# Sable Offshore Corp — Pipeline Special Permit **Citation:** PHMSA-2026-0464 **Type / status:** permit / current **Agency:** Pipeline and Hazardous Materials Safety Administration **Effective:** 2026-06-25 **Published:** 2026-06-25 PHMSA-2026-0464, issued 2026-06-25 for Sable Offshore Corp's hazardous liquid system. ## Document text PHMSA pipeline special permit PHMSA-2026-0464. Operator: Sable Offshore Corp. System: Hazardous Liquid. Issue date: 2026-06-25. <<>> U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION SPECIAL PERMIT Special Permit Information: Docket Number: PHMSA-2026-0464 Requested By: Sable Offshore Corp. Operator ID #: 40881 Original Date Requested: January 22, 2026 Original Issuance Date: June 25, 2026 Effective Dates: June 25, 2026, to June 25, 2036 Code Section(s): 49 CFR § 195.452(h)(4)(iii)(H) Grant of Special Permit: By this order, subject to the terms and conditions set forth below, the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS)1 grants this special permit to Sable Offshore Corp. (Sable). This special permit applies to two segments of the Santa Ynez Pipeline System (SYPS), an interstate hazardous liquid pipeline facility that transports crude oil produced on the Outer Continental Shelf (OCS) through an onshore processing facility located in Santa Barbara County, California, to a terminal located in Kern County, California. The two segments that are subject to the special permit are known as Lines CA-324 and CA-325 (CA-325A and CA-325B). The regulation waived is 49 Code of Federal Regulations (CFR) § 195.452(h)(4)(iii)(H), which requires hazardous liquid pipeline operators to remediate certain longitudinal seam weld corrosion within 180 days of discovery. I. Purpose and Need: Lines CA-324 and CA-325 were originally installed with polyurethane foam and an overlying polyethylene wrap tape to provide thermal insulation. The use of these materials is known to cause shielding, a condition that interferes with the proper functioning of cathodic protection and increases the risk of corrosion in pipeline systems. Sable requested a special permit authorizing an alternative approach for managing the increased corrosion risk on Lines CA-324 and CA-325 1 Throughout this special permit, the usage of “PHMSA” or “PHMSA OPS” means the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration Office of Pipeline Safety. <<>> to implement the terms of a Consent Decree entered in Civil Action No. 2:20-CV-02415 by the U.S. District Court for the Central District of California. The Consent Decree includes provisions to address a rupture that occurred on the SYPS in Santa Barbara County, California, in May 2015. As relevant here, the Consent Decree required the prior operator of the SYPS to obtain a waiver before restarting Lines CA-324 and CA-325 to ensure that effective measures were in place to mitigate the risk of corrosion. The Consent Decree also incorporated the outstanding requirements from a corrective action order that PHMSA issued following the rupture (CPF No. 5-2015-5011H). The CAO required the restart plan for Lines CA-324 and CA-325 to include a long-term plan for managing corrosion under insulation (CUI). The Consent Decree provided multiple options for satisfying this requirement. One of the options was obtaining a special permit that requires: 1) accelerated reassessments; 2) use of appropriate, complementary assessment tools for all threats, including stress corrosion cracking; 3) coordination of data from the appropriate alternating in-line inspection (ILI) technologies; 4) more stringent repair criteria targeted at CUI; and 5) advanced data analysis techniques to account for the potential growth of CUI, including interaction criteria for anomaly assessment.2 The conditions in this special permit address the requirements in the Consent Decree. Specifically, the conditions require substantially more frequent integrity assessments as compared to the pipeline safety regulations at 49 CFR Part 195. Each integrity assessment must use threat-appropriate tools (including for wall loss anomalies from external and internal-based corrosion and for detecting crack anomalies from conditions such as stress corrosion cracking), The conditions also establish more stringent anomaly repair criteria as compared to Part 195; require enhanced data integration from integrity assessments to continuously gauge assessment performance through comparison with in-the-field and other comparative benchmarks; and require the performance of a corrosion growth rate analysis to better inform the analysis of integrity assessment data. PHMSA notes that it previously issued an emergency special permit to Sable for Lines CA-324 and CA-325 imposing substantially similar conditions on December 23, 2025 (Docket no. PHMSA-2025-1502),3 and that the California Office of State Fire Marshal (OSFM) issued waivers to Sable containing essentially the same conditions on December 17, 2024.4 PHMSA further notes that the jurisdictional status of Lines CA-324 and CA-325 has changed since the District Court entered the Consent Decree. At that time, CA-324 and CA-325 were 2 See also PHMSA ADB-2016-04, 81 Fed. Reg. 40398, 40400 (June 21, 2016). 3 The emergency special permit included several conditions which Sable indicated it had completed prior to the effective date of the emergency special permit but that it had not provided to PHMSA for review. Sable provided additional records to PHMSA following the issuance of the emergency special permit, rendering those conditions no longer necessary for inclusion in this special permit. In addition, on February 13, 2026, Sable requested that its application be considered in accordance with the Notice of Limited Enforcement Discretion and Statement of Policy issued by PHMSA on January 12, 2026. As part of that request, Sable agreed to follow the terms and conditions in the emergency special permit until PHMSA issued its decision on this application. 4 OSFM submitted a comment on the docket for this special permit request stating that the proposed special permit conditions removed the state waiver requirement that Sable account for tool tolerance in its evaluation of corrosion anomalies needing remediation prior to restart of the SYPS. As discussed in the SPAF, that requirement was not clearly stated in the state waiver itself, and PHMSA determined that the margin of error afforded by that tool tolerance allowance was not necessary for the conditions to be consistent with pipeline safety. <<>> considered part of an intrastate hazardous liquid pipeline facility subject to regulation by OSFM.5 However, as discussed more fully in the Jurisdictional Determination, PHMSA has since determined that Lines CA-324 and CA-325 are part of an interstate hazardous liquid pipeline facility. Accordingly, PHMSA has the sole and exclusive authority to issue the special permit for Lines CA-324 and CA-325 that Sable has requested in this proceeding.6 II. Special Permit Segments This permit pertains to the specified special permit segments defined in this section. Special Permit Segments: Special Permit Segment Name Location Mileage California County or Counties CA-324 Las Flores Canyon Processing Facility to Gaviota Pump Station 10.86 Santa Barbara CA-325A Gaviota Pump Station to Sisquoc Pump Station 38.72 Santa Barbara CA-325B Sisquoc Pump Station to Pentland Station 74.84 Santa Barbara; San Luis Obispo; Kern III. Conditions PHMSA grants this special permit subject to Sable implementing each of the following conditions. These conditions must be implemented and complied with in addition to all applicable requirements of 49 CFR Part 195 except for compliance with requirements in 49 CFR § 195.452(h)(4)(iii)(H). General Conditions: 1) 2) 3) The special permit segments may only be used to transport crude oil. Prior to transporting crude oil in the special permit segments, Sable must develop and implement procedures for the conditions and requirements described in the special permit. Sable shall not exceed maximum operating pressure (MOP) limits for the special permit segments, as follows: a) The MOP of Line CA-324 cannot exceed 1,003 pounds per square inch gauge (psig). b) The MOP of Line CA-325A (the segment of Line CA-325 between Gaviota and Sisquoc stations) cannot exceed 1,000 psig. 5 See 49 U.S.C. §§ 60101(a)(10) (defining “intrastate hazardous liquid pipeline facility”); 60105 (establishing requirements for State pipeline safety program certifications). 