Feeds:
Posts
Comments

Archive for the ‘Regulation’ Category

Protect Our Coast NJ petitions EPA to withdraw permit allowing Sunrise Wind to use open loop cooling

Posted in Offshore Wind, Regulation, tagged , , , on May 13, 2025| Leave a Comment »

BOEM paper on High Voltage Direct Current cooling systems

Protect Our Coast NJ submitted a petition (attached) on May 12, 2025 requesting EPA to withdraw a permit that would allow the Sunrise Wind to use an open loop cooling system. The gist of the filing:

“Sunrise Wind has obtained an EPA permit to pull nearly 8 million gallons per day (MGD) of seawater from the Atlantic Ocean and discharge it, after use in cooling and mixture with sodium hypochlorite (chlorine), back into the environment at elevated temperatures. This open-loop system was authorized by EPA Region 1 under NPDES Permit MA0004940. However, approval of this method ignores EPA’s Best Technology Available (BTA) requirement and no rigorous alternatives analysis was conducted to justify this method over a closed-cycle cooling system, despite the known and broad negative environmental impacts that will result, including harms to early life stages of marine species.
The facility lies within a biologically rich and economically vital region of southern New England and the New York Bight. NMFS and BOEM have acknowledged this area as essential fish habitat (EFH) for numerous federally managed species, including Atlantic cod, winter flounder, and longfin squid.“

POCNJ EPA Sunrise Final 051225Download

Read Full Post »

Sable clears another hurdle

Posted in California, Offshore Energy - General, Regulation, tagged , , , , , , on May 12, 2025| Leave a Comment »

John Smith reports that Sable has cleared another significant hurdle in its attempt to restart production in the Santa Ynez Unit. The California DEPARTMENT OF PARKS AND RECREATION has determined that no permit is required for the pipeline anomaly digs in Gaviota State Park (see attached).

The reasons for the exemption are that the project consists of repairs to an existing facility with no expansion of use, and the footprint of the pipeline remains the same.

Maybe the SYU restart is not Mission Impossible after all.

Gaviota S.P. – Pacific Pipeline Anomalies 2025 NOEDownload

Read Full Post »

Wind energy resource management is reminiscent of the early days of oil production

Posted in energy policy, Offshore Wind, Regulation, tagged , , , , on May 9, 2025| Leave a Comment »

Orsted photo: wind wakes trailing turbines at Vattenfall’s Horns Rev wind farm offshore Denmark

A previous post on wind theft and a recent BBC article point to the rather limited understanding that wind developers and govt land managers have about wind resource management including optimal turbine spacing and protection of correlative rights. Wind is considered a renewable energy resource, but the energy lost through inefficient operating practices is not renewable.

Given that the wake effect can extend for more than 100 km, reduce downwind energy production by >10%, and affect biological productivity, a better understanding of this phenomenon should have preceded the installation of thousands of turbines.

high density, low ultimate recovery circa 1910
modern deepwater production, few facilities, high oil recovery

Wind resource management is reminiscent of the early years of oil production when the “law of capture” reigned supreme and wasteful production practices were a self-defense mechanism.

.

Read Full Post »

“Idle Iron Decommissioning Offshore California and the Need to Amend Reefing Legislation”

Posted in California, decommissioning, energy policy, Offshore Energy - General, Regulation, tagged , , , , , on May 6, 2025| Leave a Comment »

John Smith shared an outstanding paper (attached) that was presented by co-author Robert Byrd at the SPE Regional Meeting in Garden Grove, CA last week.  

 

John Smith: “My objective in writing the paper is to hopefully spur legislators to recognize the benefits of reefing and the legislative fixes required to facilitate reefing and the removal of aging infrastructure.  The California Department of Fish and Wildlife Habitat Lead was very complimentary of the paper and has distributed it to the Interagency Team which is developing a California Artificial Reefing Plan.”  

