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The Case for Reefing California Platforms by John Smith

Environmental groups like the Environmental Defense Center and Get Oil Out continue to oppose converting the jackets of California oil and gas platforms to artificial reefs despite scientific studies (Claisse et al. 2014) showing “oil and gas platforms off the coast of California have the highest secondary fish production per unit area of seafloor of any marine habitat that
has been studied.

Another important factor environmental groups and the 2023 BOEM Programmatic EIS for Decommissioning failed to consider and acknowledge is the huge amount of air emissions that would be released by world-class heavy lift vessels like the Thialf or Balder Semi-submersible Crane Vessels (SSCVs) that would be required to safely and efficiently remove the large federal OCS platforms like Harvest, Hermosa, and Hidalgo (HHH). The HHH platforms are in waters depths ranging from 430-675 feet and have combined deck and jacket weights ranging from 20,000 – 25,000 tons. In comparison, the wrought iron structure of the Eiffel Tower weighs about 8,000 tons.

The SSCVs and accompanying Anchor Handling Tugs (AHTs) used to remove the HHH platforms will likely to be mobilized from distant locations like the North Sea or Gulf of America where they typically operate. Because SSCVs like the Thialf and Balder are too large to enter the Panama Canal, this would involve a 20,000 nautical mile roundtrip voyage around the tip of South America.

Three to four campaigns, and separate SSCV and AHT mobilizations and demobilizations, are projected to be required to fully remove the HHH platforms because the challenging oceanographic conditions offshore Point Arguello restrict heavy lift operations to a 150-day period between May and October.

Four campaigns by the SSCV and AHT would consume about 300,000 metric tons (mt) of marine diesel oil and release approximately 470,000 mt of CO2 and 11,000 mt of NOX emissions. To put these numbers into context, 470,000 mt of CO2 and 11,000 mt of NOX are:

  • the amount of CO2 emissions released by providing electrical power to 97,600 homes annually (the city of Santa Barbara has about 38,000 housing units).
  • the amount of CO2 emissions released by burning 1.1 million barrels of oil.
  • the amount of CO2 emissions released by 102,000 gasoline burning cars annually.
  • the amount of NOX emissions released by four large oil or coal-fired power plants annually.
  • the total annual NOX emissions in Santa Barbara County.

And this is only the emissions released during mobilization and demobilization of the SSCV and AHT. If full removal is required, an additional 50 days of operational time by the SSCV and AHT is estimated to be required to remove the topside and jacket of each HHH platform. This could be reduced to about 15 days per platform if the jackets are converted to artificial reefs. Only one SSCV and AHT campaign may be required if the HHH jackets are reefed, compared to the four campaigns required for the full removal scenario. This would result in a 75 percent reduction in CO2 and NOX emissions.

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Photos courtesy of Glenn’s sister and MMS colleague Eddie Lee Lim

On February 27, 2026, we lost a long-time pillar of the OCS safety program, the foremost authority on California offshore oil and gas operations, and a wonderful friend and colleague.

Glenn Shackell grew up in Hawthorne, California, where he lived most of his life. He attended Hawthorne High with the Beach Boys!

Glenn served as a helicopter door gunner during the Vietnam War, an extremely hazardous assignment. According to historical accounts, the average life expectancy of a door gunner was two weeks. Think about that! (See the door gunner video embedded below.)

Glenn discussed his Vietnam experience with Minerals Management Service (MMS) colleague Andrew Konczvald:

Glenn told me about encounters when the bullets were hitting the bottom of his Huey helicopter, and he was sitting on his personal armored jacket as the only protection against the bullets! He told me how he prayed every night and miraculously escaped wounds and returned home safely.

Thankfully, Glenn survived and returned to earn a Petroleum Engineering degree from the Univ. of Southern California. He was a proud USC Trojan.

Glenn had an outstanding career in our Pacific Region office, starting in the early days when the OCS regulatory program was part of the US Geological Survey. He assessed and monitored drilling and production operations in the region, which once produced 120,000 bopd from 23 platforms, and had up to 9 mobile drilling units operating concurrently. Floating drilling operations were pioneered offshore California with the CUSS 1, and production was extended to 1200 feet of water at Platform Harmony.

Glenn had an encyclopedic knowledge of the California offshore sector, and was an expert on the history of the applicable regulations, orders, and standards. We had countless discussions about topics like OCS Order No. 2 (Drilling) and the evolution of API RP 14C (Production Safety Systems).

Glenn served on numerous MMS teams that evaluated the latest technical innovations of the offshore industry, established research priorities, and assessed safety and environmental performance. He was an authority on drilling safety and was called on to evaluate and accredit well control training programs.

Glenn respected everyone, and everyone admired and respected him. He was a man of faith, but didn’t impose his beliefs on others. Fittingly, his favorite Bible passage was John 11:25-26: Jesus tells Martha, “I am the resurrection and the life. The one who believes in me will live, even though they die; and whoever lives by believing in me will never die.”

RIP Glenn, you continue to inspire your friends, and your important contributions to society live on. We love you man!

The HORRORS of Door Gunners in Vietnam:

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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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The State has asked the 9th Circuit Court of Appeals to set aside these three PHMSA orders:

  • PHMSA order to assume exclusive jurisdiction over the Los Flores Canyon pipelines
  • PHMSA order approving the restart plan for those pipelines
  • PHMSA order issuance of an Emergency Special Permit to Sable Offshore

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All eyes are on the 9th Circuit. No injunction yet. Will the Court intervene to block Sable?

No evidence of intervention by the State.

Does Sable restart production tomorrow?

Traders on edge. Bulls are feeling optimistic. See X post below. 😉

Spend my barrel, parked in a harbor
‘Neath the platform spotlight
Pump it up tight, let the oil start flowin’
A little crude movin’ on a federal green light
Fits my life, oh so right

My Sable Offshore Delight— Victory II (@VictoryII1) December 30, 2025

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Sable Offshore is attempting to restart the same pipeline that caused the Refugio Oil Spill in 2015. | Credit: Paul Wellman File Photo

Sable Offshore oil believes the federal Pipeline and Hazardous Materials Safety Administration (PHMSA) , not the California Fire Marshal, should have jurisdiction over the company’s onshore pipeline.

I once had the same opinion as Sable. Their pipeline is, by definition, an interstate line because it carries OCS production. Then I read Appendix D of the court approved Consent Decree that was executed following the 2015 Refugio pipeline spill. That Decree is quite clear regarding regulatory jurisdiction, and would have to be overturned to transfer authority to PHMSA.

The full Consent Decree is attached. Pasted below is an excerpt from Appendix D:

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Kayla Bartkowski/Los Angeles Times/Getty Images

WSJ article on Sable Offshore:

“Oil giants have fled California, but James Flores is desperate to get in, even if it means crossing swords with the state.”

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The press release and full program are linked. It looks like the most recent leaks were accurate. See the maps below with the locations and dates. This will stir the pot!

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Per the Washington Post, the Administration’s 5 Year Oil & Gas leasing plan will include (in addition to the Central and Western Gulf):

  • Six offshore lease sales between 2027 and 2030 in areas along the California coast
  • Expansion of leasing into the Eastern Gulf of America (Gulf of Mexico per the Post)
  • 20 sales offshore Alaska through 2031 (presumably this includes the mandated Cook Inlet sales)

Previous post about 5 Year Plan speculation

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