6 49 U.S.C. §§ 60104(c), 60118(c). <<>> 4) 5) 6) 7) 8) c) The MOP of Line CA-325B cannot exceed 1,292 psig between Sisquoc and Check Valve 37, and 1,170 psig between Check Valve 37 and Pentland Station. Sable shall not exceed maximum operating temperature limits for crude oil transported in the special permit segments, as follows: a) The maximum operating temperature of the crude oil transported in Line CA-324 must not exceed 140 degrees Fahrenheit for more than 12 consecutive hours. b) The maximum operating temperature of the crude oil transported in Line CA-325A (the segment of Line CA-325 between Gaviota and Sisquoc stations) must not exceed 125 for more than 12 consecutive hours. Temperature transmitters must be installed on Line CA-325 at Gaviota station to monitor the temperature of Line CA-325A. c) The maximum operating temperature of the crude oil transported in Line CA-325B (the segment of Line CA-325 between Sisquoc and Pentland stations) must not exceed 110 for more than 12 consecutive hours. Temperature transmitters must be installed on Line CA-325 at Sisquoc station to monitor the temperature of Line CA-325B. This special permit does not relieve Sable from complying with applicable requirements under 49 CFR Part 195, other than those waived in this special permit. This special permit does not relieve Sable from any applicable requirements contained in the Consent Decree (United States District Court Central District of California Civil Action No. 2:20-cv-02415). ILIs performed pursuant to this special permit must include a) Use of a tool that is at least capable of reliably detecting and identifying cluster corrosion and general corrosion, defined as follows: i. Cluster means two or more adjacent metal loss features in the wall of the pipe or weld that may interact based on interaction criteria. ii. General corrosion means uniform or gradually varying loss of wall thickness over an area. b) Use of a tool that is at least capable of reliably detecting and sizing corrosion at a 90 percent probability of detection (POD) and probability of identification (POI). c) Use of a tool that is at least capable of reliably detecting and sizing crack or crack-like anomalies at a 90 percent POD and POI. Prior to placing CA-324 in operation, Sable must perform fracture toughness tests on the existing 24-inch pipe from CA-324 in accordance with ASTM E1820-23B Standard Test Method for Measurement of Fracture Toughness. All test specimens must be from the predominant existing 24-inch pipe, specifically API 5L X65 HF-ERW pipe with a nominal thickness of 0.344 inches that was manufactured by Nippon Steel Corp. in the 1980s. At least three separate tests must be performed to obtain the fracture toughness values of the pipe body, heat affected zone (HAZ),7 and the HF-ERW long seam weld on the pipe to represent the fracture toughness of CA-324 (i.e., three samples for pipe body, 7 The HAZ, as used in this special permit, is defined as a 1-inch-wide area on either side of the longitudinal weld seam. <<>> 9) 10) 11) 12) three samples for HAZ, and three samples for the HF-ERW long seam weld). The lowest fracture toughness value must be applied to conditions 11, 16, 17, and 21. Sable may use pipe samples taken opportunistically during ongoing maintenance and repair efforts on Line CA-324.8 Prior to placing Line CA-325 (including CA-325A and CA-325B) in operation, Sable must perform fracture toughness tests on the existing 30-inch pipe from CA-325A/B in accordance with ASTM E1820-23B Standard Test Method for Measurement of Fracture Toughness. All test specimens must be from both of the two following predominant existing 30-inch pipe specifications: a) API 5L X70 pipe with a nominal thickness of 0.281 inches that was manufactured by the various pipe mills in the 1980s. b) API 5L X65 pipe with a nominal thickness of 0.344 inches that was manufactured by the various pipe mills in the 1980s. At least three separate tests must be performed from each pipe mill, for both of the two pipe specifications listed above, to obtain the fracture toughness values of the pipe body, HAZ, and the double submerged arc weld (DSAW) long seam weld on the pipe to represent the fracture toughness of CA-325A/B (i.e., three samples for pipe body, three samples for HAZ, and three samples for the DSAW long seam weld). The lowest fracture toughness value must be applied to conditions 11, 16, 17, and 21. Sable may use pipe samples taken opportunistically during ongoing maintenance and repair efforts on Line CA-325A/B.9 All existing immediate and 180-day repair conditions must be evaluated and remediated pursuant to the Consent Decree repair criteria prior to restarting CA-324 and CA- 325A/B.10 Upon restart Sable must utilize ultrasonic thickness wall measurement (UTWM) and ultrasonic shear wave crack detection (USCD) ILI tools within 7 days of achieving initial steady state operation in accordance with an ILI survey schedule approved by PHMSA. Sable must use the UTWM and USCD ILI results to identify, to evaluate, and to remediate any immediate and 180-day repair conditions listed in this special permit. Remaining strength of pipe calculation for all metal loss anomalies must be in accordance with the Modified B31G method as described in ASME B31G Manual for Determining the Remaining Strength of Corroded Pipelines. If ASME B31G 2012 Edition is used, then it must comply with the conditions in accordance with section 1.2 and exclusions in accordance with section 1.3 of ASME B31G 2012 Edition. However, if the metal loss anomaly intersects or is within 1 inch (circumferentially) of the longitudinal seam weld, Sable must also calculate the predicted failure pressure of the anomaly by using the crack-like flaw evaluation method ASME FFS-1/API 579-1. Sable must use cleaning pigs at regular intervals not to exceed a biweekly basis to 8 Sable indicated in its application that it has already completed all of the testing required in this condition. Sable has submitted fracture toughness results to PHMSA, and PHMSA will review the results and confirm the completion of required testing. 9 Sable indicated in its application that it has already completed all of the testing required in this condition. Sable has submitted fracture toughness results to PHMSA, and PHMSA will review the results and confirm the completion of required testing. 10 Sable indicated in its application that it has already completed the repairs required in this sentence. Sable must submit all relevant records to PHMSA. <<>> maintain adequate cleanliness on the internal pipe wall of the special permit segments. 13) Pressure testing:11 a) Prior to placing CA-324 in operation, Sable must conduct a spike hydrostatic pressure test of CA-324 at a minimum pressure that is at least 1.5 times the maximum operating pressure (MOP) or 100 percent specified minimum yield strength for a minimum of 15 minutes after the spike test pressure is stabilized. Sable must field evaluate and remediate the following anomalies before performing the spike hydrostatic test on CA-324: b) c) d) e) i. ii. All metal loss anomalies that have an ILI reported depth of 40 percent and greater wall loss. All anomalies that have a predicted failure pressure less than or equal to 1.6 times MOP. Immediately following the spike hydrostatic pressure test specified in Condition 13(a), Sable must conduct an 8-hour hydrostatic pressure test of CA-324 at a minimum of 1.25 times the MOP. Prior to placing Line 325A (segment of Line 325 between Gaviota and Sisquoc stations) in operation, Sable must conduct a spike hydrostatic pressure test of CA-325A at a minimum pressure that is at least 1.39 times the MOP, for a minimum of 15 minutes after the spike test pressure is stabilized. Sable must ensure that the spike hydrostatic pressure at the highest elevation of each testable segment is at least 1.39 times the MOP. Sable must field evaluate and remediate the following anomalies before performing the spike hydrostatic test on CA-325A: i. All metal loss anomalies that have an ILI reported depth of 40 percent and greater wall loss. ii. All anomalies that have a predicted failure pressure less than or equal to 1.5 times MOP. Immediately following the spike hydrostatic pressure test specified in Condition 13(c), Sable must conduct an 8-hour hydrostatic pressure test of CA-325A at a minimum of 1.25 times the MOP. Prior to placing Line 325B (segment of Line 325 between Sisquoc and Pentland stations) in operation, Sable must conduct a hydrostatic pressure test of CA-325B at a minimum pressure of 1.25 times the MOP, for a minimum of 8 hours. Sable must ensure that the hydrostatic pressure at the highest elevation of each testable segment is at least 1.25 times the MOP. Sable must field evaluate and remediate the following anomalies before performing the hydrostatic test on CA-325B: i. All metal loss anomalies that have an ILI reported depth of 40 percent and greater wall loss. ii. All anomalies that have a predicted failure pressure less than or equal to 1.4 times MOP. 11 Sable completed all of the testing required in this Condition, but the condition is included for completeness. <<>> f) Sable must obtain approval for each hydrostatic pressure test from PHMSA (or OSFM if such testing was performed prior to November 26, 2025) and have the approved independent testing firm forward separately the certified test results to PHMSA or the OSFM, as applicable. g) Each hydrostatic pressure test must be performed in accordance with the applicable requirements of 49 CFR Part 195 subpart E – Pressure Testing and monitored by an independent testing firm listed under PHMSA or OSFM (as applicable) approved hydrostatic testing companies. h) Failures resulting from the spike hydrostatic pressure test or the 8-hour strength test shall be immediately reported to PHMSA.12 i) Section(s) of the special permit segments that failed during the required hydrotesting must be repaired by removing and replacing the failed section. PHMSA reserves the right to revoke this special permit if failure(s) raise the concern that the special permit segments cannot be safely operated. 