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Cowboy State Daily photo courtesy Anna Cobb

Sad news reported by the Cowboy State Daily:

“Liam Cobb died Wednesday while working on a wind turbine near Medicine Bow in Carbon County. Anna Cobb said her nephew fell while working his job as a wind turbine technician.”

The Government Accountability Office report on Offshore Wind Energy (full report attached) does a good job of summarizing the potential impacts from offshore wind development. They are categorized in the report as follows:

  • Marine Life and Ecosystems (see table pasted below)
  • Fishing Industry and Fisheries Management
  • Economic Development and Community Impacts
  • Tribal Resources, Including Sacred Sites and Established Fishing Grounds
  • Defense and Radar Systems
  • Maritime Navigation and Safety

Unfortunately, GAO’s recommendations, which focus on consultation and staffing (perennial favorites), are rather meaningless. Does GAO really think more consultation will resolve the fundamental concerns of the tribes and fishing industry? Does GAO really think increasing BOEM/BSEE staff is a solution? Wind was the signature offshore energy program of the previous Administration, and it was well resourced.

When the legislation authorizing offshore wind energy development was drafted, we envisioned energy alternatives that could complement thermal energy sources like gas, coal, and nuclear plants. Natural gas plants are particularly important to intermittent energy sources, because their power can be readily dispatched on demand.

Never did we expect attempts to ban the dispatchable energy sources on which renewable energy goals were dependent. Policies that limit gas production, transportation, and consumption don’t boost offshore wind development, they doom it.

In a rush to achieve the Administration’s energy goals, the wind leasing program brushed aside important economic, safety, national security, and environmental issues. Coastal residents, tribes, fishing interests, power customers, and other affected parties have rebelled. Their concerns won’t be smoothed over by increasing consultation.

So now the wind program is in a dark and windless place (a regulatory dunkelflaute?). Five projects are under construction or in the early stages of operation. Construction has been authorized for 6 other projects. Five more projects are in various stages of permitting. What next?

Meanwhile, we still haven’t seen a report on the ugly and embarrassing Vineyard Wind blade failure offshore Nantucket last July. Shouldn’t that report be a precursor to further offshore wind development in the US Atlantic? Also of note, that same turbine was struck by lightning 2 months ago.

Should directed suspension orders be issued pending a complete review of the wind program? If so, for which leases and for how long? Suspension of projects still in the permitting phase would be relatively painless and maybe even attractive given the current state of the wind industry. However, financial impacts for projects in the construction phase would be significant. These important next-step decisions need to be made soon. Muddling along is not a strategy.

Table 2: Examples of Potential Impacts of Offshore Wind Development to Marine Life and Ecosystems

ImpactDescription
Acoustic disturbanceConstruction and survey activities produce underwater noise that can disturb sensitive marine species. Offshore wind projects take measures to mitigate underwater noise, including the use of bubble curtains to dampen pile driving sound and pausing operations if protected species are sighted.
Changes to marine habitatInstallation of infrastructure, such as turbine foundations and transmission cables, introduces new structures and causes changes to the ocean floor that can alter marine habitat and affect the distribution, abundance, and composition of marine life in the area. These new structures can create artificial habitat that may benefit some species while displacing others and could affect bottom-dwelling species through disturbing the seabed. Artificial habitat effects of wind turbines are well documented, but research is ongoing to monitor and understand impacts on marine life.
Hydrodynamic effectsOperation of wind turbines can affect hydrodynamics and ocean processes such as currents and wind wakes, but little is known about regional effects of widescale deployment on ecosystems.
Vessel disturbanceVessels can disturb some species and pose strike risks to large marine animals, but the increase in offshore wind vessels is projected to be small compared to the total volume of vessel traffic. Offshore wind vessels are required to take measures such as following speed restrictions and employing protected species observers.
Entanglement riskStructures, such as mooring cables from floating wind turbines, could snag fishing gear and other marine debris and create entanglement risk to marine animals. Wind projects employ measures to minimize entanglement (e.g., mooring systems designed to detect entanglement), but there is uncertainty about the extent of the risk from floating turbines because of limited deployment.a
Collision risk to birds and batsTurbine blades pose a collision risk to some sea birds, but little is known about offshore collision risk to bats. Research on collision risks and mitigation measures (e.g., lighting and curtailment) is ongoing.

