We preferred the House version, but the Senate Parliamentarian killed the provisions that reduced the risk of litigation and processing delays.
Whether justified or not, the royalty rate is now capped at 1/6 and a 10-year deepwater lease term is locked in.
The favorable terms and assurance of regular GOA lease sales put the ball squarely in industry’s court. We are looking for a good showing at Sale 262, including some new bidders and the return of some prominent companies.
Minimizing flaring and venting is important from both environmental and resource conservation standpoints.Flaring and venting volumes are also good indicators of how well production systems are designed, managed, and maintained.
The best performance indicators are the percentages of produced gas that are flared and vented both for oil-well gas (OWG, also known as associated or casinghead gas) and gas-well gas (GWG or non-associated gas).
Updated flaring and venting volumes for the Gulf of America have been compiled using monthly data submitted to the Office of Natural Resources Revenue (ONRR). This is the best data source because reporting is mandatory and strictly enforced, and flaring and venting are accounted for separately.
In assessing performance trends, it’s important to segment venting and flaring volumes for both OWG and GWG production. Venting produced gas (mostly methane) is a more significant environmental concern from both air quality and greenhouse gas (GHG) perspectives.
Flaring and venting data for 2019-2024 are summarized in the table below. All volumes are in millions of cubic feet (MMCF).
Notes and comments:
The more disappointing 2024 numbers are entered in red. The blue numbers, all related to OWG venting, are encouraging.
The % of all produced gas that was flared or vented in 2024 (1.3%) was the highest in the past 10 years (see the chart below the table). Until 2018, annual flaring/venting rates of <1% of production were commonly achieved. This should be the target going forward.
OWG flared increased significantly from 2023 levels, both in terms of the volume (7.26 billion cu ft) and the % of OWG produced (1.22%).
Production curtailments and restarts related to Tropical Storms Francine and Helene may have contributed significantly to the 2024 flaring increase. ONRR’s monthly reports show a near doubling of the average monthly flaring volume in Sept., when Francine and Helene shut-in 42% and 29% of oil production respectively. However, even if the Sept. flaring surge is normalized to the monthly average for the other 11 months, the total 2024 flaring still exceeds the 2023 volume by 361 MMCF.
The % of GWG vented in 2024 was the highest in the 6 year period and double the 2019, 2020, 2021 rates. Inefficiencies associated with the dramatic decline in GWG production, down 41.5% from 2023, may be a contributing factor.
The continued decline in OWG venting to only 0.16% in 2024 is encouraging. The decline should be sustainable given that most OWG is now produced at modern deepwater platforms equipped with efficient flare stacks.
Given the significance of these data, from safety, conservation, and environmental perspectives, a more comprehensive analysis by the offshore industry and regulators should be a priority.
As the chart indicates, the % of flared or vented Gulf of America gas production increased over the past 10 years. This trend is presumably due, at least in part, to the sharp increase in the % of gas production from oil wells (associated gas), which have a higher flaring rate. In 2024, 87% of Gulf gas production was from oil wells.
Flaring/venting summary tables and comments, updated through 2024, will be posted later in the week.
The Safety Alert is attached. Per BSEE, the fires resulted from an accumulation of gas caused by improperly installed or disconnected exhaust vent piping on gas starters.
Incident 1: Two workers sustained burns to the hands, arms, and face. BSEE investigators discovered that the engine’s air intake hose was disconnected, which may have allowed gas-enriched air to be drawn into the carburetor causing the backfire.
Incident 2: While attempting to start the gas engine of a pipeline pump, the lead mechanic sprayed ether into the engine’s carburetor. The exhaust vent piping for the starter had not been installed. The combination of the gas-rich atmosphere and ether caused the engine to backfire and ignited the accumulated gas. The lead mechanic, sustained burns to his face, arms, and hands.
The Alert includes important recommendations for proper venting, mechanical integrity awareness training, maintenance, and the use of gas detectors and a temporary fire watch during engine startup.
This week Total announced the acquisition of a 25% working interest in 40 Chevron leases in the Gulf of America. Total already owned interest in Chevron’s producing Ballymore (40%), Anchor (37.14%), Jack (25%), and Tahiti (17%) fields. Ironically, Federal regulations prohibited Total from jointly bidding with Chevron for any of those leases at the time of the sales. How does that make sense?
Total did not submit a single bid in any of the past 4 Gulf of America lease sales. Perhaps they prefer to acquire interest in blocks previously leased to companies like Chevron. That is a reasonable acquisition strategy. However, farm-in acquisitions yield no bonus dollars to the Federal government. Wouldn’t it have been in the government’s best interest if some of those acquisition dollars were spent at lease sales where the bonus bids go to the US Treasury?It’s long past time to remove the joint bidding restrictions!
