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Archive for the ‘Regulation’ Category

The potential rewards are great – 500+ million barrels of oil, 3 major production platforms, associated pipelines, onshore processing facilities – but can Sable survive the costly legal and administrative challenges? What is Exxon’s plan for the Santa Ynez Unit if Sable should fail?

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On Friday, California Superior Court Judge Donna Geck upheld the restraining order that blocks Sable Offshore from restarting Santa Ynez Unit production. She scheduled a followup court hearing for June 27. Meanwhile, the Ninth Circuit Court of Appeal’s hearing on PHMSA’s assertion of Federal jurisdiction over the onshore pipeline segments is scheduled for July.

Can Sable survive financially until those hearings are concluded?

Contradictorily, we learn that FourWorld Capital Management just purchased 8 million shares of Sable. Is that the financial equivalent of Pickett’s Charge or does FourWorld have good reasons for their optimism?

Prior Sable Santa Ynez Unit posts.

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John Smith has shared the Environmental Assessment (attached) associated with PHMSA’s Special Permit for segments 324 and 325 of Sable’s Santa Ynez Unit (SYU) pipeline system. The document is an interesting read for those following Sable’s attempt to restart production from the SYU.

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PHMSA’s public notice (attached) is required because Sable’s Emergency Special Permit expired on 21 FEB. Comments are due by 26 MAR. More background.

PHMSA is publishing this notice to solicit public comments on a request for a special permit submitted by Sable Offshore Corp. (Sable). Sable is seeking relief from compliance with certain requirements in the Federal pipeline safety regulations. PHMSA has proposed conditions to ensure that the special permit is not inconsistent with pipeline safety. At the conclusion of the 30-day comment period, PHMSA will review the comments received from this notice as part of its evaluation to grant or deny the special permit request.

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As posted on 9/10/2025 (prior to PHMSA’s assertion of jurisdiction): Given that the Sable pipeline will carry OCS production, it would seem to fundamentally be an interstate line (Federal jurisdiction), as it was when owned by Plains. Could DOT reverse the 2016 letter agreement? That is conjecture for the attorneys and courts to consider.

A new Bloomberg Law article explains PHMSA’s position after a challenge by the California AG:

PHMSA said state-based hurdles are preempted by federal authorizations in the emergency permit notice letter the agency sent to Sable last year. Because the pipeline originates on the Outer Continental Shelf, the system automatically comes under federal oversight, the agency said.

A law professor adds the following:

The administration is invoking interstate commerce to classify the pipeline as a federal issue, “arguing that this is between a place in a state and outside that state,” said Hannah Wiseman, a professor at the Penn State Dickinson Law.

They are claiming this under their interpretational authority, as opposed to the actual language of the Pipeline Safety Act,” she said.

The language of the law only assigns PHMSA jurisdiction over oil operations that run outside or between state lines, but here the agency is arguing the pipeline’s start point is on the OCS, not at the onshore processing facility, she said.

Not mentioned in the article but pertinent:

  • In PHMSA’s favor, the onshore pipeline was initially under their jurisdiction.
  • In California’s favor, a court approved Consent Decree clearly identifies the California Fire Marshal as the sole oversight authority.

Meanwhile, Kruti Shah cleverly summarizes the Santa Ynez Unit story in a series of posts on X. Click on the post below to get the full thread. Great read for Sable/SYU followers:

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Important and long overdue:

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On February 12, 2024, the bankruptcy court approved the sale of certain Cox Operating assets to Natural Resources Worldwide LLC (NRW), a company that had no prior offshore experience. NRW contracted with Array Petroleum to operate 154 Cox legacy platforms (per BOEM data). NRW is listed as the operator of just one platform.

In 2025, NRW/Array operations accounted for 486 incidents of non-compliance (INCs), 36.2% of the Gulf of America total. Array and NRW had INC/facility inspection rates of 2.1 and 7.0 respectively, well above the Gulf average of 0.42 and the top performers’ rates of 0.05 to 0.13.

In Array’s defense, their violations declined sharply in the second half of 2025. However, the number of inspections of their facilities declined even more sharply, so the INCs/facility inspection ratio actually increased in the second half.

For the 2025 data in the table below:W=warning, CSI=component shut-in, FSI=facility shut-in. The 3 numbers for Array in each box are full year 2025 data (top), first half 2025 (middle), and second half 2025 (bottom)

operatorWCSI
FSI
total INCs
Facility
Insp.
INCs/isp
Array352
311
41
93
46
47
6
6
0
451
363
88
218
184
34
2.1
2.0
2.6
NRW102413557.0

Three other companies had more than 10 shelf platforms and INC/facility inspection ratios >1.0: Greyhound Energy (23 platforms), Renaissance (21 platforms) and Sanare Energy (38 platforms).

operatorWCSIFSItotal INCs
facility insp
INCs/
fac.
insp
Greyhound Energy321033231.4
Renaissance Offshore2619347441.1
Sanare Energy6020282751.1

