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?
Judge Donna Geckupholds restraining orderlarge investment in Sable
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?
John Smithhas 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.
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.“
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.
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:
A company bought a cursed oil field that ExxonMobil abandoned after 7 years of failure.
They financed the purchase mostly with a loan from… Exxon itself.
Now they're fighting California, the courts, the Coastal Commission, and their own investors — simultaneously.$SOC is… pic.twitter.com/rdGSNMQE1A
Updatedincident tables for OCS oil and gas operations. The most recent data are for 2023! Providing timely details on incidents is a fundamental responsibility of a safety regulator.
A summary of incidents associated with the OCS wind program. From press reports, we know about the fatality during Empire Wind construction. What other incidents have occurred to date?
Information on the mysterious sinking of the Aban Pearl semi-submersiblein May 2010. An investigation was conducted, but the report was never shared. In the interest of offshore safety, the new regime in Venezuela should release this report.
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)
operator
W
CSI
FSI
total INCs
Facility Insp.
INCs/isp
Array
352 311 41
93 46 47
6 6 0
451 363 88
218 184 34
2.1 2.0 2.6
NRW
10
24
1
35
5
7.0
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).
operator
W
CSI
FSI
total INCs
facility insp
INCs/ fac. insp
Greyhound Energy
32
1
0
33
23
1.4
Renaissance Offshore
26
19
3
47
44
1.1
Sanare Energy
60
20
2
82
75
1.1
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).
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: