Senator Schiff and 22 California representatives sent the attached letter to Gov. Newsome urging him to:
Require the Fire Marshal to reconsider the state waiver for the pipeline, conduct environmental review, and hold a public hearing;
Require a coastal development permit for restart of the pipeline;
Require State Parks to conduct environmental review and hold a public hearing prior to deciding whether to approve a new easement for the pipeline through Gaviota State Park.
The good news for Sable: Despite the bluster in the letter’s opening paragraphs, none of the requests to Gov. Newsome are knockout punches. The first two relate to matters that have already been addressed and Sable is in a favorable position. The third, the Gaviota State Park easement renewal, is currently under review and should not be a decisive blow.
The bad news for Sable: Punches will continue to be thrown even after production resumes (should that ever actually happen.)
BSEE’s risk-based inspection and safety alert programs have effectively drawn attention to grating risks. Attached is a recent alert describing a grating incident that could have been fatal.
A worker installing a pump in a skid above unsafe grating was kneeling on scaffolding boards. The tip of his boot was on the corroded grating when it suddenly gave way. The worker was able to grab a nearby section of piping to support himself. The 36″ x 36″ piece of grating collapsed and fell into the water.
The oil industry has a long history of dealing with the correlative rights issues associated with oil drainage from competitive reservoirs. Similar issues are arising in the offshore wind industry.
Orsted claims that four nearby wind farms in the Irish Sea could result in a drop in Orsted’s annual energy production of up to 5.34%, and is seeking mitigation or compensation.
This is all rather familiar to the oil industry and its regulators, particularly the call for compensation!
“The California Coastal Commission is simply out of control and has veered far from its purpose of protecting the coast,” said Rep. Kiley. “From blocking SpaceX rocket launches to obstructing fire prevention projects, the Commission has repeatedly threatened the safety of Californians and weakened our national defense, while needlessly undercutting innovation and economic progress. The need to rein in the Commission has become urgent as we face the challenge of rebuilding Los Angeles following the fires. ”
The bill (attached), introduced by Kevin Kiley (CA), would amend the Coastal Zone Management Act (CZMA) to expedite important coastal activities, including national security initiatives, critical infrastructure development, and disaster mitigation and recovery efforts. Key provision:
‘‘(2) LIMITATION ON OBJECTION.—An objection or other challenge by a coastal state to an activity subject to a conclusive presumption of concurrence under paragraph (1) may not delay or otherwise prevent the activity from proceeding.”
While perhaps unlikely to be enacted, the bill addresses regulatory authority that many perceive to be unchecked and abusive. Congressional attention is clearly warranted.
In the case of the Rosebank and Jackdaw fields, Lord Ericht ruled that the environmental assessment must take into account the climate effect of downstream emissions resulting from the consumption of oil and gas produced at those fields.
The Sale 257 decision was even more extreme in that Judge Contreras ruled that BOEM failed to consider the “positive” effect that higher prices (which might result from lower US offshore production) would have in reducing worldwide demand and the associated GHG emissions.
Regardless of one’s opinion on the extent to which GHGs affect the climate, halting UK and US projects will have virtually no effect on international oil and gas demand. That demand will be satisfied by other suppliers who will reap the economic benefits.
Presumably, revised environmental assessments, will allow the previously approved UK projects, for which some facilities have already been constructed and installed, to go forward. The UK government has been considering how to calculate downstream emissions. The model will no doubt yield outcomes that are highly uncertain.
In the meantime, the UK sector of the North Sea, unlike its Norwegian counterpart, continues to flounder.
“We need more of it because even the most ardent supporters of renewable energy, the most vocal proponents of net zero, quietly admit oil and, especially, gas will be needed for a couple of decades at least. That obvious truth, that inarguable necessity, is not, apparently, enough for ministers to encourage UK production, however, or temper their rhetoric around renewables.“
“Allowing our rigs and refineries to power down and relying on other countries to keep the lights on still seems a little, well, counter-intuitive. We will import oil and gas but not produce it while happily exporting contracts, skills and jobs overseas? The practical impact of Labour’s refusal to grant new exploration licences in the North Sea might remain unclear but the message it sent was absolutely crystal.“
Of particular interest are mandated reviews of the:
RIsk Management and Financial Assurance Rule: Those who want to gut this rule should come to the table with proposals that better protect the taxpayer from decommissioning liabilities. Pretending that decommissioning financial risks don’t exist or that they are someone else’s (or the govt’s) problem is unacceptable.