The “Zero Based Regulatory Budgeting” Executive Order will promote confusion and uncertainty, not sustainable regulatory reform.

The EO requires agencies to issue a rule, effective not later than September 30, 2025, that inserts a sunset date into each “covered regulation.” The sunset date must be 1 year after the effective date of the sunset rule, but may be extended multiple times for a total of up to 5 years.  

From an offshore energy perspective, the confusion starts with the EO’s applicability. One section of the order exempts regulatory permitting regimes authorized by statute. Another section specifies that the order “applies to all regulations issued pursuant to the Outer Continental Shelf Act of 1953 and any amendments thereto.” This is a fundamental contradiction given that OCSLA is a statutory planning and permitting regime. Which regulations are subject to the EO?

Comments:

  • For some reason (too complicated?), EPA and the Army Corps of Engineers are given 30 days to provide a list of statutes that are subject to the EO. Perhaps all affected regulators should have been given 30 days to comment on the draft EO before it was finalized.
  • The EO is sure to create chaos as regulators, under the direction of managers keen on complying with the President’s directive, attempt to determine the EO’s applicability and establish implementation procedures.
  • The EO, which is intended to provide order and certainty, will do exactly the opposite. How does the regulated industry plan for future operations while this vague and controversial “zero based regulatory budgeting” exercise is ongoing? What are the chances of this directive being sustained?
  • Reducing the number of pages in the US Code, while desirable, is not regulatory reform.
  • The order assumes that most regulations are meaningless, which is not the case. What is the plan for filling the void after regulations are deleted?
  • The EO should embrace, rather than circumvent, the notice and comment requirements of the Administrative Procedures Act. The tedious and sometimes burdensome APA has protected the public and the energy industry from countless unjustified, unauthorized, and poorly considered regulatory initiatives.
  • Eliminating rules is not synonymous with establishing a regulatory framework that will improve efficiency and stimulate innovation.
  • Other factors are paramount in improving regulatory effectiveness and efficiency. These include regulatory fragmentation, effective goal setting, management systems, culture, data gathering, performance monitoring, continuous improvement, collaboration, and the adoption of industry standards.
  • Quality regulators are more important than quality regulations. Regulating with fewer rules requires skilled regulators.
  • Agencies should be directed to consider how they can best reduce the regulatory burden without compromising safety and environmental performance. Page reduction should be secondary.

If regulatory efficiency is the goal, this EO is likely to do more harm than good. Federal agencies are largely comprised of bright people with good intentions. Challenge them to propose innovative reforms that will simplify and improve their regulatory regimes.

“The Bureau of Ocean Energy Management’s analysis reveals an additional 1.30 billion barrels of oil equivalent since 2021, bringing the total reserve estimate to 7.04 billion barrels of oil equivalent. This includes 5.77 billion barrels of oil and 7.15 trillion cubic feet of natural gas—a 22.6% increase in remaining recoverable reserves.” 

YearNumber of fieldsOriginal ReservesHistorical Cumulative ProductionReserves
Oil BbblGas TcfBOE BbblOil BbblGas TcfBOE BbblOil BbblGas TcfBOE Bbbl
19752556.6159.917.33.8227.28.662.7932.78.61
19804358.0488.923.94.9948.713.663.0540.210.20
198557510.63116.731.46.5871.119.234.0545.612.16
199078210.64129.933.88.1193.824.802.5336.18.95
199589912.01144.937.89.68117.430.572.3327.57.22
20001,05014.93167.344.711.93142.737.323.0024.67.38
20051,19619.80181.852.214.61163.943.775.1917.98.38
20101,28221.50191.155.517.11179.349.014.3911.86.49
20151,31223.06193.857.619.58186.552.783.487.34.78
20161,31523.73194.658.420.16187.553.583.576.84.79
20171,31924.65195.259.720.78188.954.213.876.35.00
20181,31924.86195.559.721.42189.855.213.445.74.45
20191,32526.77197.061.822.12190.956.094.656.15.74
20231,33630.43201.266.224.66194.059.195.777.27.04
Oil and gas reserves and cumulative production at end of year, 1975-2023, Gulf of America, Outer Continental Shelf and Slope. “Oil” includes crude oil and condensate; “gas” includes associated and non-associated gas. Reserves estimated as of December 31 each year.

