Offshore Energy – General | Bud's Offshore Energy (BOE)

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NOT a shining moment for the offshore industry

Posted in decommissioning, Gulf of Mexico, Offshore Energy - General, tagged decommissioning, Gulf of Mexico, liability, orphaned wells on October 21, 2022| Leave a Comment »

Where is the leadership? Offshore decommissioning costs should never fall on the taxpayer. See the attached notice (excerpt below) and a previous post on this topic.

BSEE intends to execute a multi-award IDIQ Quantity Contract inclusive of a Base Year and Four (4) Option Years; however, the government reserves the right to award the IDIQ contract to a single firm. Time & Material, Labor Hour, and/or firm-fixed price task orders will be awarded for Decommissioning Services necessary to take nine (9) orphaned facilities, located in the OCS of the Gulf of Mexico, to the point of Temporary Abandonment (TA). The estimated decommissioning cost for temporary abandonment is $10,000,000 to $20,000,000.

idiq_ta_decom_pre-solicitation_notice_final_10_12_22_1 Download

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Programmatic EIS for Pacific OCS platform decommissioning presents 4 alternatives, none of which are workable

Posted in California, decommissioning, Offshore Energy - General, Regulation, rigs-to-reefs, tagged alternate uses, Decommissioning EIS, Pacific, partial removal, reef program on October 20, 2022| Leave a Comment »

The 23 platforms in Federal waters offshore California are from 33 to 55 years old. Most are no longer producing and 8 are on terminated leases. Some of the platforms are massive structures in water depths up to 1200′ (list of platforms and map below).

BOEM’s draft programmatic EIS evaluates 4 decommissioning alternatives, none of which appear to be workable for a combination of economic, environmental, and legal reasons:

Alternative 1 involves the complete removal of platforms and pipelines. This alternative is cost prohibitive and environmentally unfavorable.
Alternatives 2 and 3 evaluate prudent and environmentally responsible partial removal options. Unfortunately, partial removal and reefing are not feasible under the California Resources Legacy Act (AB 2503). This legislation holds the donating company perpetually liable for any damages associated with the reef structure. While not assuming any liability, the State nonetheless collects 80% of the savings (reefing vs. complete removal). As a result, it’s no surprise that no company has applied to participate in the State’s program.
Alternative 4 calls for leaving platforms and pipelines in place after emptying tanks and flushing pipelines. This “no action” baseline alternative violates the lease agreement and 30 CFR 250.1725, and would only be permissible if an alternate use was approved for the platforms per 30 CFR Part 585.
The EIS, with minimal discussion and no supporting data, rules out alternate uses at any of the 23 platforms. This exclusion would seem to be premature given the win-win-win opportunities for industry, government (Federal, State, and local), and academia. These include deferred decommissioning liabilities, a wide range of research opportunities, security and defense applications, weather observation and climate studies, maritime communications support, education programs, marine seismicity studies, and hydrokinetic energy projects. With proper maintenance, platforms can continue to provide social benefits long after all wells are plugged and production equipment is removed. However, once removed, replacement costs would be prohibitive.
Lastly, the EIS avoids the thorny financial responsibility issues that will complicate decommissioning decisions. Note the questions raised in the “troubling case of platforms Hogan and Houchin.”
Those wishing to comment on the draft EIS should follow the posted instructions.

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Comments on BSEE’s proposed Well Control Rule are due by Nov. 14

Posted in drilling, Offshore Energy - General, Regulation, well control incidents, tagged BOP, BSEE, comments, Well Control Rule on October 18, 2022| Leave a Comment »

Comments on BSEE’s proposed revisions to the Well Control Rule are due in 27 days (by Nov. 14). Given the fundamental importance of well control to offshore safety and pollution prevention, all interested parties are encouraged to comment. Although some of the proposed revisions are rather nuanced, the document is neither long nor complex.

My completely independent comments are being drafted and will be posted here after they have been submitted to Regulations.gov.