14) ILI assessment and frequency: a) Prior to performing ILIs of the special permit segment, Sable shall provide PHMSA with a written notification describing its assessment plan with the following information: i. Dates for integrity assessment. ii. ILI tool(s) selected, in accordance with API Standard 1163, section 5, and NACE SP010213 to assess the integrity of the subject pipe segment(s) in which ILIs must be capable to detect and size wall loss, dents, internal corrosion, external corrosion, cracks and crack-like indications. iii. ILI tool vendor(s). iv. Required tool specifications, including operational specifications and tool validation methodology. v. Anomaly feature identification criteria and reporting thresholds – wall loss, dents, internal corrosion, external corrosion, cracks, and crack-like indications. vi. Criteria used to identify locations for excavation and field verification. vii. Non-destructive examination. b) Within 7 days prior to any anticipated ILI tool run, Sable must use extensive brush pigs and solvents (xylene or other chemicals) to ensure that the internal pipe wall does not have any corrosive products, wax, and bacteria buildup that may affect the ILI tool performance. c) Metal loss tool(s): i. Initial ILI tool runs – Each year, during the first 2 years of operating the 12 All submissions to PHMSA required by this special permit shall be submitted through email to the OPS Western Region Director, Dustin Hubbard, email address, Dustin.Hubbard@dot.gov, or his designee. 13 Industry standards referenced in this special permit must utilize the editions that are incorporated by reference in 49 CFR § 195.3 unless another edition is explicitly specified in this special permit. <<>> d) e) f) ii. special permit segments, Sable shall conduct at least two ILIs using a UTWM tool with an inertial measurement unit (IMU). Sable shall compare both runs and evaluate all available information, including these tool runs and corresponding IMU data. Sable shall perform the UTWM tool run every 6 months not to exceed 9 months. If a UTWM tool run is unsuccessful, Sable shall identify the limitations that prevented the UTWM tool run from being successful, consider changes to increase the likelihood of a successful UTWM tool run, and use best efforts to rerun the UTWM tool within 30 days. Subsequent ILI tool runs – After the first 2 years of operating the special permit segments, Sable shall conduct at least one UTWM each calendar year, not to exceed 15 months, or the ILI assessment must be assessed at more frequent intervals if the remaining failure pressure ratio will be less than 1.39 times MOP prior to the next ILI assessment, based upon anomaly growth estimates and pressure cycling. If any UTWM tool run is deemed to be unsuccessful, Sable shall document the reasons why the UTWM tool was unsuccessful, consider changes to increase the likelihood of a successful UTWM tool run, and must reassess the special permit segment within 30 days after it was deemed to be unsuccessful. All metal loss tool runs must also utilize an IMU. Crack detection tools – Sable shall conduct at least one USCD tool each calendar year, not to exceed 15 months,14 or the ILI assessment must be assessed at more frequent intervals if condition 21 determined a shorter assessment interval. i. These crack tool runs must use an IMU and must be able to detect and size axial and circumferential cracks. ii. USCD performance specification requirements: 1. The USCD tools must have a probability of detection that is greater than or equal to 90 percent for axial and circumferential cracks. 2. The minimum crack depth that can be detected must be at least 1 mm for axial and circumferential cracks located in the base material. 3. The minimum crack depth that can be detected must be at least 2 mm for axial and circumferential cracks located in the weld. 4. The depth sizing accuracy for cracks must be ± 0.8 mm for axial cracks and ± 1 mm for circumferential cracks. Dents and Pipe Deformation: Sable shall conduct a high-resolution deformation ILI tool with each UTWM. Where any ILI tool fails to record data for 5 percent or more of the external and/or internal surface area of the inspected segment, reassess with the ILI tool to cover the area that is deemed to be inadequate data of the inspected segment. In addition, if the ILI tool travels at a speed outside the range of the tool velocity listed in the 14 Sable may petition PHMSA to revise the reassessment interval for crack detection tool(s) when sufficient evidence is available to determine if crack growth rates could support a longer reassessment interval. Changes to the reassessment interval are subject to PHMSA approval. <<>> tool specification for 2 percent or more of the length of the inspected segment, Sable must rerun the ILI tool to reassess the special permit segment in which the ILI tool velocity was outside of the specified tool velocity range. g) Sable must require its ILI tool vendor(s) to include in the vendor’s inspection report all metal loss indications of 10 percent or greater, based on raw data, prior to adding in any correction for tool tolerance. h) Sable must incorporate ILI tool accuracy by ensuring that each ILI tool service provider determines the tolerance of each tool, in accordance with API Standard 1163 Second Edition, and includes that tolerance in determining the size of each indication reported to Sable. i) Sable must account for ILI tool tolerance and anomaly growth rates in scheduled response times, repairs, and future reassessment intervals. Sable must document and justify the values used. Sable must demonstrate ILI tool tolerance accuracy for each ILI tool run by using calibration, excavations, and unity plots15 that demonstrate ILI tool accuracy to meet the tool accuracy specification provided by the vendor (typical for depth within +10 percent accuracy for 80 percent of the time). Sable must compare previous indications to current indications that are significantly different. If a trend is identified where the tool has been consistently over-calling or under-calling, the remaining ILI features must be re-graded accordingly. j) Prior to the ILI final report being received, Sable must perform at least four separate validation digs that do not interact with each other. At a minimum, Sable must perform validation digs in accordance with Level 2 of API Standard 1163, “In-line Inspection System Qualification” (Second Edition, April 2013). 15) Discovery of condition: The discovery date must be within 180 days of any ILI tool run for each type of ILI tool. 16) Immediate repair conditions:16 a) A crack or crack-like anomaly that meets any of the following criteria: i. Crack or crack-like anomaly that is equal to or greater than 50 percent of pipe wall thickness. ii. Crack or crack-like anomaly that has a predicted failure pressure of less than 1.39 times the MOP as calculated using crack-like flaw evaluation method ASME FFS-1/API 579-1. b) c) Internal or external metal loss anomalies where the remaining strength of pipe shows a predicted failure pressure less than 1.39 times the MOP. Any external cluster corrosion or external general corrosion located where the remaining strength of pipe shows a predicted failure pressure less than 1.5 times the 15 A minimum of four independent direct examination excavations must be used for unity plots. 