Posted in energy policy, Offshore Wind, Regulation, tagged Empire Wind, NOAA, petition to revoke LOA, Save the East Coast - NJ on July 28, 2025| Leave a Comment »
The attached petition from Save the East Coast Inc. et al requests that NOAA revoke the Empire Wind Letter of Authorization using the emergency authority delineated at 50 C.F.R. § 216.106(f).
This is a strong filing, but revocation would be difficult given the extensive development activity to date and the Administration’s decision in May to allow the project to go forward.
Posted in California, Offshore Energy - General, Regulation, tagged litigation, permitting, Sable Offshore, Santa Barbara County, Santa Ynez Unit on July 24, 2025| Leave a Comment »
In the Independent, Nick Welsh aptly described the latest court decision in the long and winding road that Sable Offshore hopes will lead to Santa Ynez Unit production:
“When Judge Donna Geck got through ruling on the latest showdown between Sable Offshore Oil and Santa Barbara’s environmental establishment last Friday morning, it wasn’t clear if the no-nonsense judge cut the proverbial baby in half or kicked the can down the proverbial road.”
Bottom line: The judge will “continue to bar the Fire Marshal from taking any steps to process Sable’s restart application until 10 days after Sable had received all the necessary permits and approvals from the myriad of state, federal, and local agencies that enjoy some degree of regulatory oversight over the proposed project.” Does that mean any agency, even one with a minor or questionable role, can block the project?
As the author notes:
“As of this writing, it’s not entirely clear which of those agencies have yet to issue Sable the permits it needs to start the restart process and when they’re likely to do so, if at all. Even less clear is whether there’s any agreement among the dueling parties as to which agencies have standing to even weigh in.”
Posted in energy policy, Offshore Energy - General, Regulation, tagged drilling Safety leaders, encouraging innovation, regulatory reform, rescinding regulations, US Dept. of the Interior on July 18, 2025| Leave a Comment »
Comments on the Dept. of the Interior’s regulatory reform initiative are due by July 21.
DOI’s “Deregulation Suggestions” form implies that their review may be limited in scope. The form focuses solely on rescinding regulations. True regulatory reform requires a broader assessment of regulatory methods and strategies.
Offshore safety regulations address known or perceived operational risks. Deleting individual provisions without considering the effect on the regulatory objective could introduce new risks without reducing the burden on operators and regulators.
More meaningful regulatory reform, and the associated improvements in operator and regulator efficiency, can be achieved by addressing regulatory fragmentation and providing regulatory incentives for companies with outstanding safety and environmental performance records.
My comments to DOI will address fragmentation and the challenges associated with updating regulations and standards. A Drilling Safety Leaders Pilot Program will be proposed. This pilot program would offer a more flexible regulatory regime for operators with outstanding safety records.
The regulatory system can constrain leading operators and delay innovation. The top performers should be encouraged to stay ahead of the technology and management curves. Most of the requirements that were added after Macondo had been adopted by leading operators well before the blowout.
Posted in energy policy, Offshore Energy - General, Regulation, tagged Big Beautiful Bill, energy policy, Gulf of America, lease sale 262 on July 7, 2025| Leave a Comment »
See the differences in the OCS oil and gas provisions in the House and Senate versions.
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.
Posted in flaring and venting, Gulf of Mexico, Offshore Energy - General, Regulation, tagged 2024 flaring performance, climate, environment, flaring and venting, gas well gas, oil well gas, ONRR, updated data on June 26, 2025| Leave a Comment »
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:
| 2019 | 2020 | 2021 | 2022 | 2023 | 2024 | |
| OWG flared | 7727 | 7385 | 5919 | 6987 | 6342 | 7260 |
| OWG vented | 2578 | 1984 | 1405 | 1638 | 1230 | 965 |
| OWG produced | 670,699 | 582,254 | 582,824 | 581,235 | 598,005 | 595,600 |
| % OWG flared | 1.15 | 1.27 | 1.02 | 1.20 | 1.06 | 1.22 |
| % OWG vented | 0.38 | 0.34 | 0.24 | 0.28 | 0.21 | 0.16 |
| GWG flared | 405 | 432 | 311 | 213 | 212 | 232 |
| GWG vented | 958 | 578 | 548 | 722 | 468 | 465 |
| GWG produced | 364,082 | 224,808 | 209,558 | 203,342 | 152,400 | 89,167 |
| %GWG flared | 0.11 | 0.19 | 0.15 | 0.10 | 0.14 | 0.26 |
| %GWG vented | 0.26 | 0.26 | 0.26 | 0.36 | 0.31 | 0.52 |
| total flared and vented | 11668 | 10233 | 8183 | 9559 | 8252 | 8922 |
| total gas production | 1,034,782 | 807,062 | 792,382 | 784,577 | 750,405 | 684,758 |
| % flared or vented | 1.13 | 1.27 | 1.03 | 1.22 | 1.10 | 1.30 |
| total vented | 3536 | 2416 | 1953 | 2360 | 1698 | 1430 |
| % vented | 0.34 | 0.30 | 0.25 | 0.30 | 0.22 | 0.21 |
| total flared | 8132 | 7817 | 6230 | 7200 | 6554 | 7492 |
| % flared | 0.79 | 0.97 | 0.79 | 0.92 | 0.87 | 1.09 |
Posted in flaring and venting, Gulf of Mexico, Offshore Energy - General, Regulation, tagged Gulf of America, increased flaring, trend, venting on June 24, 2025| Leave a Comment »
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.
Posted in accidents, Gulf of Mexico, Offshore Energy - General, Regulation, tagged BSEE, fires, gas detection, gas starters, Gulf of America, injuries, mechanical integrity, pipeline pumps, proper venting on June 23, 2025| Leave a Comment »
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.
Posted in energy policy, Gulf of Mexico, Offshore Energy - General, Regulation, tagged bidding restrictions, Chevron, farm-ins, Gulf of America, joint bidding, lease acquisition, leasing, Total on June 20, 2025| Leave a Comment »
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?
Restrictions limiting joint bidding by major oil companies date back to the Energy Policy and Conservation Act of 1975. Although these restrictions were intended to increase competition and revenues, OCS program economists have asserted, and studies have shown, that the ban results in fewer bids per tract and lower bonuses to the government.
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!
Posted in accidents, Gulf of Mexico, Offshore Energy - General, Regulation, tagged bypassing safety devices, Gulf of America, offshore production, process safety, risk-based inspections, Safety Alert, safety management on June 12, 2025| 2 Comments »
As explained in the attached Safety Alert, BSEE’s risk-based inspection program has identified deficiencies in safety device bypass practices including:
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.
Bud's Offshore Energy (BOE) 
Regulatory reform comments
Posted in energy policy, Offshore Energy - General, Regulation, tagged comments, Department of the Interior, drilling Safety leaders, pilot program, regulatory burden, regulatory fragmentation, regulatory reform on July 23, 2025| Leave a Comment »
My comments in response to the Dept. of the Interior’s regulatory reform notice are attached. First and foremost, I believe these recommendations would reduce safety and environmental risks. Second, I am confident that they would also reduce governmental costs and the regulatory burden on industry.
The first attachment discusses regulatory fragmentation and recommends actions to reduce the complexity and redundancy of the offshore regulatory regime. The second attachment proposes a Drilling Safety Leaders Pilot Program as a means of evaluating a more adaptable framework regulatory framework for operators with outstanding performance records.
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