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Archive for the ‘Regulation’ Category

Cox legacy facilities continued to have high violation rates in 2025

Posted in Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , , , , , , on February 12, 2026| 1 Comment »

On February 12, 2024, the bankruptcy court approved the sale of certain Cox Operating assets to Natural Resources Worldwide LLC (NRW), a company that had no prior offshore experience. NRW contracted with Array Petroleum to operate 154 Cox legacy platforms (per BOEM data). NRW is listed as the operator of just one platform.

In 2025, NRW/Array operations accounted for 486 incidents of non-compliance (INCs), 36.2% of the Gulf of America total. Array and NRW had INC/facility inspection rates of 2.1 and 7.0 respectively, well above the Gulf average of 0.42 and the top performers’ rates of 0.05 to 0.13.

In Array’s defense, their violations declined sharply in the second half of 2025. However, the number of inspections of their facilities declined even more sharply, so the INCs/facility inspection ratio actually increased in the second half.

For the 2025 data in the table below:W=warning, CSI=component shut-in, FSI=facility shut-in. The 3 numbers for Array in each box are full year 2025 data (top), first half 2025 (middle), and second half 2025 (bottom)

operatorWCSI
FSI
total INCs
Facility
Insp.
INCs/isp
Array352
311
41		93
46
47		6
6
0		451
363
88		218
184
34		2.1
2.0
2.6
NRW102413557.0

Three other companies had more than 10 shelf platforms and INC/facility inspection ratios >1.0: Greyhound Energy (23 platforms), Renaissance (21 platforms) and Sanare Energy (38 platforms).

operatorWCSIFSItotal INCs
facility insp
INCs/
fac.
insp
Greyhound Energy321033231.4
Renaissance Offshore2619347441.1
Sanare Energy6020282751.1

The table below provides 2025 oil and gas production through Oct (with Gulf of America rank) for the 5 companies mentioned in this post. In determining rankings, subsidiaries and affiliates were counted as a single company (e.g. Chevron, Unocal, and Hess counted as one company).

oil (bbls)oil rankgas (MCF)gas rank
Renaissance729,904191,220,43319
Array416,267211,197,91520
Sanare246,845251,763,55218
Greyhound182,65827280,42326
NRW101,11029104,02530

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John Smith: “Sable Remains Mired in a Cobweb of Lawsuits – Can it Survive?”

Posted in California, energy policy, Offshore Energy - General, pipelines, Regulation, tagged , , , on February 10, 2026| 1 Comment »

Attached is John Smith’s updated Sable litigation table. John is a BOEM retiree who has been closely monitoring Sable’s legal and regulatory challenges. His summary:

“Sable Offshore Corp. is involved either directly or indirectly in no less than 12 lawsuits that have been filed by environmental groups, state and county regulatory agencies, and the Attorney General of California, all of whom are committed to stopping Sable from restarting Santa Ynez Unit (SYU) oil and gas production. All of the lawsuits are active and many are likely to result in prolonged judicial proceedings extending over several years. Will Sable have the will and financial resources to continue these legal battles indefinitely? – that’s a multi-million dollar question.”

Table Sable Litigation Summary JBS 020926Download

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2025 Safety Compliance – Shell tops the Gulf of America performance list

Posted in Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , , , , , , , , , , on February 5, 2026| Leave a Comment »

The 2025 Gulf of America Safety Compliance Leaders are ranked below according to the number of incidents of non-compliance (INCs) per facility inspection. To be ranked, a company must:

  • operate at least 2 production platforms
  • have drilled at least 2 wells during the year
  • average <1 INC for every 5 facility inspections (0.20 INCs/facility inspection). This is a higher standard (fewer INCs) than in previous years.
  • average <1 INC for every 10 inspections (0.1 INCs/inspection). Note that each facility inspection may include multiple types of inspections (e.g. production, pipeline, pollution, Coast Guard, site security, etc). In 2025, there were on average 3.2 inspections for every facility inspection.
operatorWCSIFSItotal INCsfacility inspINCs/
fac insp		inspINCs/
insp
Shell381122310.055570.02
Chevron1080182600.077720.02
Oxy26191330.073250.03
BP820101220.083040.03
Murphy6208700.111770.05
Cantium574161210.134880.03
Gulf-wide 202581544584134431790.42102180.13
Gulf-wide 2024957398109146431330.47106640.14
Notes: Numbers are from published BSEE data; INC=incident of non-compliance; W=warning INC; CSI=component shut-in INC; FSI=facility shut-in INC; INCs/fac insp= INCs issued per facility inspection; each facility-inspection may include multiple types of inspections (e.g. production, pipeline, pollution, Coast Guard, site security, etc), in 2025, there were on average 3.2 inspections for every facility inspection

Criteria: This ranking is based solely on BSEE’s published compliance data. The absence of timely public information on safety incidents (e.g. injuries, fires, pollution, gas releases, property damage) precludes inclusion of these data. Although Panel Investigations are conducted for fatalities, serious injuries, and significant pollution events, the last panel report was for an incident on 3/25/2022, and no information is available for any ongoing investigations. BSEE District offices investigate the more significant incidents that don’t qualify for panel investigations. These District Investigation reports are more timely, but some are not issued within 90 days of the incident. The District reports will be reviewed later in the year. Note that there were no occupational fatalities in 2025.