John adds: “They are in the process of creating a statewide artificial reef plan and you can sign up for updates and get more information. The California Artificial Reef Program (CARP) Plan won’t discuss the specifics of Rigs-to-Reefs but will be compliant with the National Fisheries Enhancement Act and National Artificial Reef Plan and meet the BSEE requirement of having an adopted state artificial reef plan. The intent is to add an addendum to the plan when resources become available to move Rigs-to-Reefs forward in California. You can check out the latest program update that further discusses the CARP Plan and Rigs-to-Reefs.”

SPE Paper Amended Reefing Legieslation Needed SPE-224190-msDownload

Read Full Post »

Why timely well plugging and financial assurance rules must be strictly enforced!

Posted in decommissioning, energy policy, Gulf of Mexico, Offshore Energy - General, Regulation, well control incidents, tagged , , , , , , , on May 5, 2025| Leave a Comment »

Coast Guard photo. Thanks to Lars Herbst for bringing this incident to my attention.

In what the Coast Guard is describing as an “uncontrolled discharge” (euphemism for blowout), an 82-year-old oil well has been spewing oil, gas, and water into the coastal marshes of southern Plaquemines Parish, Louisiana, for more than a week.

In hopes of future production, prior and current owners had elected not to permanently plug the well, apparently with the State’s acquiescence.

The well is currently operated by an affiliate of Spectrum Energy. Typical of these situations, the previous owner, Whitney Oil and Gas, was in bankruptcy.

The Coast Guard has taken over the response and has accessed the Oil Spill Liability Trust Fund.

We don’t need relaxed decommissioning and financial assurance requirements. We need a cooperative Federal, State, and industry effort to ensure that wells are plugged in a timely manner and that financial assurance is provided to protect the public interest.

Read Full Post »

DOI intends to revise offshore financial assurance rule. Is this cause for concern?

Posted in decommissioning, energy policy, Offshore Energy - General, Regulation, tagged , , , on May 3, 2025| Leave a Comment »

The U.S. Department of the Interior today (5/2/2025) announced its intent to “update” the Bureau of Ocean Energy Management’s 2024 Risk Management and Financial Assurance for OCS Lease and Grant Obligations Rule. 

Those who are concerned about minimizing the Federal government’s decommissioning risk exposure should closely monitor this process. Some companies and their political allies have sought to minimize the financial risks associated with plugging wells and removing facilities. As a result, it has been necessary to defend BOEM from unwarranted commentary about decommissioning issues and the financial assurance rule. Stay tuned!

Read Full Post »

Oil companies don’t fare well when they drift from their core businesses

Posted in CCS, energy policy, Gulf of Mexico, Offshore Energy - General, Offshore Wind, Regulation, tagged , , , , , , , , , on May 1, 2025| Leave a Comment »

BP dropped the regrettable Beyond Petroleum campaign and has now cut their renewable energy investments to focus on oil and gas production. They are doing quite well in the Gulf of America where they are the no. 2 oil and gas producer.

The leading Gulf of America oil and gas producer, Shell, has also slowed its renewable investments and is no longer participating in any US offshore wind projects.

Only Equinor (formerly Statoil), which is 2/3 Norwegian government owned, remains committed to renewable projects, much to the chagrin of some private investors. Equinor’s Empire Wind misadventure may be matched in the Pacific where their floating wind project offshore California is a long way from reality.

Farther in the past, there were noteworthy failures (below) like Mobil’s acquisition of Montgomery Ward, Exxon’s investment in Reliance Electric, and Gulf’s real estate ventures.

Mobil – Montgomery Ward
Exxon – Reliance Electric
Gulf Land – Reston

Finally, don’t expect the carbon sequestration boom that some are forecasting. As wind investors have discovered, industries dependent on mandates and subsidies are risky.

Not much unites climate activists and skeptics, but they are largely aligned in their opposition to carbon sequestration (euphemism for disposal), as are fiscal conservatives. The word chutzpah comes to mind when companies seek public funds to dispose of emissions associated with the combustion of their products.