16 The criteria specified in this special permit is supplemental to, and does not relieve Sable from complying with, the requirements set forth in 49 CFR § 195.452(h)(4)(i). All immediate repair conditions must be remediated with a permanent repair method. <<>> MOP.17 17) 180-day repair conditions:18 a) A crack or crack-like anomaly that has a predicted failure pressure of less than 1.5 times the MOP. 18) b) Internal or external metal loss anomalies where the remaining strength of pipe shows a predicted failure pressure less than 1.5 times the MOP. c) All internal or external metal loss anomalies that have an ILI reported depth of 40 percent or greater wall loss, including tool sizing tolerance for depth.19 d) For any crack (likely crack or possible crack) or crack-like anomaly, regardless of its dimensions, that interacts with metal loss anomalies and are within 1 inch (circumferentially) of the longitudinal seam weld, Sable must integrate the ILI results from the most recent crack tool run and the most recent metal loss tool run before the discovery date deadline. Corrosion growth rate analysis (CGRA): a) Sable must develop a CGRA procedure to annually calculate corrosion growth rates between successive ILIs (using most recent ILI compared to prior ILI) and perform pipeline remediations needed to assure the integrity of the special permit segments is maintained.20 The timing of remediations under this condition shall be based on the most recent calculation of short-term corrosion rates. b) The CGRA procedure must include ILI data matching methods21 to analyze data from successive ILIs, methodologies for growth rate calculations and errors from comparing ILI data. c) Sable must identify the projected date when remaining metal loss indications will reach a depth of 70 percent or greater wall loss. d) When determining the projected date when remaining metal loss indications will reach a depth of 70 percent or greater wall loss, Sable must account for reported ILI depth, tool tolerance and corrosion growth rates.22 e) All metal loss indications that are projected to reach a depth of 70 percent or greater wall loss prior to the next ILI, will become actionable and must be remediated before the next ILI. 17 Cluster means two or more adjacent metal loss features in the wall of the pipe or weld that may interact based on interaction criteria. General corrosion means uniform or gradually varying loss of wall thickness over an area. 18 The criteria specified in this special permit is supplemental to, and does not relieve Sable from complying with, the requirements set forth in 49 CFR § 195.452(h)(4)(iii), except for those associated with 49 CFR § 195.452(h)(4)(iii)(H). All immediate repair conditions must be remediated with a permanent repair method. 19 For example, if the ILI tool reports a 31 percent metal loss anomaly and the tool sizing tolerance is ±10 for depth, then this anomaly is a 180-day repair condition since it can be considered as an external metal loss anomaly with 41 percent metal loss depth. If Sable is unable to remediate such indications within 180 days of discovery, Sable must notify PHMSA, temporarily reduce the operating pressure, and take further remedial action in accordance with 49 CFR § 195.452 until the indication is remediated or until otherwise authorized by the PHMSA. 20 At a minimum, Sable must include signal matching between ILI data sets. 21 If there are several matching techniques that can be used, Sable must utilize the most accurate method of comparing ILI data sets. 22 Growth projections must use corrosion rates determined in accordance with the CGRA procedure. A default corrosion rate of 32 mpy must be used in determining projections, if corrosion rates determined by CGRA are less than the default value. <<>> 19) 20) Pressure reduction: If Sable is unable to perform field evaluation and remediation of any required conditions within the time limit conditions specified in this special permit, Sable must temporarily implement a minimum 20 percent or greater operating pressure reduction, based on actual operating pressure for 2 months prior to the date of inspection, until the anomaly is repaired. In field direct examination of pipe: a) Direct examinations23 of pipe must include appropriate non-destructive examination methods for cracking, such as magnetic particle inspection, shear wave technology, or phased array ultrasonic testing (PAUT).24 PAUT must be used for sizing any crack or crack-like anomaly lengths and depths. b) Permanent repairs of metal loss anomalies are required for any section of pipe with wall loss equal to or greater than 40 percent in accordance with repair method 1, 4b, or 5 of Table 451.6.2(b)-1 of ASME B31.4 2006 Edition. However, the following additional conditions apply if Sable chooses repair method 5 for metal loss anomalies: c) d) e) f) i. ii. Method 5 must not be used on metal loss anomalies that are in the HAZ, girth weld, or longitudinal seam weld. Sable must increase the metal loss anomaly’s depth by 20 percent when it inputs it into the formula for calculating the number of wraps needed for repair method 5. iii. After the anomaly is repaired via repair method 5, Sable must monitor the anomaly’s wall loss depth in subsequent UTWM tool runs. If the anomaly’s wall loss depth increases by more than 15 percent of the wall thickness in the subsequent UTWM tool runs, Sable must repair this anomaly via repair method 1 or 4b of Table 451.6.2(b)-1 of ASME B31.4 2006 Edition. Permanent repairs are required for all cracks and/or crack-like anomalies discovered during direct examination, regardless of crack depth or crack length in accordance with repair method 1 or 4b of Table 451.6.2(b)-1 of ASME B31.4 2006 Edition. Sable must develop a coating repair procedure for excavated or remediated corrosion anomalies that prevents further external corrosion and seals transition areas from currently insulated pipe to newly coated sections. Any time a shrink sleeve or coating is exposed, remove the shrink sleeve and coating, investigate circumferentially and longitudinally along the pipe for external corrosion and coating deterioration, and recoat with two-part epoxy. Sable must recoat in accordance with its coating repair procedure. All external polyurethane foam and the polyethylene tape wrap on buried pipe exposed during the field evaluation must not be replaced with new insulation or 23 Any time the pipeline is exposed for direct examination of an indication or to perform a repair, Sable must document the condition of the coating and carrier pipe (including anomalies) with photographs. 24 Direct examinations for ILI reported crack or crack-like indications must include a magnetic particle inspection complemented by shear wave technology or inspection by phased array ultrasonic testing. <<>> polyethylene tape wrap. 21) Integrity management: a) A fracture mechanics and pressure cycling evaluation is required for un-remediated cracks and crack-like indications detected by ILI or indirect inspection tools. i. Sable must determine the predicted failure pressure, failure stress pressure and crack growth of un-remediated cracks and crack-like anomalies in accordance with 49 CFR § 192.712(d)(1). ii. Sable must perform a fatigue analysis using an applicable fatigue crack growth law or other technically appropriate engineering methodology in accordance with 49 CFR § 192.712(d)(2). b) Sable must analyze a sample of additional indications of varying amounts of metal loss between 10 percent and 40 percent for validation. The sample size shall be at least ten, unless fewer than ten indications are reported within that range, in which case Sable would examine the number of indications called. 22) c) When sizing metal loss indications, apply interaction/clustering criteria of 6t by 6t for applicable ILI tool(s). d) Sable must send all field measurements to the ILI tool vendor within 90 days of completing direct examinations and require the ILI vendor to validate the accuracy of the tool. Sable must conduct annual meetings with the ILI tool vendor to discuss tool performance and incorporate lessons learned. e) Sable must utilize a third-party expert to review all ILI reports, verification of digs, data integration, ILI tool tolerances, development of unity plots, measured field findings, failure pressure ratios and any other finding that could affect the integrity of the special permit segments. The review must be conducted within 6 months of each ILI assessment. The third-party expert must be approved by PHMSA prior to being selected. f) Within 1 year from date of issuance, Sable must use a NACE-certified expert to conduct an evaluation and determine if alternating current (AC) interference or direct current (DC) interference or shorting that could contribute to external corrosion is occurring. The expert must recommend the frequency of subsequent interference surveys. All evaluations must be approved and signed by the NACE- certified expert.25 Data requirements for predicted failure analysis: a) Unless the defect dimensions have been verified using a direct examination measurements, Sable must explicitly analyze uncertainties in reported assessment results, including—but not limited to—tool tolerance, detection threshold, probability of detection, probability of identification, sizing accuracy, conservative anomaly, interaction criteria, location accuracy, anomaly findings, and unity chart plots or equivalent for determining uncertainties and verifying tool performance, in identifying and characterizing the type and dimensions of anomalies or defects used in the analyses. 25 Sable completed the evaluation required in this condition, but the condition is included for completeness. <<>> b) The analyses performed in accordance with this special permit must utilize pipe and material properties of the pipe body and longitudinal weld seam that are documented in traceable, verifiable, and complete records. 