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Posts Tagged ‘pipeline repairs’

John Smith reports that Sable has cleared another significant hurdle in its attempt to restart production in the Santa Ynez Unit. The California DEPARTMENT OF PARKS AND RECREATION has determined that no permit is required for the pipeline anomaly digs in Gaviota State Park (see attached).

The reasons for the exemption are that the project consists of repairs to an existing facility with no expansion of use, and the footprint of the pipeline remains the same.

Maybe the SYU restart is not Mission Impossible after all.

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See the attached letter from Sable’s attorneys; highlights below:

  • The Commission staff appears to be asserting Commission jurisdiction over already permitted activities in order to attempt to exert influence over Sable’s planned restart of the Santa Ynez Unit oil production operations. Jurisdiction over restart activities is entirely outside of the Commission’s jurisdiction and is separately regulated by other agencies.
  • Sable’s repair and maintenance activities (anomaly repairs, safety valve installation, and span remediation) are in compliance with applicable provisions of Santa Barbara County’s Coastal Zoning Ordinance (CZO), certified Local Coastal Program (LCP), and the Coastal Act. As such, no cease and desist order is warranted – whether issued by the Executive Director or the full Coastal Commission.
  • The onshore and offshore repair and maintenance work is fully authorized by coastal development permits previously approved by Santa Barbara County and the Commission. Therefore, those activities do not require new or amended coastal development permits and are not otherwise subject to the Commission’s jurisdiction or enforcement authority.
  • Onshore anomalies: Santa Barbara County reviewed the detailed information Sable submitted with Zoning Clearance applications in 2024 and confirmed in a letter dated February 12, 2025, that the anomaly repair work is authorized by the pipelines’ existing coastal development permits and, consistent with past practice, no new or separate Coastal Act authorization is required for Sable to perform the work. Commission staff has repeatedly ignored that the County — as the applicable agency with delegated LCP authority under the Coastal Act — expressly has confirmed that the anomaly repair work was authorized by the onshore pipelines’ existing Coastal Development Permit, Final Development Plan, and Conditions of Approval.
  • Onshore safety valves: Sable was required to undertake safety valve repair and maintenance activities pursuant to state law that the Coastal Commission supported. The safety valve repair work involves the exact same type of work as pipeline anomaly repairs, and Sable completed the safety valve work only after the County confirmed in writing that no further authorization from the County was required for the safety valves.
  • Offshore span remediation: Sable’s span remediation maintenance activities were fully contemplated and authorized within the original coastal development permit approved by the Coastal Commission for the Offshore Pipelines in 1988 and the Development and Production Plan approved by the Department of the Interior. The span remediation maintenance activities involve the placement of sand-cement bags beneath certain segments of the offshore pipelines to provide additional pipeline support. The exact same support enhancement (span remediation) activities have been performed in the past on these same offshore pipelines without requiring any new Coastal Act authorizations.
  • Sable has filed a lawsuit against the Commission in Superior Court in Santa Barbara County where it has asked the Court for damages and declaratory and injunctive relief to protect its vested rights to repair, maintain and operate the Santa Ynez Unit and Las Flores Pipeline Systems.

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John Smith forwarded Sable’s court filing (attached) and highlighted important text.

The Coastal Commission has asserted that anomaly repair work on Sable’s onshore pipeline, which was required by the California Fire Marshall and approved by Santa Barbara County, constitutes a violation of the Coastal Act.

Santa Barbara County had confirmed in writing that Sable’s repair work is authorized by the pipeline’s existing coastal development permits and, consistent with the County’s past practices, no new or separate Coastal Act authorization is required.

John and I believe Sable has a strong case, but you can be the judge. For the Commission and County to have such divergent opinions is rather surprising.

Among other assertions, Sable argues (par. 115) that the Coastal Commission violated the takings clause of the Fifth Amendment to the U.S. Constitution, as incorporated by the Fourteenth Amendment, which prohibits the temporary or permanent taking of private property for public use without prior, just compensation. This could lead to significant liability costs for the State.

Much more on Sable’s Santa Ynez Unit challenges.

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