Observations:

  • The overall inspection and INC results for 2025 were similar to those for 2024.
  • The top companies performed better in 2025 than in 2024. In 2024, only 2 companies had INC/facility inspection ratios of <0.10 and only 3 had ratios <0.15. In 2025, all 6 of the performance leaders had ratios <0.15.
  • All 6 of these top companies were also on the 2024 top performers list.
  • Shell’s total INCs and INCs/facility inspection decreased by 73% and 78% respectively vs. 2024
  • Cantium, which operates 85 shallow water platforms, has demonstrated that a shelf operator can be an outstanding safety performer. Cantium’s total INCs and INCs/facility inspection decreased by 50% vs. 2024
  • Should fewer inspections be conducted at facilities that have such low INC rates? On the one hand, fewer inspections would reduce regulatory costs and transportation risks. On the other hand, there are benefits from BSEE inspection visits besides compliance enforcement. These include direct communication with offshore workers (including contractors) regarding regulatory policies and safety practices, witnessing safety tests, evaluating new technology, and assessing management system implementation and corporate culture at the facility level.
  • Absent specific details on the violations, no attempt was made to weight the INCs. Although shut-in INCs are generally considered to be more significant than warnings, that is not always the case. For example, a component shut-in INC for a safety device that is marginally out of tolerance and is corrected on the spot may be less serious than a warning that is indicative of structural deterioration, poor maintenance, or organizational shortcomings.

Not meeting one of the activity level requirements, but nonetheless noteworthy, were the compliance records of LLOG and BOE Exploration & Production (younger than and unrelated to the BOE blog 😀). See their impressive results below:

operatorWCSIFSItotal INCsfacility inspINCs/
fac insp		inspINCs/
insp
BOE0011330.03780.01
LLOG1113290.10780.04

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Six Gulf of America operators had outstanding safety compliance records in 2025

Posted in Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , , , , , , , on February 4, 2026| Leave a Comment »

Shell topped the list followed by Chevron, Oxy/Anadarko, bp, Murphy, and Cantium.

Details and observations will be posted tomorrow.

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Santa Ynez Unit production: an OS&T is not the solution!

Posted in California, energy policy, Offshore Energy - General, Regulation, tagged , , , , , on February 4, 2026| 1 Comment »

Back to the future? Santa Ynez Unit OS&T – 1981-1994

Pasted below are excerpts from Sable’s Prospectus Supplement. Is Sable serious about pursuing a Santa Ynez Unit strategy that employs a production and treatment vessel 3.5 miles from shore ala the development option that was reluctantly approved by the Federal govt in 1974, two decades before the onshore infrastructure was in place?

The OS&T option is inferior to onshore treatment and pipeline transportation in every way – spill risks, air emissions, economics, ultimate oil recovery, transportation to market, natural gas utilization, and public benefit.

This blogger supports a resumption of Santa Ynez Unit production. However, the only responsible path forward is to do the right thing and continue to pursue the onshore pipeline approvals administratively and legally. It is far better to defend a good project than a contrived workaround. 

When will BOEM share Sable’s proposed “update”(actually a massive revision) to the SYU Development and Production Plan, as they are obligated to do?

Evaluation of the revised plan will require a detailed environmental review.

Operationally, BSEE and the Coast Guard will need to carefully consider vessel integrity, treatment capabilities, mooring and offloading plans, transportation schemes, gas utilization/injection, and many other technical details.

Meanwhile, does Exxon, the previous (and future?) owner, remain on the sidelines when the OS&T permitting circus begins in earnest?

Excerpts from Sable’s Prospectus Supplement (emphasis added):

On September 29, 2025, Sable announced that it is evaluating and pursuing an offshore storage and treating vessel (“OS&T”) strategy to provide access to domestic and global markets via shuttle tankers for federal crude oil produced from the SYU in the Pacific Outer Continental Shelf Area (the “OS&T Strategy”). Continued delays related to the Santa Ynez Pipeline System have prompted Sable to evaluate and pursue the OS&T Strategy. On October 9, 2025, Sable submitted a Development and Production Plan update for the SYU to the Bureau of Ocean Energy Management (“BOEM”). Prior to implementation of the OS&T Strategy, regulatory authorizations are required, including clearance from BOEM.

Preparations for the OS&T Strategy include the acquisition of a suitable OS&T vessel, certain refitting and upgrades to the vessel and the SYU equipment, transportation of the vessel to SYU, and related installation. In connection with implementation of the OS&T Strategy, the Company expects to opportunistically acquire an existing OS&T in the first quarter of 2026, with delivery of the vessel to SYU expected in the third quarter of 2026. Following the acquisition of the vessel, and vessel and platform upgrades and installation, Sable would expect to begin sales from all SYU platforms in the fourth quarter of 2026, with expected comprehensive oil production rates of over 50,000 barrels of oil per day, utilizing the OS&T within the SYU federal leases, provided the Company receives regulatory clearances. Sable estimates that the total capital required to execute the OS&T Strategy is approximately $475.0 million. The Company has already incurred a small portion of such capital expenditures, with the vast majority of such capital expenditures remaining, provided the Company receives regulatory clearances. See “Risk Factors—Risks Associated with Our Operations—In order to commence operations pursuant to an OS&T offtake strategy, we will require clearances and permitting, including from BOEM.”

