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.”
Pasted below are excerpts from Sable’s Prospectus Supplement. Is Sable serious about pursuing a Santa Ynez Unit strategy that employs a production and treatment vessel 3.5 miles from shore ala the development option that was reluctantly approved by the Federal govt in 1974, two decades before the onshore infrastructure was in place?
The OS&T option is inferior to onshore treatment and pipeline transportation in every way – spill risks, air emissions, economics, ultimate oil recovery, transportation to market, natural gas utilization, and public benefit.
This blogger supports a resumption of Santa Ynez Unit production. However, the only responsible path forward is to do the right thing and continue to pursue the onshore pipeline approvalsadministratively and legally. It is far better to defend a good project than a contrived workaround.
When will BOEM share Sable’s proposed “update”(actually a massive revision) to the SYU Development and Production Plan, as they are obligated to do?
Evaluation of the revised plan will require a detailed environmental review.
Operationally, BSEE and the Coast Guard will need to carefully consider vessel integrity, treatment capabilities, mooring and offloading plans, transportation schemes, gas utilization/injection, and many other technical details.
Meanwhile, does Exxon, the previous (and future?) owner, remain on the sidelines when the OS&T permitting circus begins in earnest?
On September 29, 2025, Sable announced that it is evaluating and pursuing an offshore storage and treating vessel (“OS&T”) strategy to provide access to domestic and global markets via shuttle tankers for federal crude oil produced from the SYU in the Pacific Outer Continental Shelf Area (the “OS&T Strategy”). Continued delays related to the Santa Ynez Pipeline System have prompted Sable to evaluate and pursue the OS&T Strategy. On October 9, 2025, Sable submitted a Development and Production Plan update for the SYU to the Bureau of Ocean Energy Management (“BOEM”). Prior to implementation of the OS&T Strategy, regulatory authorizations are required, including clearance from BOEM.
Preparations for the OS&T Strategy include the acquisition of a suitable OS&T vessel, certain refitting and upgrades to the vessel and the SYU equipment, transportation of the vessel to SYU, and related installation. In connection with implementation of the OS&T Strategy, the Company expects to opportunistically acquire an existing OS&T in the first quarter of 2026, with delivery of the vessel to SYU expected in the third quarter of 2026. Following the acquisition of the vessel, and vessel and platform upgrades and installation, Sable would expect to begin sales from all SYU platforms in the fourth quarter of 2026, with expected comprehensive oil production rates of over 50,000 barrels of oil per day, utilizing the OS&T within the SYU federal leases, provided the Company receives regulatory clearances. Sable estimates that the total capital required to execute the OS&T Strategy is approximately $475.0 million. The Company has already incurred a small portion of such capital expenditures, with the vast majority of such capital expenditures remaining, provided the Company receives regulatory clearances. See “Risk Factors—Risks Associated with Our Operations—In order to commence operations pursuant to an OS&T offtake strategy, we will require clearances and permitting, including from BOEM.”
The State has asked the 9th Circuit Court of Appeals to set aside these three PHMSA orders:
PHMSA order to assume exclusive jurisdiction over the Los Flores Canyon pipelines
PHMSA order approving the restart plan for those pipelines
PHMSA order issuance of an Emergency Special Permit to Sable Offshore
In light of the venue and the clear language in the 2015 Consent Decree regarding the California Fire Marshal’s jurisdiction, the State’s petition would seem to have a good chance of success.
“Exxon spinoff Sable Offshore faces seven barriers to restart its pipeline, idled since a major oil spill in 2015. One of those approvals needs to come from the California Coastal Commission, which Sable CEO Jim Flores criticized for its “Teflon” “eco-Nazi attitude” in a leaked call recording newly obtained by Hunterbrook. Because of these barriers — and despite Trump Administration intervention — Sable’s project, originally scheduled to go online in Jan 2024, may never sell oil. At least not under the ownership of Sable ($SOC), which is quickly running out of cash.“
Exxon’s options per Hunterbrook:
The Exxon purchase agreement gives Exxon a free reassignment option: If Sable fails to “restart production” by Mar. 31, Exxon can demand reassignment of the assets within 180 days, “without reimbursement of any Purchaser costs or expenditures.”
In other words: Exxon can just take back the asset. For free.
And if Sable’s regulatory pathway is really just delayed, not denied — as Sable claims — that may be a more appealing proposition for Exxon than it once was.
Or, perhaps, Exxon will decide to retire the project, recognizing the Sisyphean path to production. (Exxon already took a $2.5 billion write-down as part of exiting offshore operations in California.)