This increase in reserves will not please those responsible for the current 5 Year Oil and Gas Leasing Plan. They told us that we don’t need more OCS lease sales and that our biggest concern is producing too much oil and gas for too long!

Page 6 of the Leasing Plan:

The long-term nature of OCS oil and gas development, such that production on a lease may not begin for a decade or more after lease issuance and can continue for decades, makes consideration of net-zero pathways relevant to the Secretary’s determinations on how the National OCS Program best meets the Nation’s energy needs.

Energy experts like Dan Yergin and Vicki Hollub have a much different view. Per Hollub:

Crude reserves are being found and developed at a much slower pace than they’ve been in the past. Specifically, she said the world has only newly identified less than half the amount of crude it’s consumed over the course of the past 10 years. Given the current trends, this means demand will exceed supply before the end of 2025.

A bit off-topic, but Jeff Walker, a former colleague and the MMS Regional Supervisor in Alaska, had the best quip about reserve numbers. In explaining an operator’s revised reserve numbers for a producing unit which had leases with different royalty rates, Jeff noted that “oil always migrates to the lower royalty leases.”😉

  1. Responsible Offshore Development Alliance (RODA), Petitioner, Amicus briefs submitted by Green Oceans, America First Policy Institute, and the Save Right Whales Coalition
  2. Seafreeze Shoreside, Inc., Petitioner, Amicus briefs submitted by Green Oceans, Protect Our Coast NJ, America First Policy Institute, and the Save Right Whales Coalition

Given that the SCOTUS declined to hear a Vineyard Wind challenge by the Nantucket-based ACK for Whales group, the odds of the new challenges being heard would seem to be low. However, it’s noteworthy that both Vineyard Wind and the Federal Government have waived their right to respond to these petitions. The Government’s waiver to respond to the RODA petition is pasted below.

Analysis by Jonathan A. Lesser:

Of all commercial renewable generation technologies, offshore wind is the costliest, far more so than solar photovoltaics and onshore wind. The newest incarnation of offshore wind—floating turbines that can be sited in deep water—are more expensive still. Although offshore wind is supposed to benefit from more prevalent ocean breezes, it remains, like land-based wind and solar power, an intermittent source of electricity. Hence, as offshore wind comprises a larger share of total electricity capacity, it requires ever more backup generation or storage to compensate.”

Offshore wind’s high cost and intermittency raise a simple question: Why have renewable energy advocates and policymakers in many Atlantic Coast states, as well as those on the West Coast, placed such emphasis on this technology? One justification, like all forms of renewable energy, is that offshore wind will reduce U.S. greenhouse gas emissions. Whether that is true remains an open, empirical question. Offshore wind’s high costs, which require substantial—and increasing—taxpayer and ratepayer subsidies, will raise electricity rates and reduce electricity consumption. Even offshore wind manufacturers such as German-based Siemens Energy admit this. By itself, reduced electricity consumption may reduce greenhouse gas emissions slightly, as will offshore wind replacing lower-cost natural-gas-fired generation. However, any such reductions will be so small as to have no measurable effect on climate.

Full article

Sable supporter Trent Fontenot calls out the CCC for government overreach.  Daniel Green / Noozhawk photo

Yesterday, the California Coastal Commission voted 8-3 to fine Sable Offshore $18,022,500 for performing pipeline repairs necessary to minimize operating risks and comply with the FIre Marshall’s requirements.

In the minds of at least some commissioners, Santa Barbara County, which reached agreement with Sable on pipeline repairs, is also a villain in this matter. Per Commissioner Harmon:

“We have not gotten a foothold with Sable, and we’ve not gotten a foothold with Santa Barbara County either. So, we are where we are, and because of this absolute failure of communication and Sable’s, to be frank, absolute failure to follow the law, this hearing has become necessary,” Harmon said.

We’ll see how this gets sorted out in the courts. Sable appears to have a strong case against the Commission, but litigation in California courts is not exactly ideal for oil companies.