23) Recordkeeping: a) Procedures, records of investigations, data, analyses, and other actions made in accordance with the requirements of this special permit shall be kept for the life of the special permit segments and must be submitted to the PHMSA in the manner requested (electronic, hardcopy, or other format) within 30 days. b) Sable must maintain the following records: i. Technical approach used for the analysis. ii. All data used and analyzed. iii. Pipe and longitudinal weld seam properties. iv. Procedures used to implement special permit conditions. v. Evaluation methodology used. vi. Models used. vii. Direct in situ examination data. viii. All ILI tool assessments information evaluated. ix. Pressure test data and results. x. xi. All in-the-ditch assessments performed on the special permit segments. All measurement tool, assessment, and evaluation accuracy specifications and tolerances used in technical and operations results. xii. All finite element analysis results. xiii. The number of pressure cycles to failure, the equivalent number of annual pressure cycles, and the pressure cycle counting methodology. xiv. The predicted fatigue life and predicted failure pressure from the required fatigue life models and fracture mechanics evaluation methods. xv. Safety factors used for fatigue life and/or predicted failure pressure calculations. xvi. Reassessment time interval and safety factors. xvii. The date of the review. xviii. Confirmation of the results by qualified technical subject matter expert(s). xix. Approval by responsible Sable management personnel. xx. Records of additional preventive and mitigative measures performed. xxi. Reports required by this special permit. 24) Reporting: a) Any release on the special permit segments shall be reported to PHMSA at the earliest practicable moment following discovery but no later than 24 hours from the <<>> b) c) d) time of discovery.26 An email notification shall be made to PHMSA at least 3 days prior to a special permit segment being exposed for non-emergency purposes of field evaluation and repair. The email notification shall include, if applicable: i. Tool type and run date. ii. Unique identifier (e.g., dig number, joint number, flaw ID, condition type). iii. Dig sheets. iv. Field contact information for Sable. v. Time and location of the field evaluation and repair. Sable shall provide a summary of conditions report within 210 days of the last date of an ILI run to PHMSA and include: i. Tool type. ii. Run date. iii. Summary of conditions report.27 iv. Final vendor report and pipe tally. Sable shall provide a report to PHMSA by June 15 of every year for the duration of this special permit. At a minimum, the annual report shall contain the following, if applicable: i. A closure report for the previous calendar year (CY), which contains: 1. Features that were remediated in previous CY, including documentation for in-the-ditch assessments and repairs. 2. Identify features that remain to be assessed. 3. Unity plots for previous ILI runs. ii. Fracture mechanics and pressure cycling analyses in accordance with condition 21(a). iii. The third-party ILI expert reviews in accordance with condition 21(e). iv. v. AC and DC interference surveys that are due in accordance with condition 21(f). A copy of the CGRA for prior year, including: 1. Mean corrosion growth rate for the special permit segments. 2. Distribution graph of the corrosion growth rate for the special permit segments (e.g., occurrences (#) versus corrosion rate (mpy)). 26 This requirement does not relieve Sable from spill reporting requirements that might exist under local, State, or Federal regulations. 27 PHMSA may stipulate specific formatting or other information (e.g., condition type, anomaly details, remaining strength calculation method, failure pressure, CGRA) to be included in the summary of conditions reports, closure report, and annual reports if information provided is not deemed sufficient. <<>> 25) Limitations: a) b) c) d) e) PHMSA grants this special permit for a period of ten years from the date of issuance. PHMSA may order the special permit segments to be shut down, if appropriate, pursuant to its authority under 49 U.S.C. § 60112. PHMSA may issue a compliance order or may initiate proceedings to determine the nature and extent of the violations and appropriate civil penalty for failure to comply with this special permit. The terms and conditions of any compliance order shall take precedence over the terms of this special permit. In the event of conflict between the conditions of this special permit and industry standards, the special permit conditions shall prevail. If Sable sells, merges, transfers or otherwise disposes of all or part of the assets covered by the special permit, Sable must provide PHMSA with written notice of the change within 30 days of the consummation date. Issued in Washington, D.C. on June 25, 2026. Digitally signed by PAUL ROBERTI Date: 2026.06.25 18:22:33 -04'00' PAUL ROBERTI Paul Roberti, Administrator, Pipeline and Hazardous Materials Safety Administration <<>> June 25, 2026 Lance Yearwood Vice President Sable Offshore Corp. PPC 845 Texas Avenue, Suite 2800 Houston, TX 77002 Re: Docket No. PHMSA-2026-0464 Dear Mr. Yearwood: On January 22, 2026, pursuant to 49 CFR § 190.341, Sable Offshore Corp. PPC (Sable) requested the Pipeline and Hazardous Materials Safety Administration (PHMSA) issue a special permit for segments CA-324 and CA-325 of the Santa Ynez Pipeline System transporting crude oil in Santa Barbara, San Luis Obispo, and Kern counties, California. PHMSA grants that request and issues this special permit waiving compliance with 49 CFR § 195.452(h)(4)(iii)(H) subject to enhanced integrity management conditions. These conditions include, but are not limited to, significantly increased frequency of in-line inspections and more stringent anomaly repair criteria. This and other pertinent documents can be reviewed in Docket No. PHMSA-2026-0464 in the Federal Docket Management System at www.regulations.gov. 1 My staff would be pleased to discuss this special permit or any other regulatory matter with you. Max Kieba, Director, Engineering and Research Division, may be contacted at pipelinespecialpermits@dot.gov for technical matters; and Dustin Hubbard, Director, Western Region, may be contacted at dustin.hubbard@dot.gov, for compliance matters specific to this special permit. Sincerely, Paul Roberti Paul Roberti Administrator, Pipeline and Hazardous Materials Safety Administration 1 https://www.regulations.gov/docket/PHMSA-2026-0464 Emergency Special Permit PHMSA-2026-0464 Letter of Decision– Sable Offshore Corp PPC, CA <<>> U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION Special Permit Analysis and Findings Sable Special Permit Special Permit Information: Docket Number: PHMSA-2026-0464 Requested By: Operator ID#: 40881 Original Date Requested: Original Issuance Date: Code Section(s): Sable Offshore Corp. PPC January 22, 2026 June 25, 2026 49 CFR § 195.452(h)(4)(iii)(H) Purpose: The Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),1 provides this information to describe the facts of the subject special permit application submitted by Sable Offshore Corp. PPC (Sable), to discuss significant public comments received with respect to the application, to present the engineering and safety analysis of the special permit application, and to make findings regarding whether the requested special permit should be granted and, if so, under what conditions. Pipeline System Affected: On January 22, 2026, Sable applied for a special permit seeking to waive the applicability of the requirements in 49 CFR § 195.452(h)(4)(iii)(H) to approximately 124.42 miles of 24- and 30-inch diameter pipe in the Santa Ynez Pipeline System (SYPS). The pipe is part of two SYPS segments, known as Lines CA-324 and CA-325 (CA-325A and CA-325B), that continue the transportation of crude oil produced on the Outer Continental Shelf (OCS) from an onshore processing facility to a terminal in Kern County, California. Additional information about Sable’s special permit application is provided below. Special Permit Request: Sable, in its special permit application, requested a waiver of 49 CFR § 195.452(h)(4)(iii)(H) as applied to Lines CA-324 and CA-325. Without this special permit, 49 CFR § 195.452(h)(4)(iii)(H) would 1 Throughout this special permit the usage of “PHMSA” or “PHMSA OPS” means the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration Office of Pipeline Safety. PHMSA-2026-0464 – Sable Offshore Corp. PPC Special Permit Analysis and Findings – CA Page 1 of 8 <<>> require corrosion of or along a longitudinal seam weld to be scheduled for evaluation and remediation within 180 days of discovering the condition.2 Description and definition of the special permits segments and the pipeline specifications are detailed in Sable’s application letter with attachments in Docket No. PHMSA-2026-0464, including a map of the special