As explained in the attached Safety Alert, BSEE’s risk-based inspection program has identified deficiencies in safety device bypass practices including:
inadequate documentation
inoperative data history software
bypassing more devices than is necessary
bypassing devices for longer than necessary
missing audit documentation
mistakenly bypassing the entire safety system during production
The regulations restricting the bypassing of safety devices are core elements of OCS regulatory and operator management programs. Because they are critical to process safety, these requirements are widely supported and strictly enforced.
Operator/licensee responsibility:The definitions correctly establish the operator or license holder as the responsible party. This means that in the event of a well blowout while drilling from a mobile drilling unit, the licensee/operator would be the responsible party. This aligns with the “operator responsibility” mantra that is fundamental to the US offshore program. Drilling and other contractors are managed by the operator and are the operator’s responsibility.
Unlimited liability: The liability section (Part VI) establishes an unlimited liability standard for the responsible party. As previously discussed in more detail, this is a daunting, open-ended obligation that would trouble permittees in any industry. The unlimited liability provision could preclude responsible independent operators, including Guyanese companies, from seeking licenses.
The unlimited liability standard (par. 17) is qualified with a provision (pasted below) that also favors major international companies.
The unlimited liability provision therefore does not seem to apply to parent companies idemnifying a project. This was a point of contention during the parliamentary debate. The Kaieteur News delves into the issue and is not entirely convinced by the Government’s defense. Their article closes as follows:
It is important to note that stakeholders have argued that since ExxonMobil Guyana Limited (the responsible party) does not have adequate assets, the burden of oil spill-related costs could be left on Guyana, especially in the absence of unlimited coverage from the parent company. These and other “flaws” have prompted Guyanese to urge President Irfaan Ali not to assent to the Bill, passed in the National Assembly on May 16, 2025. Be that as it may, the Ministry maintained that the “robust statutory framework now established protects Guyana and its people.”
John Smith informs me that today (6/6/2025), a Santa Barbara Superior Court issued an order preventing the restart of the Santa Ynez Unit’s onshore pipeline pending Court resolution of the dispute.
Sable’s shares plunged 18% in response to the news.
ACK For Whales, the Wampanoag Tribe of Gay Head / Aquinnah, Green Oceans, a coalition of charter fishing groups and seven individuals filed suit in federal court asserting that the Departments of Interior and Commerce violated the law when they approved the Record of Decision (ROD) for the New England Wind 1 and 2 projects.
Construction has not yet begun on the New England Wind 1 and 2 projects. The leases abut Vineyard Wind’s troubled lease 0501 (see above map), site of last summer’s turbine blade failure.
“In offshore wind project after offshore wind project, from Revolution Wind, Vineyard Wind and New England Wind to the others, the government was so desperate to rush these projects that it cut corners and violated the law,” Oliver said. “The government didn’t care if it trampled on the Wampanoag sacred beliefs and rites, hurt the charter boat, fishing and lobster industries or wiped out the Right whales. The only thing that mattered was to get these environmentally destructive turbines built, costs to the rest of us be damned.”
ACK FOR WHALES, INC., VALLORIE OLIVER, AMY DISIBIO, VERONICA BONNET, DOUGLAS LINDLEY, STEVEN AND SHARYL KOHLER, DANNY PRONK, WILLIAM VANDERHOOP, GREEN OCEANS, RHODE ISLAND PARTY AND CHARTER BOAT ASSOCIATION, CAPE COD CHARTER BOAT ASSOCIATION, INC., CONNECTICUT CHARTER AND PARTY BOAT ASSOCIATION, INC., MONTAUK BOATMEN AND CAPTAINS ASSOCIATION, INC. and WAMPANOAG TRIBE OF GAY HEAD AQUINNAH
Defendant:
UNITED STATES DEPARTMENT OF COMMERCE, NATIONAL MARINE FISHERIES SERVICE, BUREAU OF OCEAN ENERGY MANAGEMENT, UNITED STATES DEPARTMENT OF THE INTERIOR, DOUG BURGUM, in his official capacity as Secretary of the Interior, WALTER CRUICKSHANK, in his official capacity as the Director of the Bureau of Ocean Energy Management, HOWARD LUTNICK, in his official capacity as the Secretary of Commerce and EUGENIO PIEIRO SOLER, in his official capacity as the Assistant Administrator of the National Marine Fisheries Service
For the reasons set forth herein, the application of the California Coastal Commission for issuance of a preliminary injunction is granted. No bond is required. The Commission shall present a written order for entry by the court.
The roller coaster ride continues. Sable Offshore’s stock price plunged in response to the latest order.
Bud's Offshore Energy (BOE) 