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Coming next week: 2025 Gulf of America Safety Compliance Leaders

Posted in accidents, Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , , , on January 30, 2026| Leave a Comment »

Next week, BOE will rank the 2025 Gulf of America Safety Compliance Leaders according to the number of incidents of non-compliance (INCs) per facility inspection.

Last year’s results.

How is your company’s safety culture?

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California sues Federal govt over PHMSA pipeline orders

Posted in California, Regulation, pipelines, tagged , , , , , , on January 26, 2026| Leave a Comment »

The State has asked the 9th Circuit Court of Appeals to set aside these three PHMSA orders:

  • PHMSA order to assume exclusive jurisdiction over the Los Flores Canyon pipelines
  • PHMSA order approving the restart plan for those pipelines
  • PHMSA order issuance of an Emergency Special Permit to Sable Offshore

In light of the venue and the clear language in the 2015 Consent Decree regarding the California Fire Marshal’s jurisdiction, the State’s petition would seem to have a good chance of success.

CA sues FedDownload

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Hunterbrook – “Zombie Pipeline: Why Sable is Still a Pipe Dream”

Posted in California, energy policy, Offshore Energy - General, Regulation, tagged , , , , , on January 26, 2026| Leave a Comment »

Updated Hunterbrook Media summary of Sable’s prospects for restarting Santa Ynez Unit production:

“Exxon spinoff Sable Offshore faces seven barriers to restart its pipeline, idled since a major oil spill in 2015. One of those approvals needs to come from the California Coastal Commission, which Sable CEO Jim Flores criticized for its “Teflon” “eco-Nazi attitude” in a leaked call recording newly obtained by Hunterbrook. Because of these barriers — and despite Trump Administration intervention — Sable’s project, originally scheduled to go online in Jan 2024, may never sell oil. At least not under the ownership of Sable ($SOC), which is quickly running out of cash.“

Exxon’s options per Hunterbrook:

The Exxon purchase agreement gives Exxon a free reassignment option: If Sable fails to “restart production” by Mar. 31, Exxon can demand reassignment of the assets within 180 days, “without reimbursement of any Purchaser costs or expenditures.” 

In other words: Exxon can just take back the asset. For free.

And if Sable’s regulatory pathway is really just delayed, not denied — as Sable claims — that may be a more appealing proposition for Exxon than it once was.

Or, perhaps, Exxon will decide to retire the project, recognizing the Sisyphean path to production. (Exxon already took a $2.5 billion write-down as part of exiting offshore operations in California.)

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TMC files the first consolidated deepsea minerals application

Posted in deep sea mining, energy policy, Regulation, tagged , , , , , on January 23, 2026| Leave a Comment »

The Metals Company has filed the first consolidated application for an exploration license and commercial recovery permit under NOAA’s new regulations.

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Positive step for deepsea mining – revised NOAA regulations are now final

Posted in deep sea mining, energy policy, Regulation, tagged , , , , , , , on January 23, 2026| Leave a Comment »

Remotely operated vehicle traverses over an extensive field of ferromanganese nodules that form the bulk of the hard seafloor substrate. Credit: NOAA.

Links to final rule and post about the draft rule

“The objective of this rule is to provide the option for a consolidated application streamlining the process for qualified applicants.”

Reflecting on advances in environmental science, seafloor mapping, and offshore mineral-collection technologies, the revised rule allows qualified companies that gather the necessary site information to proceed to the collection phase. Deepsea mining is now more closely aligned with offshore oil and gas in that companies acquiring licenses are able to proceed to production after regulatory approvals.

The preamble nicely summarizes the opposition to the rule for environmental and jurisdictional reasons:

“General opposition to deep seabed mining was expressed for a variety of stated reasons, including, but not limited to the following assertions: effects on the environment; effects on seabed habitat and to marine species including undiscovered species especially in the Clarion-Clipperton Fracture Zone; harm to cultural resources and Pacific Islander livelihoods and beliefs; inadequate scientific research and information; inadequate resource protection measures and regulations; uncertainties regarding environmental impacts and a nascent industry; significant technical challenges to deep seabed mining; opposition to deep seabed mining from many U.S. states, countries, and global companies; that deep seabed mining is contrary to international agreements and efforts; the need for moratoria; that deep seabed minerals are not needed to meet U.S. demand for critical minerals and domestic sources and recycling of such minerals should be used instead; the U.S. needs to focus on building domestic refineries; using renewable and alternative resources rather than deep-sea minerals; and jeopardizing vital carbon sinks.”

“Commenters stated that acting unilaterally on deep seabed mining undermines the ISA (International Seabed Authority) process, international norms, global stability, and the rule of law, and that it could result in harm to protected areas, such as Areas of Particular Environmental Interest designated by the ISA.”

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