My comments will explain why the proposal may reduce the rigor of the BOP system performance standard and will address a related shear ram issue. The comments will also discuss the management of BOP equipment failure and other safety data, the use of independent third parties and standards development organizations, dual shear rams on surface BOP stacks, ROV intervention capabilities, and BOP test data reporting and management.

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Expect this type of behavior to continue

Posted in climate, energy policy, Offshore Energy - General, UK, Uncategorized, tagged anti-oil activism, Sunflowers, Van Gogh, Vandalism on October 17, 2022| Leave a Comment »

Two supporters of Just Stop Oil have thrown soup over Vincent Van Gogh’s Sunflowers, as actions in the capital roll into the 14th day. They are demanding that the UK government halts all new oil and gas projects.
Just Stop Oil

Why these stunts will continue in Europe and N. America:

Minimal penalties for their behavior.
Publicity and contributions. (Donate buttons are the main feature of JustStopOil)
Prominent supporters and leading political figures have endorsed their message, if not their conduct.
Weak, imbalanced educational systems, particularly with regard to energy.

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OCS Wind Program: the beginning

Posted in energy policy, Offshore Energy - General, Wind Energy, tagged alternate use, Barbara Cubin, Energy Policy Act of 2005, Johnnie Burton, OCS wind, OCSLA on October 14, 2022| Leave a Comment »

The need for alternate energy/use legislation was obvious to Minerals Management Service (predecessor of BSEE and BOEM) personnel decades ago given the growing interest in renewable energy projects and the reuse of offshore platforms. Twenty years ago, MMS staff took the initiative to draft alternate use amendments to the OCS Lands Act that MMS Director Johnnie Burton and the congressional liaison office worked closely with Congresswoman Barbara Cubin of Wyoming to gain support for the amendments and they were adopted as part of the Energy Policy Act of 2005

Attached below are the talking points used by MMS in briefing congressional staff and other agencies. These talking points were spot-on and have endured the test of time.

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Does this count as a comment on BOEM’s 5 Year OCS leasing plan? It should!

Posted in energy policy, Offshore Energy - General, tagged 5 year leasing plan, BOEM, Jamie Dimon, JPMorgan on October 12, 2022| 1 Comment »

“In my view, America should have been pumping more oil and gas and it should have been supported,” Dimon told CNBC’s Julianna Tatelbaum at the JPM Techstars conference in London.

“We have a longer-term problem now, which is the world is not producing enough oil and gas to reduce coal, make the transition [to green energy], produce security for people,” he said.

“I would put it in the critical category. This should be treated almost as a matter of war at this point, nothing short of that,” he added.

“This is the chance to get our act together and to solidify the Western, free, democratic, capitalist, free people, free movements, freedom of speech, free religion for the next century,” he continued.

“Because if we don’t get this one right, that kind of chaos you can see around the world for the next 50 years.”
Jamie Dimon, CEO, JPMorgan Chase,

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Lebanon – Israel maritime boundary settlement

Posted in energy, natural gas, Offshore Energy - General, tagged Eastern Mediterranean, Israel, Karish, Lebanon, natural gas, Qana on October 11, 2022| Leave a Comment »

In a world where diplomacy seems to be lacking, it’s nice to learn that Israel and Lebanon have reached an agreement on their maritime boundary, and that both countries are satisfied. Based on press reports, it appears that the Qana gas field will fall under the control of Lebanon and that Israel will control the Karish field. Good for Lebanon, good for Israel, and good for energy!

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Well Control Rule comments

Posted in drilling, Offshore Energy - General, Regulation, tagged BOP failure data, BSEE, comments, Well Control Rule on October 11, 2022| Leave a Comment »

Hopefully, the attached response is indicative of the quality of comments BSEE will receive on their proposed WCR revisions.

The comments, which were submitted by a retired engineer (always the best commenters 😉), express the opinion that BSEE should not remove the option for submitting failure data to BTS. While my comments will express a somewhat different opinion, I thought he made good arguments in support of his position.

bsee-2022-0009-0004_attachment_1 Download

The chart below is excerpted from the SafeOCS Dashboard cited in the comment letter: