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Government Shutdown and BOEM, BSEE and ONRR Contingency Plans

By Kathleen L. Doody & Jana Grauberger on October 14, 2025
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Copy of energy law this week

Due to the government shutdown, which began on Wednesday, October 1, 2025, the Bureau of Ocean Energy Management (BOEM) and the Bureau of Safety and Environmental Enforcement (BSEE) implemented their respective contingency plans that were prepared in the event of a lapse in government funding.  These contingency plans essentially halt renewable energy activities while prioritizing oil and gas projects and permitting during the government shutdown. 

With respect to the Office of Natural Resources Revenue (ONRR), ONRR does not publish its own standalone “contingency plan,” but instead generally operates under the U.S. Department of the Interior’s (DOI) broader contingency plan.

Highlights of the plans are as follows:

BOEM Contingency Plan:

Number and percentage of BOEM furloughed employees: 339 of its 473 employees (or 71% of its workforce)

Continued agency activities (i.e., those activities related to priority and time sensitive offshore oil and gas projects) include, but are not limited to, the following:

  • processing and reviewing certain oil and gas exploration and development plans, to the extent such plans are necessary to protect human life and federal property, including revised plans if they are related to BSEE’s ongoing permitting work;
  • preparing the upcoming Gulf of America Lease Sale 262, scheduled to occur on December 10, 2025;
  • preparing the next National Outer Continental Shelf Oil and Gas Leasing Program;
  • preparing the 2026 offshore critical mineral lease sales; and
  • emergency response activities necessary to protect human life and federal property (for both oil and gas and renewable energy projects);

Ceased agency activities (i.e., those activities deemed non-time sensitive and those unrelated to emergency response for incidents posing a threat to human life and/or federal property) include, but are not limited to, the following:

  • all renewable energy activities (other than emergency response activities, noted above), including permitting, leasing, and environmental reviews;
  • non-time sensitive activities related to offshore oil and gas, including resource and economic evaluations, data releases, and website updates;
  • environmental reviews required by the National Environmental Policy Act;
  • environmental studies under the Outer Continental Shelf Lands Act; and
  • processing and reviewing geological and geophysical permits.

For more information on BOEM’s contingency plan please see the following link:

Bureau of Ocean Energy Management Contingency Plan

BSEE Contingency Plan:

Number and percentage of BSEE furloughed employees: 190 of its 560 employees (or 34% of its workforce)

Continued agency activities (i.e., those activities related to “critical permitting and oversight activities”) include, but are not limited to, the following:

  • processing permits for new wells and well modifications;
  • receiving and reviewing critical plans and documents supporting offshore oil and gas energy, including oil spill response plans;
  • other activities related to safety, environmental protection and emergency response, including drilling oversight activities; and
  • undertaking investigations, inspections, and enforcement activities related to offshore operations.

Ceased agency activities (i.e., those activities deemed non-time sensitive and those unrelated to emergency response for incidents posing a threat to human life and/or federal property) include, but are not limited to, the following:

  • studies unrelated to major ongoing activities;
  • drafting and promulgating non-critical regulations; and
  • website updates.

For more information on BSEE’s contingency plan please see the following link:

Bureau of Safety and Environmental Enforcement Contingency Plan

DOI/ONRR Contingency Plan:

Number and percentage of ONRR furloughed employees: unknown

Continued agency activities include, but are not limited to, the following:

  • energy and mineral revenue collection and disbursement activities.

Ceased agency activities include, but are not limited to, the following:

  • compliance reviews and audit activities;
  • verification of natural resource production meters;
  • royalty valuation;
  • developing and issuing new regulations;
  • enforcement actions;
  • processing of revenue related appeals; and
  • website updates.

For more information on DOI/ONRR’s contingency plan please see the following link:

Office of the Secretary Contingency Plan

Photo of Kathleen L. Doody Kathleen L. Doody

Kathleen Doody is an accomplished oil and gas attorney practicing in the firm’s New Orleans office, with over 15 years of transactional experience representing and advising E&P companies, oilfield service companies and lending institutions on a broad range of corporate, energy, regulatory, secured…

Kathleen Doody is an accomplished oil and gas attorney practicing in the firm’s New Orleans office, with over 15 years of transactional experience representing and advising E&P companies, oilfield service companies and lending institutions on a broad range of corporate, energy, regulatory, secured financing and real estate matters.

Read more about Kathleen L. DoodyEmail
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Photo of Jana Grauberger Jana Grauberger

Jana Grauberger is an oil and gas lawyer with more than 20 years experience. Clients turn to her as a trusted advisor in connection with their contract negotiations, regulatory advice and appeals, litigation, and arbitration related to onshore and federal offshore upstream and…

Jana Grauberger is an oil and gas lawyer with more than 20 years experience. Clients turn to her as a trusted advisor in connection with their contract negotiations, regulatory advice and appeals, litigation, and arbitration related to onshore and federal offshore upstream and midstream projects and facilities. Jana has represented clients in negotiating a wide variety of onshore and offshore contracts, including purchase and sale agreements, farmouts, participation agreements, joint operating agreements, production handling agreements, platform use agreements, gathering agreements, connection agreements, construction contracts, transportation contracts, and decommissioning agreements. She also represents clients in connection with regulatory matters involving Department of Interior agencies, including the Bureau of Ocean Energy Management (BOEM), the Bureau of Safety and Environmental Enforcement (BSEE), and the Office of Natural Resources Revenue (ONRR).

Read more about Jana GraubergerEmail
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  • Posted in:
    Energy and Utilities
  • Blog:
    The Energy Law Blog
  • Organization:
    Liskow & Lewis
  • Article: View Original Source

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