permit segments in Attachment A. Public Notice: On February 24, 2026, PHMSA posted a notice of this special permit request in the Federal Register (91 FR 8949) with a closing date of March 26, 2026. On March 20, 2026, PHMSA posted a notice extending the comment period to April 3, 2026, to give the public additional time for review following the issuance of the Defense Production Act (DPA) Order by the Secretary of Energy on March 13, 2026. Sable’s special permit application letter with attachments, the Federal Register notices, environmental assessment, and all other pertinent documents are available for review in Docket No. PHMSA-2026-0464 in the Federal Docket Management System (FDMS) located at www.regulations.gov. PHMSA reviewed all public comments received for Docket Number PHMSA-2026-0464 through April 3, 2026. PHMSA received 58 public comments submitted by both identified and anonymous members of the public concerning this special permit request.3 Significant comments are addressed below. Some comments, which specifically referenced possible environmental effects of the proposed special permit or the environmental assessment prepared by PHMSA, are addressed in the Finding of No Significant Impact (FONSI), also available on Docket Number PHMSA-2026-0464 at www.regulations.gov. Public Comments: Jurisdictional Comments Several commenters questioned whether CA-324 and CA-325 are part of an interstate hazardous liquid pipeline facility subject to PHMSA’s jurisdiction under the Pipeline Safety Act. One commenter argued that the system should be classified as an interstate pipeline because it connects offshore Federal waters to a system terminating at international ports, thereby falling under federal rather than strictly state oversight. PHMSA addresses these comments in a separate document, titled Jurisdictional Determination in Support of Special Permit, that is available for review in the docket. General Comments Many commenters supported the issuance of the special permit, noting that the operation of the SYPS is essential for California’s energy security, economic health, and national interests. Supportive commenters believed the SYPS is ready for a safe restart and referenced the numerous tests, repairs, and system enhancements completed in recent years as demonstrating that the pipeline meets safety 2 OPS published a revision of Hazardous Liquid Integrity Management Frequently Asked Question 7.16 on September 12, 2025 clarifying that corrosion coincident with a longitudinal seam does not need to be mitigated per 49 CFR § 195.452(h)(4)(iii)(H). 3 PHMSA received a total of 12,816 comments on the Sable Offshore Corp. Special Permit request (Docket ID: PHMSA-2026-0464). One comment from a non-profit included a form campaign with over 12,000 signatories. Aside from the form campaign comments, there were a total of 58 unique comments. PHMSA-2026-0464 – Sable Offshore Corp. PPC Special Permit Analysis and Findings – CA Page 2 of 8 <<>> requirements. Supportive commenters explained that increasing domestic oil production will stabilize or lower gas prices, and that the operation of the SYPS is expected to support high wage jobs and generate state and local tax revenues to fund schools, infrastructure, and public services. Supporters pointed out that California imports a large percentage of its oil, that domestic production may protect the state from global supply disruptions, and that oil transported by pipeline has a lower carbon footprint than oil shipped by oceangoing tankers. Some commenters stated that the SYPS is critical infrastructure and argued that the Secretary of Energy’s DPA Order demonstrates the strategic importance of the pipeline system for national energy reliability. Thirty-one comments, submitted by anonymous and identified individuals as well as several organizations, opposed the issuance of the special permit. The opposing commenters stated that granting the special permit would prioritize corporate profit over the safety of the environment, wildlife, and local communities. Some commenters referenced the 2015 failure of Line CA-324 and resulting release of crude oil. Commenters pointed out that corrosion caused the 2015 spill, and stated that the special permit does not address the underlying cause of the incident – an inadequate coating and insulation system that shields the steel from effective cathodic protection – and would waive a regulatory provision involving corrosion repair deadlines. In response to these comments, PHMSA notes that the special permit conditions address the risks of corrosion occurring underneath insulation on the SYPS. Corrosion-driven metal loss is detectable using ILI tools and can be remediated using more stringent repair criteria, including the use of corrosion growth rate assessments. PHMSA further notes that the special permit only waives the requirement that Sable remediate certain longitudinal seam weld corrosion within 180 days, and that the waiver is subject to additional and more stringent conditions, including anomaly detection and repair deadlines calibrated to address corrosion that could threaten the pipeline integrity. In addition, PHMSA notes that the pipe in segments CA-324 and CA 325 is not particularly susceptible to longitudinal seam weld corrosion, meaning that the waiver and conditions, in combination, enhance the safety of the pipeline. The limited effectiveness of cathodic protection beneath insulation does not mean that corrosion on the pipeline cannot be adequately addressed to maintain the safety of the pipeline, particularly in light of the additional and more stringent conditions included in the special permit. Comments Regarding the National Energy Emergency and the DPA Order PHMSA received several comments addressing the potential impact that the DPA order might have on issuing the special permit, including whether the special permit remains necessary. Sable submitted a comment asserting that the special permit is necessary to fulfill the DPA Order and to resume hydrocarbon transportation during a national energy emergency, while implementing safety measures that exceed standard Federal pipeline safety requirements. Sable’s submission included an extensive expert declaration from Michael J. Rosenfeld, P.E., who explained that the use of state-of-the-art, multi-tool in-line inspections (ILIs) performed much more frequently than the industry standard— coupled with more stringent anomaly repair criteria—effectively mitigates risks related to cathodic protection shielding and elevated operating temperatures. Other commenters stated that issuing the special permit is consistent with the DPA, and that the Secretary of Energy directed Sable to re-start the pipeline on March 13, 2026, under the authority of the DPA, so issuing the special permit is justified. Other commenters disagreed and stated that the DPA has no bearing on the special permit. These commenters stated that the DPA Order itself is unlawful and does not supersede safety requirements PHMSA-2026-0464 – Sable Offshore Corp. PPC Special Permit Analysis and Findings – CA Page 3 of 8 <<>> under the Pipeline Safety Act. In response to these comments, PHMSA notes that the Secretary of Energy issued the DPA Order separately from PHMSA’s consideration of Sable’s special permit request, and that PHMSA does not have authority to ignore, override, or otherwise nullify the DPA Order. PHMSA has determined that it remains appropriate to consider and to issue the special permit with conditions that are consistent with pipeline safety. Opposing commenters stated that the operation of the SYPS is not needed to address a national energy emergency, pointing to data and economic models indicating that restarting the pipeline would have limited impact on statewide or national energy markets. They also claimed the local economic benefit would be negligible compared to the risk, stating the local economy relies on tourism, recreation, and fishing, which were negatively impacted following the 2015 spill. One commenter claimed that many workers are brought in from Gulf states and live on the offshore platforms, meaning the pipeline restart would result in no benefits to local jobs or businesses. In response to these comments, PHMSA notes that Sable’s application included multiple reports (Attachments C, D, E, and F) describing the economic and energy impact of the SYPS on Kern County and California. The possible negative impacts of a spill do not outweigh these benefits because PHMSA has determined that the special permit maintains pipeline safety, meaning there is no increased risk of spills occurring compared to operation of the SYPS absent the special permit. PHMSA also notes that while special permit applications must provide a description of impacts on affected stakeholders, the decision of whether to grant the application turns on whether the special permit would be consistent with pipeline safety. While PHMSA believes that operation of the SYPS will