“The Santa Barbara Channel has been dubbed the Galápagos of North America” ~ Maggie Hall, Environmental Defense Center attorney. (comments: 1. clever branding ala calling ANWR “America’s Serengeti!;” 2. no natural oil seeps in the Galapagos Islands; 3. 130 years of oil production history in the Channel)
Sable opponents organize entertaining rallies featuring famous celebrities:
Ted Danson Jane FondaJulia-Louis Dreyfus
Meanwhile, Sable has some starpower of its own with strong public support from golfer Phil Mickelson.
Senior Federal officials and key agencies are outspoken Sable supporters:
“Only in California! Newsom is blocking oil production off California’s coast from reaching their own refineries, driving gasoline prices even higher for Californians! Now, this oil production will have to be shipped elsewhere, lowering gas prices for other areas— just not for California! This is the opposite of common sense!” ~ Energy Secretary Chris Wright
BSEE declared victory 6 months ago: “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.”
Perhaps most entertaining are the exchanges on X between Sable bulls and short-sellers. A few examples are embedded below:
Listen Lassy, you could take your signing bonus and have $10 million in cash right now. But that’s short term thinking. Once Big Daddy Trump gets the regulations fixed Sable stock will be worth 50, 60, maybe even 100x that. We’ll be sipping Coffee for Wellness on our yachts in… pic.twitter.com/H2le8c0otE
Good luck but this stock & company are train wrecks. I live close to pipeline so state, local opposition to a restart remains steadfast. Here’s latest news, do your homework.https://t.co/ZfKSKwwrcW
Unsurprisingly, President Trump was not particularly pleased with Darren Woods’ “uninvestable” quote, the main media takeaway from Friday’s meeting on redevelopment of Venezuela’s oil and gas resources.
Exxon CEO Darren Woods: “If we look at the legal and commercial constructs and frameworks in place today in Venezuela — today, it’s uninvestable.”
The response from President Trump: “I didn’t like Exxon’s response,” Trump said to reporters on Air Force One as he departed West Palm Beach, Florida. “They’re playing too cute.” He told reporters he was inclined to deny Exxon any role in rebuilding Venezuela’s oil industry.
If Exxon is now in the President’s doghouse, what does this mean for the Santa Ynez Unit, an Exxon orphan that was adopted by Sable Offshore? Given Sable’s financial challenges, the SYU may soon be returning to Exxon.
Regardless of ownership, an SYU production restart faces strong opposition in California and is fully dependent on an assertive and supportive Federal government. Meanwhile, an injunction on SYU production remains in place, and despite rumors to the contrary, Sable confirms they are complying with that order.
The number of BSEE inspections in 2025 (first chart) remained relatively constant despite the extended government shutdown.
The decline in the number of Incidents of Noncompliance (INCs) in 2025 is encouraging (chart 2).
Given that BSEE’s tables have yet to be updated to include 2024 incidents, let alone 2025, it’s difficult to assess whether there have been similar declines in the number and severity of incidents. We do know that there were no occupational fatalities in 2025. (Note that OCS incident tables were once updated within 30 days at the end of each quarter. The public has a right to timely information on the type of incidents that are occurring, the operating companies, and the resulting casualties, pollution, and property damage.)
Chart 3 shows the decline in INCs by type – warnings, component shut-ins, and facility shut-ins
As is typically the case, a few companies accounted for a disproportionate number of violations, most notably the Cox legacy operators. More on this in a subsequent post.
The top 6 oil producers all had excellent compliance records, as did a leading shelf operator. More to follow.
Sable Offshore, California’s most notorious operator, fared well during 77 inspections of their three platforms in the Santa Barbara Channel.
The Commission’s letter to PHMSA is attached (click on pages to enlarge). The CCC asserts the right, pursuant to the Coastal Zone Management Act, to review Sable’s restart/special permit application and further asserts that PHMSA’s special permit should be stayed pending their review.
The Commission also raises NEPA and Consent Decree compliance issues, and implies that PHMSA’s designation of the pipeline as “interstate” is subject to consistency review.
$SOC Field Update: Hydro-testing finalized this morning. System has officially transitioned to Line Fill. Nitrogen displacement by crude is underway. Expecting first oil at Pentland early-mid Jan. The operational window is now locked.
$SOC: Ninth Circuit order grants leave to intervene, but denies the request to stay PHMSA’s Dec. 22 Restart Plan approval and Dec. 23 Emergency Special Permit. Case is expedited and goes on the next available calendar. Briefing: opening Jan. 26, 2026; answering Feb. 17;… pic.twitter.com/YdGeVMu6cI
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
Bud's Offshore Energy (BOE) 