well plugging operations were still ongoing on 5/11/2026 when the fire occurred. According to BSEE’s borehole file, most of the Habitat wells have been temporarily abandoned, but few have been permanently abandoned, and several are still completed (i.e. neither temporarily nor permanently abandoned).
The risks and costs associated with delaying well plugging and abandonment have once again been demonstratedat Habitat. Fortunately, there were no casualties or pollution.
With regard to overall safety compliance, DCOR is the violations leader in the Pacific Region. In 2025 and 2026 (YTD) they were cited for 70 violations, 66 of which required component or facility shut-ins. The age of the 9 DCOR platforms (installed by others between 1968 and 1984) has likely contributed to the compliance challenges.
BSEE spreadsheets for 2020-2024 show 6 incidents at Platform Habitat. BSEE’s incident summaries are pasted in the second attachment.
Neither DCOR nor BSEE has issued a statement on the Habitat fire.
The oil and gas industry is crucial for Norway and for Europe. The government is today announcing new exploration areas in the APA (Allocations in Predefined Areas) to further develop the petroleum sector, so that it can continue to create great value for the community, lay the foundation for good jobs throughout the country, ensure our common welfare and contribute to Europe’s energy security and safety, says Prime Minister Jonas Gahr Støre.
Kudos to Norway for the strong, unequivocal announcement. Consistent acreage offerings are important in sustaining offshore production:
Allocations in Predefined Areas (APA) are an annual licensing round that covers the best-known exploration areas on the continental shelf. Through the APA scheme, oil companies gain predictability regarding access to exploration acreage, which is important for a long-term industry such as the petroleum industry. After more than 50 years of exploration activity, the APA scheme today covers the majority of the area that is opened and available on the Norwegian continental shelf.
California Attorney General Bonta asks the Court to stay Energy Secretary Wright’s Order directing Sable, under the Defense Production Act to restart production and preliminarily enjoin Defendants, and all those acting in concert with Defendants (i.e. Sable), from enforcing or relying on it. See the attached Federal Court filing.
The AG’s irreparable harm and public interest arguments seem particularly weak, and this may not be the best time to attempt to halt a 20+% increase in California oil production.
Attached are my comments on BOEM’s proposed revisions to the decommissioning financial assurance regulations. These comments were submitted to Regulations.gov yesterday (3 days early 😀). Bud
Concluding Remarks
MMA’s highest priority must be assuring that facilities are safely decommissioned without public funding. Supplemental financial assurance determinations and lease assignment approvals must be consistent with that priority.
Predecessor liability is an important financial assurance principle, but legal boundaries and administrative procedures must be clearly established.
Safety and compliance are inextricably related to financial performance, and must be considered in determining supplemental assurance requirements.
Using reserve estimates to reduce supplemental assurance exposes taxpayers to geologic and accounting risks.
Unacceptable public risks have resulted from financial assurance decisions intended to advance offshore wind development.
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.
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.
Equinor has cut planned investments in renewable energy by roughly EUR 3.5bn for 2026–2027, while the company maintains and expects growth in oil and gas production.
Perhaps the premium for climate virtue signaling has shrunk, and Equinor, like other energy giants, is making a prudent business decision for its shareholders, which include the Norwegian govt.
Meanwhile, what are the implications for Equinor’s offshore wind investments in the US? Equinor’s embattled Empire Wind project is probably too far along to reverse course. Their Central Atlantic (Lease 0557) and California (Lease 0563, Atlas Wind) may be a different story. However, buyback negotiations would be complicated by the Empire Wind situation, and perhaps by the Norwegian government’s 2/3 ownership. On the other hand, Equinor is a significant oil and gas leaseholder in the Gulf of America, so they would have ample options for investing wind lease rebates.
Bud's Offshore Energy (BOE) 
My comments on BOEM’s proposed revisions to decommissioning financial assurance requirements
Posted in California, decommissioning, energy policy, Gulf of Mexico, Offshore Energy - General, Regulation, tagged BOEM, comments, decommissioning, financial assurance, predecessor liability, proposed regulation, reserve estimates, safety and compliance on May 6, 2026| 1 Comment »
Attached are my comments on BOEM’s proposed revisions to the decommissioning financial assurance regulations. These comments were submitted to Regulations.gov yesterday (3 days early 😀). Bud
Concluding Remarks
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