And how are those 199 wrongfully acquired carbon sequestration leases in the Gulf working out (graphic below)? Barring some legislative sleight of hand, those leases are worthless.

199 oil and gas leases were wrongfully acquired at Sales 257, 259, and 261 with the intent of developing these leases for carbon disposal purposes. Repsol was the sole bidder at Sale 261 for 36 nearshore Texas tracts in the Mustang Island and Matagorda Island areas (red blocks at the western end of the map above). Exxon acquired 163 nearshore Texas tracts (blue in map above) at Sales 257 (94) and 259 (69).

Read Full Post »

BSEE commingling policy change is a good example of how to regulate

Posted in energy policy, Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , , , on April 28, 2025| Leave a Comment »

fig. 1, UT study: analyzed deepwater Paleogene fields, stratigraphic column (MMS map 😉)

BSEE’s decision to revise downhole commingling policy by increasing the allowable pressure differential between reservoirs is sound and supported by an impressive University of Texas (UT) Petroleum Engineering study. Although the announcement hype is a bit much, this is the way regulation is supposed to work.

The main benefit of commingling (vs. sequential production) is the accelerated return on investment, which is fine as long as other risks are not introduced and ultimate oil recovery is not sacrificed. The UT study of Paleogene (Wilcox) reservoirs found that downhole commingling actually maximizes per-well oil production compared to sequential schemes. Over 30 and 50 years, commingling yields 61% and 21% more oil respectively.

The UT study analyzed 3 cases with 19 variables (Table 2 in their report). The reservoir pressure differentials were 500, 1000, and 1500 psi. Interestingly, pressure differential had essentially no impact on cumulative production in either the commingled or sequential scenarios.

Figure 13. Cumulative production over 50 years for commingled (left) and sequential (right) production scheme. The most significant variables are shown in the first four pairs of plots. The last pair of plots shows the least important parameter which is pressure difference between reservoir units.

Also note that (fig. 13):

  • As the upper reservoir thickness increases to 1000 ft (high case), total production increases by 41% for the commingled production scheme and 26% for the sequential production scheme.
  • The second most important field feature is upper reservoir facies proportion for both production schemes. A higher sand proportion in the reservoir results in higher production.

Read Full Post »

Emergency permitting procedures announced

Posted in energy policy, Regulation, tagged , , , on April 24, 2025| Leave a Comment »

The U.S. Department of the Interior will implement emergency permitting procedures to accelerate the development of domestic energy resources and critical minerals.

I’m trying not to be skeptical, but these timelines are very ambitious. How much leeway do the words “approximately” and “roughly” provide?

  • Projects analyzed in an environmental assessment, normally taking up to one year, will now be reviewed within approximately 14 days.
  • Projects requiring a full environmental impact statement, typically a two-year process, will be reviewed in roughly 28 days. 

Do we really have a “National Energy Emergency?” Environmental lawyers (and their fundraisers) will no doubt be very busy.

Read Full Post »

BOEM letter to Empire Wind

Posted in energy policy, Offshore Wind, Regulation, tagged , , , on April 18, 2025| Leave a Comment »

The letter is attached. Excerpt:

The Bureau of Ocean Energy Management (BOEM) is issuing this Director’s Order to Empire Offshore Wind LLC to halt all ongoing activities related to the Empire Wind Project on the outer continental shelf to allow time for it to address feedback it has received, including from the National Oceanic and Atmospheric Administration (NOAA), about the environmental analyses
for that project. BOEM received this and other feedback regarding Empire Wind as an outgrowth of the review that the Department is engaged in related to offshore wind projects. See the President’s Memorandum of January 20, 2025. 90 Fed. Reg. 8363 (January 29, 2025).

BOEM Director's Order Empire WindDownload

Read Full Post »

« Newer Posts - Older Posts »