The number of BSEE inspections in 2025 (first chart) remained relatively constant despite the extended government shutdown.
The decline in the number of Incidents of Noncompliance (INCs) in 2025 is encouraging (chart 2).
Given that BSEE’s tables have yet to be updated to include 2024 incidents, let alone 2025, it’s difficult to assess whether there have been similar declines in the number and severity of incidents. We do know that there were no occupational fatalities in 2025. (Note that OCS incident tables were once updated within 30 days at the end of each quarter. The public has a right to timely information on the type of incidents that are occurring, the operating companies, and the resulting casualties, pollution, and property damage.)
Chart 3 shows the decline in INCs by type – warnings, component shut-ins, and facility shut-ins
As is typically the case, a few companies accounted for a disproportionate number of violations, most notably the Cox legacy operators. More on this in a subsequent post.
The top 6 oil producers all had excellent compliance records, as did a leading shelf operator. More to follow.
Sable Offshore, California’s most notorious operator, fared well during 77 inspections of their three platforms in the Santa Barbara Channel.
The Commission’s letter to PHMSA is attached (click on pages to enlarge). The CCC asserts the right, pursuant to the Coastal Zone Management Act, to review Sable’s restart/special permit application and further asserts that PHMSA’s special permit should be stayed pending their review.
The Commission also raises NEPA and Consent Decree compliance issues, and implies that PHMSA’s designation of the pipeline as “interstate” is subject to consistency review.
Note: In light of last night’s events, I’m re-posting this 10/13/2025 BOE post.
Nobel Peace Prize winner Maria Corina Machado wisely calls for privatizing Venezuela’s oil and gas industry, which was highly respected prior to the Chavez regime. The national oil company, Petróleos de Venezuela (PDVSA), is now a corrupt arm of the Maduro government.
“The whole Board is responsible for the loss of about 800,000 barrels per day of oil production; for the fraudulent certification of “proven oil reserves” in the Orinoco heavy oil region; for the irregular contracting, with a ghost company, of the offshore drilling barge Aban Pearl for twice the amount really paid to the owners of the barge; for the importing of 180,000 tons of food that later went to rot in Venezuelan ports but provided some of the members of the board with millions of dollars in criminal profits; and in numerous other corrupt practices that are well documented.“
Machado’s oil and gas platform is pasted below. She has a good perspective on the proper role of govt.
Privatization and reactivation of oil and gas production by attracting specialized international and national companies. Venezuela has one of the world’s largest reserves of oil and natural gas. As per the Organization of Petroleum Exporting Countries (OPEC) and the International Energy Agency (IEA), the country has reserves of over 300 billion barrels of oil and 200 trillion cubic feet of natural gas. The goal in this area is to steadily increase oil and gas production in order to leverage the window of opportunity that exists in today’s global demand for hydrocarbons. Achieving this objective will require enormous investments that the Venezuelan State cannot undertake. The solution is to attract private capital, and the strategy to achieve this end is the industry’s privatization. Where appropriate, all the industry’s productive activities will be privatized in order to secure massive private investments and a sustained increase in production, under conditions that guarantee legal certainty and an environment that is attractive for investors. The State will continue to receive fiscal income in the form of royalties and taxes, and will ensure that an operational framework exists in which private companies can increase production in the shortest possible timeframe. A Venezuelan Energy and Petroleum Agency will be established to exercise the role of industry regulator. Oil privatization will allow Venezuela to regain its position as a safe and reliable supplier, and will provide unparalleled investment opportunities in the industry.
Attached is the supplemental complaint in the lawsuit Revolution Wind, LLC v. United States Department of the Interior, Case No. 1:25-cv-02999-RCL, filed in the U.S. District Court for the District of Columbia.
The December 28 court ruling is consistent with the Department of the Interior’s position that the TRO request be converted to a request for a preliminary injunction. Interior had argued that a preliminary injunction motion could likely be resolved by mid-to-late-January.
The Government also asserted that more time is needed to submit the classified information that is central to the dispute.
Thoughts on this case: A respected colleague recalled this advice from Don Hodel, a widely admired Secretary of the Interior during the Reagan administration: “For all its faults, a contract is a contract, great men and great nations keep their word.”
Another colleague reminded me of the offshore North Carolina oil and gas leases that were suspended in the 1990s. The companies sued the Federal government for breach of contract, and the U.S. Supreme Court ruled 8-1 on June 26, 2000, in Mobil Oil Exploration & Producing Southeast Inc. v. United States, that the government must repay the lessees.
If the suspended Atlantic wind leases are cancelled, the govt would presumably have to compensate lessees for lease purchase and development expenditures. The costs to the Federal govt would be enormous – in the tens of $billions.
All eyes are on the 9th Circuit. No injunction yet. Will the Court intervene to block Sable?
No evidence of intervention by the State.
Does Sable restart production tomorrow?