China National Offshore Oil Corp. (CNOOC) has surrendered its 21% interest in the Appomattox (Mississippi Canyon 391, 392, and 393) project and its 25% stake in Stampede (Green Canyon 468, 511, and 512). Those ownership positions were acquired in CNOOC’s takeover of Calgary-based Nexen in 2013.

CNOOC had been quite positive about the prospects for Appomattox and Stampede, which are producing at higher than expected rates. However, because of sanctions concerns, an exit from operations in the US, Canada, and the UK had been under consideration for at least 2 years.

CNOOC’s shares of Appomattox and Stampede were acquired by INEOS Energy, a UK company.

The transaction is also discussed in CNOOC’s 2024 Annual Report (p.19).

Stampede TLP

Below are interesting pictures of Vineyard Wind’s repair and installation activity taken today by Nantucket pilot Doug Lindley. He commented that only of the turbines was spinning.

Note the lightning damage to the turbine with the failed blade. The lightning protection system was not operational on that turbine.

Also note the vessel transporting replacement blades.

It’s a bit difficult to rationalize all of this, but the Administration of Massachusetts Governor Maura Healey sees these projects as being critical to the Commonwealth’s energy future.

In December 2023, the Governor ordered a transition away from natural gas and set a goal of making Massachusetts carbon-neutral by 2050. As a candidate for governor in October 2022, then-Attorney General Maura Healey bragged,Remember, I stopped two gas pipelines from coming into this state. This in a State where half of the households are heated with natural gas.

BSEE incident investigations are another window into OCS safety performance.

Panel reports are published for the most significant OCS incidents (e.g. fatalities, serious injuries, significant pollution). Unfortunately, these reports have been unacceptably delayed in recent years. Status reports are not provided leaving the public in the dark as to what is being investigated and why.

The more common investigations, conducted by BSEE’s district offices, are timely and informative. The Districts typically investigate lost time (>72 hours) injuries, crane and lifting equipment incidents, small fires, pollution events, property damage > $25k, gas releases, and other incidents requiring workers to muster for possible evacuation.

The number of District investigations in 2024 declined significantly to 31, one-third fewer than the average of 46.25 for the past 4 years.

Violations were not identified for 2/3 of the incidents.

A complete list of the 2024 District investigations follows. Hyperlinks are provided for those who want to review the reports.

DateOperatorTimeViolation(s)Area/BlockAccident Type
12-25-2024bp1330noGC 584lifting, LTA
11-24-2024Anadarko1710noVK 915Muster, gas release
11-15-2024Anadarko837noGB 668Muster
11-10-2024Murphy145noGC 432LTA
10-12-2024LLOG540yesAC 337LTA – Lifting
10-03-2024Shell900noAC 857Fire, > $25K damage
09-27-2024LLOG200noAC 337LTA, Crane
09-21-2024Talos1630noSM 160LTA
08-11-2024Gulf Offshore1910yesVR 170Fire, Explosion, >$25k, Muster, LTA
07-20-2024Talos2200noSS 224DLTA
07-11-2024Manta Ray730noHI A 5LTA
07-08-2024Cantium1908yesST 23CCLifting
06-05-2024Kosmos1538noMC 727Muster, > $25K
05-31-2024MC Offshore100yesGC 52Crane, > $25K
05-02-2024Murphy1620noGC 478Crane; > $25K
04-24-2024Murphy815noGC 389LTA
04-04-2024Renaissance2230yesVR 369 ALTA
03-28-2024BOE2200yesWR 51LTA
03-20-2024Talos700yesGB 506LTA
03-19-2024Chevron1330noMC 607Lifting, <$25k
03-13-2024Walter2010noSS 189Crane
03-07-2024LLOG1500yesKC 785LTA, lifting
03-05-2024Shell415yesMC 391Pollution, >$25k
02-25-2024Talos930yesSM 130 BCrane,> $25K
02-21-2024W&T1319noHI A 379BFire
02-16-2024Chevron1335noWR 29LTA, Crane
02-13-2024Shell2035noMC 899LTA
02-07-2024Williams855noGA A 244JPLTA
01-29-2024Cantium1900noST 23 CCFire,>$25K
01-18-2024Murphy1303noGC 478Lifting, > $25k
01-16-2024Arena252noSM 128 BFire, > $25K