Attached isJohn 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.”
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.
operator
W
CSI
FSI
total INCs
facility insp
INCs/ fac insp
insp
INCs/ insp
Shell
3
8
1
12
231
0.05
557
0.02
Chevron
10
8
0
18
260
0.07
772
0.02
Oxy
2
6
1
9
133
0.07
325
0.03
BP
8
2
0
10
122
0.08
304
0.03
Murphy
6
2
0
8
70
0.11
177
0.05
Cantium
5
7
4
16
121
0.13
488
0.03
Gulf-wide 2025
815
445
84
1344
3179
0.42
10218
0.13
Gulf-wide 2024
957
398
109
1464
3133
0.47
10664
0.14
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.
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:
Pasted below are excerpts from Sable’s Prospectus Supplement. Is Sable serious about pursuing a Santa Ynez Unit strategy that employs a production and treatment vessel 3.5 miles from shore ala the development option that was reluctantly approved by the Federal govt in 1974, two decades before the onshore infrastructure was in place?
The OS&T option is inferior to onshore treatment and pipeline transportation in every way – spill risks, air emissions, economics, ultimate oil recovery, transportation to market, natural gas utilization, and public benefit.
This blogger supports a resumption of Santa Ynez Unit production. However, the only responsible path forward is to do the right thing and continue to pursue the onshore pipeline approvalsadministratively and legally. It is far better to defend a good project than a contrived workaround.
When will BOEM share Sable’s proposed “update”(actually a massive revision) to the SYU Development and Production Plan, as they are obligated to do?
Evaluation of the revised plan will require a detailed environmental review.
Operationally, BSEE and the Coast Guard will need to carefully consider vessel integrity, treatment capabilities, mooring and offloading plans, transportation schemes, gas utilization/injection, and many other technical details.
Meanwhile, does Exxon, the previous (and future?) owner, remain on the sidelines when the OS&T permitting circus begins in earnest?
On September 29, 2025, Sable announced that it is evaluating and pursuing an offshore storage and treating vessel (“OS&T”) strategy to provide access to domestic and global markets via shuttle tankers for federal crude oil produced from the SYU in the Pacific Outer Continental Shelf Area (the “OS&T Strategy”). Continued delays related to the Santa Ynez Pipeline System have prompted Sable to evaluate and pursue the OS&T Strategy. On October 9, 2025, Sable submitted a Development and Production Plan update for the SYU to the Bureau of Ocean Energy Management (“BOEM”). Prior to implementation of the OS&T Strategy, regulatory authorizations are required, including clearance from BOEM.
Preparations for the OS&T Strategy include the acquisition of a suitable OS&T vessel, certain refitting and upgrades to the vessel and the SYU equipment, transportation of the vessel to SYU, and related installation. In connection with implementation of the OS&T Strategy, the Company expects to opportunistically acquire an existing OS&T in the first quarter of 2026, with delivery of the vessel to SYU expected in the third quarter of 2026. Following the acquisition of the vessel, and vessel and platform upgrades and installation, Sable would expect to begin sales from all SYU platforms in the fourth quarter of 2026, with expected comprehensive oil production rates of over 50,000 barrels of oil per day, utilizing the OS&T within the SYU federal leases, provided the Company receives regulatory clearances. Sable estimates that the total capital required to execute the OS&T Strategy is approximately $475.0 million. The Company has already incurred a small portion of such capital expenditures, with the vast majority of such capital expenditures remaining, provided the Company receives regulatory clearances. See “Risk Factors—Risks Associated with Our Operations—In order to commence operations pursuant to an OS&T offtake strategy, we will require clearances and permitting, including from BOEM.”
Next week, BOE will rank the 2025 Gulf of America Safety Compliance Leaders according to the number of incidents of non-compliance (INCs) per facility inspection.