be economically beneficial, that determination is not necessary to issue this special permit. Instead, PHMSA issues this permit because it has determined that the pipeline’s operation is consistent with pipeline safety. Commenters also stated that PHMSA does not have the authority to issue the emergency special permit (ESP) or the special permit. Specifically, commenters stated that issuing the special permit per E.O. 14156 was improper because the E.O. does not supersede applicable law, statutory protections, or state governance. Commenters also stated that the ESP did not meet the definition of emergency, which should be reserved for incidents like hurricanes or spills. Another commenter stated that PHMSA’s Notice of Limited Enforcement Discretion and Statement of Policy for Issuing Special Permits in Response to National Energy Emergency is an inappropriate application of PHMSA’s enforcement responsibilities, and that PHMSA did not adequately justify how issuing the ESP and the special permit would meet the purpose and need and address the energy emergency. In response to these comments, PHMSA notes that it is authorized to grant special permits on an emergency basis under 49 U.S.C. § 60118(c)(2) and 49 CFR 190.341(g), and that the ESP expired on its own terms in February 2026. PHMSA further notes that 49 CFR 190.341(g) defines emergency as an event that may be: local, regional, or national in scope and includes significant fuel supply disruptions and natural or manmade disasters such as hurricanes, floods, earthquakes, terrorist acts, biological outbreaks, releases of dangerous radiological, chemical, or biological materials, war-related activities, or other similar events. Only the President can declare a national energy emergency. PHMSA determined that granting the ESP was consistent with the requirements in the Pipeline Safety Act given PHMSA-2026-0464 – Sable Offshore Corp. PPC Special Permit Analysis and Findings – CA Page 4 of 8 <<>> the national energy emergency declared by the President in E.O. 14156. PHMSA’s decision to grant the ESP also implemented the directives in E.O. 14154 and avoided a potential gap in coverage under the waivers issued by OSFM. PHMSA’s Notice of Limited Enforcement Discretion and Statement of Policy for Issuing Special Permits in Response to National Energy Emergency, which is separate from the permit itself, is an application of PHMSA’s enforcement discretion. The Notice merely allows operators to request expedited consideration of requests for special permits which implicate the national energy emergency, and exercises PHMSA’s discretion to forgo enforcement action while such requests are under PHMSA review. The Notice did not modify PHMSA’s jurisdiction, rights of inspection or access, or investigatory authority, and did not prevent PHMSA from “pursuing an enforcement action if it determines that a significant safety issue warrants doing so” or if the request is ultimately denied. Even absent the issuance of the Notice, PHMSA would retain the discretion not to pursue enforcement actions as appropriate. Comments Regarding Proposed Special Permit Conditions An opposing comment highlighted that past ILIs on this system underestimated corrosion, meaning that ILI data should not continue to be relied upon to assess the pipeline segments. In response to this comment, PHMSA notes that the special permit conditions require ILI assessment of the pipeline segments to a much more exacting level than standard ILI tool runs. To ensure ILIs are an effective tool in assessing the integrity of the pipeline, the special permit conditions require accelerated reassessments, appropriate and complementary tool selection to address all threats, enhanced data analysis practices, more stringent repair criteria, and advanced corrosion growth data analysis techniques. In addition, PHMSA personnel have reviewed records related to actions that Sable has already taken to ensure the pipeline system will be operated safely, including safely completing hydrostatically pressure testing of Lines CA-324, CA-325A, and CA-325B in 2025 to 139-percent or greater of the pipelines’ maximum operating pressure. Other commenters stated that issuing the special permit for a pipeline with a history of incidents is inconsistent with pipeline safety. Commenters referenced previous instances of Sable’s noncompliance. Commenters also stated that the terms of the special permit are misrepresented, and it is inaccurate to describe them as substantially the same as those in the State waivers. Other commenters noted that Sable has a positive safety reputation. Overall, PHMSA has determined that granting the special permit would be consistent with requirements under the Pipeline Safety Act and the policy priorities embodied in E.O. 14156 and E.O. 14154. The proposed non-emergency special permit requests to waive the same regulatory requirement as the ESP, and the conditions imposed are overwhelmingly aligned with the requirements from the prior state waivers. Any future non-compliance by Sable with the special permit conditions may be addressed by PHMSA’s inspection program and enforcement actions as necessary. Some commenters proposed changes to conditions, including limiting the term of the special permit to a fixed number of years, allowing PHMSA to revoke the special permit if Sable does not comply with all conditions, and allowing PHMSA to revoke, suspend, or modify the special permit under certain circumstances. In light of these comments, PHMSA is revising the conditions to grant the special permit for a period of ten years from the date of issuance, and removing the prior limitation in Condition 25(a). PHMSA reserves the right to include such a limitation in the future. Comments Regarding Sable as an Applicant PHMSA-2026-0464 – Sable Offshore Corp. PPC Special Permit Analysis and Findings – CA Page 5 of 8 <<>> Some opposing commenters questioned whether Sable submitted its application to bypass California state law AB 864, which imposes additional requirements on state-regulated pipelines, including a requirement to analyze the need for additional leak detection systems, shutoff systems, and valves, and to retrofit existing pipelines according to that analysis. In response to these comments, PHMSA notes that the Consent Decree required completion of an analysis to determine the need for emergency flow restricting devices, and that, as a result, Sable installed 27 new safety valves along Lines CA-324, CA- 325A and CA-325B, including a safety valve only 1.25 miles downstream of the start of CA-324. The special permit conditions also impose more stringent repair criteria on the pipeline segments. These actions demonstrate that Sable has and will improve the safety of the pipeline segments regardless of the applicability of AB 864. Other negative commenters questioned the trustworthiness of Sable as an operator due to investigations and enforcement proceedings conducted by other governmental entities. They also stated that restart was rushed due to financial deadlines faced by the operator. PHMSA notes that Sable has provided the agency with extensive records regarding testing and anticipated operations, and that PHMSA performed an on-site inspection of its onshore processing facility as well as its control room. As an interstate pipeline, the SYPS will also be subjected to mandated reporting requirements and PHMSA’s inspection program, including enforcement action as appropriate. PHMSA notes that the restart is occurring pursuant to a detailed plan and under the agency’s oversight following years of improvements to the pipeline. Lastly, due to the issuance of the DPA Order, the restart of the pipeline has already safely occurred, and PHMSA’s special permit does not displace or nullify the DPA Order’s requirement that Sable operate the SYPS. Comments Regarding the Prior State Waivers OSFM submitted a comment recommending PHMSA deny the special permit request. OSFM stated that the prior state-issued waivers and the proposed special permit are different in that the state waivers required Sable to repair all anomalies, plus tool tolerances, before the pipeline segments were restarted. OSFM also stated that PHMSA previously reviewed and did not object to the state waivers in February 2025. In response to these comments, PHMSA notes that the tool tolerance requirement described by OSFM represents an allowance of a 10% margin of error for ILI measurements of anomalies detected on CA- 324 and CA-325. Notwithstanding OSFM’s assertion, PHMSA finds the prior state waivers did not clearly require this allowance for tool tolerance for pre-restart ILI runs. The prior state waivers only discussed tool tolerance adjustment for post-restart ILI runs, a requirement that is also in the special permit conditions. Even if the state waivers had included the requirement to remediate anomalies accounting for tool tolerance prior to restart, PHMSA has determined that the extra margin of error created