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Posts Tagged ‘well stimulation’

The Supreme Court has decided to allow the 9th Circuit decision on offshore well stimulation to stand.

From a regulatory and technical standpoint, the 9th Circuit decision is highly questionable. The limited well stimulation operations offshore California were conducted 9-31 years ago and were carefully reviewed and monitored. No fluids were released or escaped to the marine environment.

During the Obama administration (and under the capable leadership of Directors Brian Salerno and Abigail Ross Hopper), BSEE and BOEM conducted a Programmatic Environmental Assessment (EA) and issued a Finding of No Significant Impact (FONSI) from the use of specific well stimulation treatments in oil and gas activities on the Pacific OCS. The 9th Circuit decided that wasn’t enough and the SCOTUS chose not to review their decision.

Given the current state of Pacific offshore operations, the court decisions will have little or no effect on well activity now or in the foreseeable future. If the BSEE well permitting site is up-to-date, there have been no Pacific well operations in the past 3 years. For the 2 years prior to that, the only well operations were for plugging and abandonment purposes. Therefore, the main concerns are the decision to require an EIS prior to any future well stimulation operations, and perhaps more importantly, the implications of the decision on offshore operations elsewhere.

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A full EIS is needed!

Further to the summary from the 2016 EA announcement, it appears that the only Pacific Region well operations over the past 2 years have been for plugging and abandonment purposes. The legal circus continues with or without actual operations.

There have been 24 well stimulation treatments (21 of which involved hydraulic fracturing) on the OCS offshore California between 1982 and 2014, and these were conducted on four of the 23 platforms. Reservoirs on the OCS off Southern California tend to be much more permeable than onshore reservoirs, and are already highly naturally fractured. Therefore, little permeability enhancement has been required for their development. As described in the scenario evaluated in the EA, the future use of Well Stimulation Treatments is expected to continue to be occasional rather than essential to hydrocarbon production from these platforms.

BOEM, 2016

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