“Exxon spinoff Sable Offshore faces seven barriers to restart its pipeline, idled since a major oil spill in 2015. One of those approvals needs to come from the California Coastal Commission, which Sable CEO Jim Flores criticized for its “Teflon” “eco-Nazi attitude” in a leaked call recording newly obtained by Hunterbrook. Because of these barriers — and despite Trump Administration intervention — Sable’s project, originally scheduled to go online in Jan 2024, may never sell oil. At least not under the ownership of Sable ($SOC), which is quickly running out of cash.“
Exxon’s options per Hunterbrook:
The Exxon purchase agreement gives Exxon a free reassignment option: If Sable fails to “restart production” by Mar. 31, Exxon can demand reassignment of the assets within 180 days, “without reimbursement of any Purchaser costs or expenditures.”
In other words: Exxon can just take back the asset. For free.
And if Sable’s regulatory pathway is really just delayed, not denied — as Sable claims — that may be a more appealing proposition for Exxon than it once was.
Or, perhaps, Exxon will decide to retire the project, recognizing the Sisyphean path to production. (Exxon already took a $2.5 billion write-down as part of exiting offshore operations in California.)
“The objective of this rule is to provide the option for a consolidated application streamlining the process for qualified applicants.”
Reflecting on advances in environmental science, seafloor mapping, and offshore mineral-collection technologies, the revised rule allows qualified companies that gather the necessary site information to proceed to the collection phase. Deepsea mining is now more closely aligned with offshore oil and gas in that companies acquiring licenses are able to proceed to production after regulatory approvals.
The preamble nicely summarizes the opposition to the rule for environmental and jurisdictional reasons:
“General opposition to deep seabed mining was expressed for a variety of stated reasons, including, but not limited to the following assertions: effects on the environment; effects on seabed habitat and to marine species including undiscovered species especially in the Clarion-Clipperton Fracture Zone; harm to cultural resources and Pacific Islander livelihoods and beliefs; inadequate scientific research and information; inadequate resource protection measures and regulations; uncertainties regarding environmental impacts and a nascent industry; significant technical challenges to deep seabed mining; opposition to deep seabed mining from many U.S. states, countries, and global companies; that deep seabed mining is contrary to international agreements and efforts; the need for moratoria; that deep seabed minerals are not needed to meet U.S. demand for critical minerals and domestic sources and recycling of such minerals should be used instead; the U.S. needs to focus on building domestic refineries; using renewable and alternative resources rather than deep-sea minerals; and jeopardizing vital carbon sinks.”
“Commenters stated that acting unilaterally on deep seabed mining undermines the ISA (International Seabed Authority) process, international norms, global stability, and the rule of law, and that it could result in harm to protected areas, such as Areas of Particular Environmental Interest designated by the ISA.”
“The Santa Barbara Channel has been dubbed the Galápagos of North America” ~ Maggie Hall, Environmental Defense Center attorney. (comments: 1. clever branding ala calling ANWR “America’s Serengeti!;” 2. no natural oil seeps in the Galapagos Islands; 3. 130 years of oil production history in the Channel)
Sable opponents organize entertaining rallies featuring famous celebrities:
Ted Danson Jane FondaJulia-Louis Dreyfus
Meanwhile, Sable has some starpower of its own with strong public support from golfer Phil Mickelson.
Senior Federal officials and key agencies are outspoken Sable supporters:
“Only in California! Newsom is blocking oil production off California’s coast from reaching their own refineries, driving gasoline prices even higher for Californians! Now, this oil production will have to be shipped elsewhere, lowering gas prices for other areas— just not for California! This is the opposite of common sense!” ~ Energy Secretary Chris Wright
BSEE declared victory 6 months ago: “This is a significant achievement for the Interior Department and aligns with the Administration’s Energy Dominance initiative, as it successfully resumed production in just five months.”
Perhaps most entertaining are the exchanges on X between Sable bulls and short-sellers. A few examples are embedded below:
Listen Lassy, you could take your signing bonus and have $10 million in cash right now. But that’s short term thinking. Once Big Daddy Trump gets the regulations fixed Sable stock will be worth 50, 60, maybe even 100x that. We’ll be sipping Coffee for Wellness on our yachts in… pic.twitter.com/H2le8c0otE
Good luck but this stock & company are train wrecks. I live close to pipeline so state, local opposition to a restart remains steadfast. Here’s latest news, do your homework.https://t.co/ZfKSKwwrcW
Bud's Offshore Energy (BOE) 