by the tool tolerance allowance was not necessary for the special permit to be consistent with pipeline safety, and PHMSA’s prior no objection would not mean that an otherwise substantially identical waiver is not also consistent with pipeline safety. In addition, due to the DPA Order, the pipeline has already restarted operation, and the special permit conditions will require Sable to remediate the same anomalies, plus tool tolerances, following the performance of initial ILI runs once the SYPS reaches steady-state operation. PHMSA-2026-0464 – Sable Offshore Corp. PPC Special Permit Analysis and Findings – CA Page 6 of 8 <<>> One commenter was neutral, acknowledging special permits can be beneficial to pipeline safety by allowing flexibility in pipeline safety regulations, but urged PHMSA to complete a thoughtful evaluation of the safety benefits and to give careful consideration to the public’s comments. PHMSA appreciates the need to conduct a thoughtful review and has done so. The finalized special permit conditions include minor adjustments for clarity after PHMSA review of Sable records. Condition 3(c) includes a specific MOP for two subsections of Line CA-325B. Condition 13(f) clarifies that Sable must obtain PHMSA approval rather than a specific identification number for applicable hydrostatic testing, and similar language which appeared at Condition 14(g) in the proposed conditions was removed. Analysis: Background Special permits may be granted upon request if unique circumstances make the applicability of a regulation or standard unnecessary or inappropriate for an applicant’s pipeline facility. Special permits will only be granted when pipe conditions, integrity management (IM), and the proposed special permit conditions will provide a level of safety greater than or equal to the code requirements. The operator’s Federal pipeline safety regulation compliance and incident history are also evaluated prior to issuance of a special permit. PHMSA reviewed this special permit request to understand the known type of integrity threats that are in the special permit segments. This integrity information informed the special permit conditions which ensure that the operator has an ongoing program to locate and remediate safety threats. Enforcement History The special permit segments were previously considered intrastate at the time of entry of the Consent Decree and were regulated by OSFM pursuant to its state certification with PHMSA under 49 U.S.C. § 60105(a). As discussed in the Jurisdictional Determination, the special permit segments are now considered part of an interstate hazardous liquid pipeline facility. PHMSA reviewed OSFM’s inspection history of the special permit segments in the time since Sable became the operator of Lines CA-324 and CA-325 in 2024.4 OFSM conducted 16 inspections of Sable’s SYPS in 2024 and 2025, with no concerning or unsatisfactory findings or enforcement actions resulting from the inspections. Therefore, Sable’s inspection and enforcement history does not indicate that granting the special permit would be inconsistent with pipeline safety. Incident History PHMSA typically reviews the previous 5 years of incident history to assess the quantity and severity5 of reported incidents on proposed special permit segments. Lines CA-324 and CA-325 remained 4 In October 2022, Pacific Pipeline Company (PPC), then a subsidiary of ExxonMobil, acquired CA-324 and CA-325 from Plains. In 2024 Sable acquired PPC and became the designated operator of CA-324 and CA-325. 5 “Significant Incidents” are those including any of the following conditions: (1) Fatality or injury requiring in-patient hospitalization; (2) $50,000 or more in total costs, measured in 1984 dollars; (3) Highly volatile liquid releases of 5 barrels or more or other liquid releases of 50 barrels or more; and (4) Liquid releases resulting in an unintentional fire or explosion. Gas distribution incidents caused by a nearby fire or explosion that impacted the pipeline system are excluded from this definition. PHMSA-2026-0464 – Sable Offshore Corp. PPC Special Permit Analysis and Findings – CA Page 7 of 8 <<>> “active” pursuant to PHMSA’s Part 195 regulations but did not transport crude oil from May 19, 2015,6 until March 14, 2026. Including the time since the restart of the SYPS, no incidents have occurred in the last five years. Even taking a longer view of the special permit segment’s incident history to include the May 2015 spill, actions taken by Sable in implementing safety requirements reflected in the Consent Decree and prior state waivers, as well as adherence to the special permit conditions, ensure that issues reflected in the incident history of the pipeline have been and will be addressed. Therefore, the incident history does not indicate that the granting of the special permit would be inconsistent with pipeline safety. Findings: Based on the information submitted by Sable and PHMSA’s review of the documentation, PHMSA finds that granting this special permit with conditions that waives the requirements of 49 CFR § 195.452(h)(4)(iii)(H) for Sable’s Lines CA-324 and CA-325 is in the public interest and is not inconsistent with pipeline safety. This special permit requires Sable to implement the special permit conditions that include applying IM practices to the special permit segments. Completed in Washington D.C. on: June 25, 2026 6 In May 2015 Lines CA-324 and CA-325 were owned and operated by Plains Pipeline, L.P., and known as Lines 901 and 903, respectively. PHMSA-2026-0464 – Sable Offshore Corp. PPC Special Permit Analysis and Findings – CA Page 8 of 8 ## Provenance - Official: Yes - Source: - Source ID: `phmsa-special-permits` - SHA-256: `f1b93bf89f4b1ed0d5895036132f4f4bb935d4982013929293d8e583c8fdcf0d` - Retrieved: 2026-08-20T01:06:17.853Z - Exported: 2026-08-23T09:48:25.733Z - Document slug: `phmsa-special-permit-phmsa-2026-0464` ### Source metadata ```json { "materialSubtype": "pipeline_special_permit", "operator": "Sable Offshore Corp", "system": "Hazardous Liquid", "issuedOn": "2026-06-25", "issuanceStatus": "issued", "renewal": null, "indexUrl": "https://www.phmsa.dot.gov/pipeline/special-permits-state-waivers/special-permits-issued", "docketUrl": "https://www.regulations.gov/docket/PHMSA-2026-0464", "docketDocumentCount": 12, "decisionDocumentCount": 3, "decisions": [ { "id": "PHMSA-2026-0464-0076-09000064b935ea66", "regulationsGovDocumentId": "PHMSA-2026-0464-0076", "title": "Final Conditions-2026-0464-Sable_06252026", "postedDate": "2026-07-01", "documentUrl": "https://www.regulations.gov/document/PHMSA-2026-0464-0076", "pdfUrl": "https://downloads.regulations.gov/PHMSA-2026-0464-0076/attachment_1.pdf", "pdfArtifactPath": "data/sources/phmsa-special-permits/artifacts/phmsa-2026-0464/phmsa-2026-0464-0076.pdf", "pdfArtifactSha256": "eaee4cf796c9c6c351256d816986f979c614a204a719d0950d5a5909ff8a7213", "extractedTextPath": "data/sources/phmsa-special-permits/artifacts/phmsa-2026-0464/phmsa-2026-0464-0076.txt", "extractedTextSha256": "998f45a70ac8c7dd84d0385570aee06f8d48ec409d26bb71c0924c3dcc2630ff", "pageCount": 15, "extractionVersion": 2 }, { "id": "PHMSA-2026-0464-0075-09000064b935ea64", "regulationsGovDocumentId": "PHMSA-2026-0464-0075", "title": "LOD-2026-0464 -Sable_06252026", "postedDate": "2026-07-01", "documentUrl": "https://www.regulations.gov/document/PHMSA-2026-0464-0075", "pdfUrl": "https://downloads.regulations.gov/PHMSA-2026-0464-0075/attachment_1.pdf", "pdfArtifactPath": "data/sources/phmsa-special-permits/artifacts/phmsa-2026-0464/phmsa-2026-0464-0075.pdf", "pdfArtifactSha256": "70abd1fdd1d2bc7b550ea4380436d16d8b00539d07e2036a830707338b32010c", "extractedTextPath": "data/sources/phmsa-special-permits/artifacts/phmsa-2026-0464/phmsa-2026-0464-0075.txt", "extractedTextSha256": "96b83a12b8bfc917847a7edc1bde15e31ccbbc3dd33f88fbdb2beed111068e15", "pageCount": 1, "extractionVersion": 2 }, { "id": "PHMSA-2026-0464-0074-09000064b935ea62", "regulationsGovDocumentId": "PHMSA-2026-0464-0074", "title": "SPAF-2026-0464-Sable_06252026", "postedDate": "2026-07-01", "documentUrl": "https://www.regulations.gov/document/PHMSA-2026-0464-0074", "pdfUrl": "https://downloads.regulations.gov/PHMSA-2026-0464-0074/attachment_1.pdf", "pdfArtifactPath": "data/sources/phmsa-special-permits/artifacts/phmsa-2026-0464/phmsa-2026-0464-0074.pdf", "pdfArtifactSha256": "b945c0d958f42595e98724e04d9514b2c787b492bbacd5d5e5bb658e7cf9c706", "extractedTextPath": "data/sources/phmsa-special-permits/artifacts/phmsa-2026-0464/phmsa-2026-0464-0074.txt", "extractedTextSha256": "020debf2d8a429ae30bc007d1146a979aa6d2d0d4dba68ae21d5d7dd0a3b1caa", "pageCount": 8, "extractionVersion": 2 } ], "citedSections": [ "195.452", "195.3", "192.712", "190.341" ], "caveat": "The issued-permit index establishes issuance, not current validity or applicability to facilities beyond those covered by the permit. Read the official decision and conditions.", "jurisdiction": "US", "operatorName": "Sable Offshore Corp" } ```