JL Daeschler shared a London Sunday Times piece about the Piper Alpha fire that killed 167 workers, the worst tragedy in the history of the offshore industry. We were troubled by the headline, because it seems inconceivable that any UK offshore worker could call July 6, 1988, the best day of their life. However, Punchard helped a number of workers escape the fire, so his mixed message is somewhat understandable.
Lord Cullenās comprehensive inquiry into the Piper AlphatragedyĀ challenged traditional thinking about regulation and how safety objectives could best be achieved, and was perhaps the most important report in the history of offshore oil and gas operations.Ā That report and the US regulatory response to the tragedy are discussed in this post.
BSEE’s new downhole commingling rule, which responds to a Congressional mandate, is contrary to Cullen’s Safety Case principles in that it puts the burden of proof on the regulator to conclusively demonstrate that a potentially hazardous operation is unsafe.This is exactly the opposite of the approach recommended by Cullen. It’s also the first time in the history of the OCS program that Congress has dictated approval of complex downhole operations. More on this in a later post.
In addition to the Johnson filing, at least 7 other law firms (links below) have announced class action litigation alleging that Sable Offshore made false or misleading statements regarding the restart of Santa Ynez Unit production.
āThis is a significant achievement for the Interior Department and aligns with the Administrationās Energy Dominance initiative, as it successfully resumed production in just five months.ā
Will the Dept. of Justice intervene on behalf of Sable?
Meanwhile, Sable’s share price rebounded in mid-July and is holding up surprisingly well (see below). Perhaps investors don’t see the class action suits as a significant incremental threat given the risks associated with decisions by 8 California agencies, Santa Barbara County, and various judges, and the persistent challenges by well-organized opponents of offshore production.
BOEM tweet (12/8/2023):Offshore wind is a once-in-a-generation opportunity to build a new clean energy industry, tackle the climate crisis, and create good-paying jobs, while ensuring economic opportunities for all communities.BOEM tweet (7/31/2025): Americaās offshore energy resources are powering the nation. In FY2024 that looks like 668M barrels of oil, 700B cubic feet of natural gasBSEE 2023 logoBSEE 2025 logo
BTW, the new BSEE logo appears to have been influenced by the masterpiece Rig at Sunset š š
On July 25, 2025, more than 2 months after Sable’s brief production restart and 7 weeks after a court decision halted further production, BSEE surprisingly announced the resumption of Santa Ynez Unit (SYU) production boasting:
“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.“
Were the authors of the press release unaware that the SYU production, which was largely from well tests, was halted by court order shortly after it began? More philosophically, is such cheerleading appropriate for the principal safety regulator, particularly given that BSEE is engaged in litigation over its practices in facilitating SYU production?
Ironically, just 3 days after BSEE hailed the resumption of production, the attached lawsuit was filed on behalf of investors who purchased Sable Offshore securities between May 19, 2025 and June 3, 2025. BOE contributor John Smith shared the filing.
The plaintiffs allege misleading statements regarding the resumption of production. Some of the key points cited in the filing:
On May 19, 2025, before the market opened, the Company issued a press release entitled āSable Offshore Corp. Reports Restart of Oil Production at the Santa Ynez Unit and Anticipated Oil Sales from the Las Flores Pipeline System in June 2025.ā
The release informed that Sable expected to fill the ~540,000 barrels of crude oil storage capacity at LFC (Los Flores Canyon onshore processing facility) by the middle of June 2025 and subsequently recommence oil sales in July 2025.
Following the May 19 Press Release, Sable Offshore stock climbed from a closing price of $28.86 per share on May 16, 2025 to $33.02 per share on May 19, 2025, a 14.4% climb in share price.
Contrary to Defendantsā representations, Sable Offshore had not resumed commercial production off the coast of California.
Defendants then used the share price appreciation following the May 19 Press Release to conduct a secondary public offering (or āSPOā) at a higher offering price per share than would have otherwise been possible.
State Lands Commission staff informed the Lt. Gov./Commission Chair that the limited oil flows were the result of well-testing procedures required by BSEE prior to restart. These activities did not constitute a resumption of commercial production or a full restart of the SYU.
Characterizing testing activities as a restart of operations is not only misleading but also highly inappropriate āparticularly given that Sable has not obtained the necessary regulatory approvals to fully resume operations at SYU.
Any attempt to restart commercial operations at the SYU without final regulatory approvals may place the company in violation of its lease terms and jeopardize the status of Sableās holdover State lease.
Santa Barbara County Judge Thomas Anderle granted a preliminary injunction requested by the California Coastal Commission against Sable Offshore for alleged violations of The California Coastal Act.
Given the investigation’s significance, not only for Vineyard Wind, but for other offshore wind projects planned or under construction, how is the delay in issuing the report acceptable?
Keep in mind that the lengthy and complex National Commission, BOEMRE, Chief Counsel, and NAE reports on the Macondo blowout wereĀ published 6 to to 17 months after the well was shut-in.
The Safety Alert is attached. Per BSEE, the fires resulted from an accumulation of gas caused by improperly installed or disconnected exhaust vent piping on gas starters.
Incident 1: Two workers sustained burns to the hands, arms, and face. BSEE investigators discovered that the engineās air intake hose was disconnected, which may have allowed gas-enriched air to be drawn into the carburetor causing the backfire.
Incident 2: While attempting to start the gas engine of a pipeline pump, the lead mechanic sprayed ether into the engineās carburetor. The exhaust vent piping for the starter had not been installed. The combination of the gas-rich atmosphere and ether caused the engine to backfire and ignited the accumulated gas. The lead mechanic, sustained burns to his face, arms, and hands.
The Alert includes important recommendations for proper venting, mechanical integrity awareness training, maintenance, and the use of gas detectors and a temporary fire watch during engine startup.
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 1000ā 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.
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.
Construction 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 habitat
Installation 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 effects
Operation 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 disturbance
Vessels 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 risk
Structures, 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 bats
Turbine 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.
In a peer reviewed paper, AI (Grok-3) debunks the man-made climate crisis narrative.
Doug Burgum: Hydraulic fracturing technology is āone of the reasons why the U.S. shale revolution is a miracle. But that miracle keeps on getting better and better. Itās the thing that has literally turned around the economy.ā Posted here 15 years ago: Natural Gas Bonanza ā Why Arenāt WeĀ Celebrating?
“The State Fire Marshal stated on February 25 āĀ during a packed-house meeting at La Cumbre Junior High SchoolĀ ā that he would not issue Sable authorization to restart production at the Santa Ynez Unit until all outstanding permit issues between Sable and the eight state agencies with oversight authority are resolved.“
Although Sable has a good defense against the Coastal Commission’s accusations, that statement by the Fire Marshal is ominous.
More bad news for Sable: The Center for Biological Diversity suit challenging the Federal government’s extension of the 16 Santa Ynez Unit leases is not going well. The government requested a voluntary remand of BSEEās 2023 approval because “BSEE plans to reconsider its decision in light of Plaintiffsā claims and conduct additional analysis, as warranted, under OCSLA and NEPA.ā
In the attached decision, shared by John Smith, the judge denied the Federal government’s request. This does not bode well for the Federal government’s case going forward.
Bud's Offshore Energy (BOE) 