The table below provides 2025 oil and gas production through Oct (with Gulf of America rank) for the 5 companies mentioned in this post. In determining rankings, subsidiaries and affiliates were counted as a single company (e.g. Chevron, Unocal, and Hess counted as one company).

oil (bbls)oil rankgas (MCF)gas rank
Renaissance729,904191,220,43319
Array416,267211,197,91520
Sanare246,845251,763,55218
Greyhound182,65827280,42326
NRW101,11029104,02530

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Attached is John Smith’s updated Sable litigation table. John is a BOEM retiree who has been closely monitoring Sable’s legal and regulatory challenges. His summary:

“Sable Offshore Corp. is involved either directly or indirectly in no less than 12 lawsuits that have been filed by environmental groups, state and county regulatory agencies, and the Attorney General of California, all of whom are committed to stopping Sable from restarting Santa Ynez Unit (SYU) oil and gas production. All of the lawsuits are active and many are likely to result in prolonged judicial proceedings extending over several years. Will Sable have the will and financial resources to continue these legal battles indefinitely? – that’s a multi-million dollar question.”

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The 2025 Gulf of America Safety Compliance Leaders are ranked below according to the number of incidents of non-compliance (INCs) per facility inspection. To be ranked, a company must:

  • operate at least 2 production platforms
  • have drilled at least 2 wells during the year
  • average <1 INC for every 5 facility inspections (0.20 INCs/facility inspection). This is a higher standard (fewer INCs) than in previous years.
  • average <1 INC for every 10 inspections (0.1 INCs/inspection). Note that each facility inspection may include multiple types of inspections (e.g. production, pipeline, pollution, Coast Guard, site security, etc). In 2025, there were on average 3.2 inspections for every facility inspection.
operatorWCSIFSItotal INCsfacility inspINCs/
fac insp
inspINCs/
insp
Shell381122310.055570.02
Chevron1080182600.077720.02
Oxy26191330.073250.03
BP820101220.083040.03
Murphy6208700.111770.05
Cantium574161210.134880.03
Gulf-wide 202581544584134431790.42102180.13
Gulf-wide 2024957398109146431330.47106640.14
Notes: Numbers are from published BSEE data; INC=incident of non-compliance; W=warning INC; CSI=component shut-in INC; FSI=facility shut-in INC; INCs/fac insp= INCs issued per facility inspection; each facility-inspection may include multiple types of inspections (e.g. production, pipeline, pollution, Coast Guard, site security, etc), in 2025, there were on average 3.2 inspections for every facility inspection

Criteria: This ranking is based solely on BSEE’s published compliance data. The absence of timely public information on safety incidents (e.g. injuries, fires, pollution, gas releases, property damage) precludes inclusion of these data. Although Panel Investigations are conducted for fatalities, serious injuries, and significant pollution events, the last panel report was for an incident on 3/25/2022, and no information is available for any ongoing investigations. BSEE District offices investigate the more significant incidents that don’t qualify for panel investigations. These District Investigation reports are more timely, but some are not issued within 90 days of the incident. The District reports will be reviewed later in the year. Note that there were no occupational fatalities in 2025.

Observations:

  • The overall inspection and INC results for 2025 were similar to those for 2024.
  • The top companies performed better in 2025 than in 2024. In 2024, only 2 companies had INC/facility inspection ratios of <0.10 and only 3 had ratios <0.15. In 2025, all 6 of the performance leaders had ratios <0.15.
  • All 6 of these top companies were also on the 2024 top performers list.
  • Shell’s total INCs and INCs/facility inspection decreased by 73% and 78% respectively vs. 2024
  • Cantium, which operates 85 shallow water platforms, has demonstrated that a shelf operator can be an outstanding safety performer. Cantium’s total INCs and INCs/facility inspection decreased by 50% vs. 2024
  • Should fewer inspections be conducted at facilities that have such low INC rates? On the one hand, fewer inspections would reduce regulatory costs and transportation risks. On the other hand, there are benefits from BSEE inspection visits besides compliance enforcement. These include direct communication with offshore workers (including contractors) regarding regulatory policies and safety practices, witnessing safety tests, evaluating new technology, and assessing management system implementation and corporate culture at the facility level.
  • Absent specific details on the violations, no attempt was made to weight the INCs. Although shut-in INCs are generally considered to be more significant than warnings, that is not always the case. For example, a component shut-in INC for a safety device that is marginally out of tolerance and is corrected on the spot may be less serious than a warning that is indicative of structural deterioration, poor maintenance, or organizational shortcomings.

Not meeting one of the activity level requirements, but nonetheless noteworthy, were the compliance records of LLOG and BOE Exploration & Production (younger than and unrelated to the BOE blog 😀). See their impressive results below:

operatorWCSIFSItotal INCsfacility inspINCs/
fac insp
inspINCs/
insp
BOE0011330.03780.01
LLOG1113290.10780.04

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Shell topped the list followed by Chevron, Oxy/Anadarko, bp, Murphy, and Cantium.

Details and observations will be posted tomorrow.

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