Traders on edge. Bulls are feeling optimistic. See X post below. 😉
Spend my barrel, parked in a harbor ‘Neath the platform spotlight Pump it up tight, let the oil start flowin’ A little crude movin’ on a federal green light Fits my life, oh so right My Sable Offshore Delight— Victory II (@VictoryII1) December 30, 2025
Summary: “BOEM’s order sets forth no rational basis, cannot be reconciled with BOEM’s own regulations and prior issued lease terms and approvals, is arbitrary and capricious, is procedurally deficient, violates the Outer Continental Shelf Lands Act (“OCSLA”), and infringes upon constitutional principles that limit actions by the Executive Branch. This Court must therefore vacate the Order and enjoin BOEM from taking further action with respect to that Order.”
Key points raised by Dominion:
Dominion Energy Virginia (DEV) has spent approximately $8.9 billion to develop CVOW to date, which is over two-thirds of the total projected cost of $11.2 billion.
BOEM and Interior afforded DEV no advance warning or due process regarding the Order for CVOW.
The Order alleges no CVOW violation or deficiency.
The Order points to unnamed “national security threats” based on a November 2025 “additional assessment regarding the national security implications of offshore wind projects” by DoD, “including the rapid evolution of relevant adversary technologies and the resulting direct impacts to national security from offshore wind projects” generally.
The Order deems this information “new” and “classified” without any justification or detail. Moreover, as BOEM and DoD should know, certain DEV officials have security clearances to receive and review classified information, yet never were afforded such an opportunity prior to issuance of the Order.
DEV is suffering more than $5 million per day in losses solely for costs relating to vessel services associated with the Order. DEV is also incurring losses related to additional storage costs for the significant amount of equipment, idle workforce, contractual penalties, and additional costs.
Agencies are required to consider costs and benefits in their decision-making
Agencies are required to consider alternatives in their decision-making.
The CVOW Order unlawfully deprives DEV of a property interest without due process.
Dominion’s weakest argument follows (bad State legislation shouldn’t dictate Federal energy policy):
CVOW is critical to Virginia’s legislative clean energy directive and DEV’s commitment to achieving net-zero emissions. The VCEA requires the transition of Virginia’s electric grid to 100 percent non-carbon producing energy generation by 2045. Va. Code § 56-585.5. The VCEA also states that the construction of Virginia offshore wind facilities is in the public interest. Va. Code § 56-585.1:11 (C)(1).
Attached are PHMSA’s Christmas week Emergency Special Permit and Permit Analysis document. Is the path clear to restart SYU production before New Year’s day?
Three excerpts from the first attachment are pasted below. The last paragraph on p. 2 succinctly explains PHMSA’a emergency permit:
PHMSA was able to assume jurisdiction from the State because the pipeline transports Federal OCS oil and is thus inherently interstate. The perceived problem with a PHMSA takeover had been the court approved Consent Decree that was executed following the 2015 Refugio pipeline spill. That Decree specifies that the State Fire Marshal must approve a restart of the pipeline. The first paragraph on p. 2 of the permit explains PHMSA’s position that the Consent Decree has been superseded.
The provision pasted below (p. 4 of the permit) seems contradictory in that it stipulates compliance with the Consent Decree. However, PHMSA apparently sees no contradiction in that references to the Fire Marshal (OSFM) should now be read as references to PHMSA. PHMSA presumably included this provision to reaffirm the need to comply with the technical requirements in the Decree.
The second attachment is PHMSA’s analysis of the special permit. Note that the permit expires in 60 days. Public notice and opportunity for comment would be required for a renewal.
Environmental organizations reacted quickly to the PHMSA permit, filing an emergency motion in the 9th circuit (third attachment). Observations:
Impressive effort given the time crunch. The PHMSA permit was issued on 12/23, just 3 days prior to the court filing. No Christmas break for those folks!
If you wonder why the petition was filed with the 9th Circuit (seemed convenient given the 9th Circuit’s reputation), a filing at the Circuit level is required for appeals of PHMSA orders.
Petitioners strongest argument: Sable is not entitled to emergency relief, as there is no real emergency. PHMSA asserts that EO 14156, which declared a National Energy Emergency, supports the emergency permit.
The petitioners environmental doom prediction is not compelling. PHMSA’s position is that the mitigations they are imposing (reduced operating pressure, inline inspections, testing and sampling, etc) provide protection equal to or greater than than the corrosion remediation requirement that is being waived.
The petitioners asked the Court for relief no later than 12/26. That date has passed. Will there be a ruling today?
Barring an injunction, odds are that Sable restarts production prior to New Year’s Day, when a requirement (SB 237) for a new Coastal Development Plan, takes effect.
Leslie Beyer, Assistant Secretary for Land and Minerals Management (ASLM), has stepped down from her post as the leader of the Dept of the Interior’s offshore energy programs. She was the senior official at this month’s BGG1 lease sale, and made strong remarks about the importance of the offshore oil and gas program. Ms. Beyer was confirmed by the Senate in September.
Lanny Erdos, Director, Office of Surface Mining Reclamation and Enforcement, has been named Acting ASLM.
This leaves the offshore energy program without a confirmed Asst. Secretary and with Acting Directors at both BOEM (Matthew Giacona) and BSEE (Kenny Stevens).
Bud's Offshore Energy (BOE) 