5 Year leasing program – This review is urgently needed. See this and this!
BOP/Well Control Rule – This keystone safety rule has undergone multiple reviews in recent years. Because of the rule’s importance, further review for continuous improvement purposes may nonetheless be warranted. Here are the blog comments on the current version of the rule.
Pioneering offshore engineer J.L. Daeschler, a Frenchman who lives in Scotland and has worked on drilling rigs worldwide, shared his 1974 training certificate signed by Bill Hise, the first director of the Blowout Prevention and Well Control Training Center at LSU. JL recalls his training:
The LSU well control course was new and very well organized. Training options were limited at that time. LSU took a step forward and incorporated equipment donated by Cameron Iron Works, Armco Steel /National, VETCO, and others.
The course was split between indoor class room style and outdoor trainingon a live well to remind us of the real things, like hard hats, tally books, and safety shoes.
LSU had a 1200 ft vertical well and a small 2″ diameter gas injection line to create a bottom hole gas kick, using a nitrogen truck as the supply. (note: the live well was a first for any well control school.) You had a choice of several manual chokes. I selected the Cameron Willis choke to circulate the gas kick out with no increase in mud weight (drillers method).
The mud return level, kick detection, and general management of the operation were realistic as if on a rig. The gas would whistle and escape thru a vent line.
The training was simple and effective in that proper well control procedures were learned. In the process, there were many errors. Mud was seen flying out of the mud shaker/pits. School management would bring things under control and explain the errors that were made !!!
Given the importance of minimizing drilling risks, the Minerals Management Service (MMS) was the primary funder of the LSU facility. MMS predecessor, the Conservation Division of USGS, first established well control training requirements in 1975 (pasted below).
… Union Oil Company’s reckless well plan forever scarred the U.S. offshore program. Learn more about the details.
Santa Barbara blowout
Examinations of the Santa Barbara, Montara, and Macondo blowouts, the Piper Alpha fire, and other major incidents should be a part of every petroleum engineering curriculum, and should be mandatory for those who conduct and regulate offshore oil and gas operations.
There is no better learning experience than studying the failures that had such enormous human and economic consequences.
Withdrawal from the Paris Climate Change Agreement:The US Ambassador to the UN shall immediately submit formal written notification of the US withdrawal from the Paris Agreement under the United Nations Framework Convention on Climate Change.
Regulatory Freeze: Agencies may not propose or issue a rule until approved by a Presidential appointee. OMB may exempt emergency or urgent rules (déjà vu for regulators 😉).
Alaska: Withdraws a Secretarial Order intended to halt ANWR oil and gas leasing. Rescinds cancellation of ANWR leases.
Encourage energy exploration and production on Federal lands and waters, including on the Outer Continental Shelf.
Eliminate the electric vehicle (EV) mandate.
Requires immediate review of actions that could burden the development of energy resources.
Develop and begin implementing action plans to suspend, revise, or rescind all unduly burdensome agency actions.
Revoke climate change and “clean energy” EOs.
Terminate all activities, programs, and operations associated with the American Climate Corps (RIP 😉).
Expedite and simplify permitting processes.
Facilitate the permitting and construction of interstate energy transportation and other critical energy infrastructure, including pipelines.
Disband the Interagency Working Group on the Social Cost of Greenhouse Gases.
Terminate the Green New Deal.All agencies must immediately pause the disbursement of funds appropriated through the Inflation Reduction Act of 2022 (Public Law 117-169) or the Infrastructure Investment and Jobs Act (Public Law 117-58).
The Secretary of Energy is directed to restart reviews of applications for LNG export projects as expeditiously as possible.
Bud's Offshore Energy (BOE) 