BOEM’s Final Notice of Sale (FNOS) for Big Beautiful Gulf 1 (BBG1), to be published in the Federal Register on November 10, 2025, will offer for leasing approximately 15,083 unleased OCS blocks located across the Gulf of America (GOA) – all, regardless of water depth, at the lowest allowable federal offshore royalty rate of 12.5%. BBG1 will be held on December 10, 2025, and is the first of 30 federal offshore lease sales mandated by the One Big Beautiful Bill Act (OBBBA), Pub. L. No. 119-21, which was signed into law on July 4, 2025.
The FNOS contains details regarding lease terms and conditions for BBG1. Pursuant to the OBBBA, BBG1 is legislatively required to offer at least 80 million acres (or all unleased GOA OCS lands not subject to a prohibition against or restricted from leasing). The OBBBA also legislatively mandates that leases in water depths of 800 meters or greater have a 10-year initial term. The FNOS incorporates these requirements, as well as the Form BOEM 2005 (February 2017) lease form and most stipulations from Lease Sale 254 held in 2020, which were also legislatively mandated for BBG1 and future lease sales occurring pursuant to the OBBBA.
With respect to the Rice’s whale, an endangered species with its exclusive habitat in the GOA, the Lease Sale 254 Protected Species Stipulation applicable to BBG1 contains no provisions specific to protecting the Rice’s whale. However, the Information to Lessees document provided as part of the BBG1 FNOS package notifies potential bidders of the National Marine Fisheries Service’s (NMFS) recent programmatic Biological Opinion, issued on May 20, 2025, (2025 NMFS BiOp) and notes that “the 2025 NMFS BiOp includes a jeopardy finding for the Rice’s whale, and a reasonable and prudent alternative (2025 RPA) that is currently under review and discussion at the Department, Bureaus, and NMFS.” While the 2025 NMFS BiOp is not mentioned in the stipulation, BOEM advises bidders that “under the 2025 NMFS BiOp, certain post-lease approvals (e.g., for activities involving new and unusual technologies, certain tiers of seismic surveys, including certain ancillary geological and geophysical [G&G] surveys), will require an ESA [Endangered Species Act] review by BOEM, and applicable protocols and/or COAs [Conditions of Approval] will be applied per the 2025 NMFS BiOp, subject to additional mitigations to protect ESA-listed species.” BOEM further advises that amendments to the 2025 NMFS BiOp and related permit conditions will be binding on future lease actions for leases issued pursuant to BBG1.
Leases issued in BBG 1 may include Royalty Suspension Volumes (RSVs), which are designed to promote development, increase production, or encourage production of marginal resources on certain leases or categories of leases. Details relating to eligibility and implementation of RSVs are located at 30 CFR part 203.
Bid opening for BBG1 will be available for public viewing on BOEM’s website at https://www.boem.gov/Sale-BBG1 via live-streaming video beginning at 9:00 a.m. on December 10th.
For more information, contact Liskow attorneys Jana Grauberger and Kathleen Doody, and visit Liskow’s Energy-Regulatory practice page.