Sable Offshore Corp. (SOC) - A Hearing on the Motion to Stay the Cease and Desist Order is Currently Scheduled to be Held on July 9, 2025 Before Judge Anderle.

***Please note that the information below was delivered to clients on July 8, 2025.***

On July 9, 2025, a Hearing on the Motion to Stay the Cease-and-Desist Order is currently scheduled to commence at 10:00 AM PT in the Case of: "Sable Offshore Corp et al vs California Coastal Commission" (Case #25CV00974).  Please note that this is in the Case in which Sable challenges the Cease/Desist Order issued by the California Coastal Commission preventing maintenance activities on the Las Flores Pipeline.  This is independent of the Case before Judge Geck in which the Preliminary Injunction Hearing is currently scheduled to be held on July 18, 2025.

Sable & Pacific Pipeline filed this Case in the Superior Court of California - County of Santa Barbara on February 18, 2025 - with an Amended Complaint being filed on April 16, 2025.  In its Complaint, Sable challenges the Violations and the Cease/Desist Order issued by the California Coastal Commission.  Sable argues that the Coastal Commission's Orders are preventing maintenance activities on the Las Flores Pipeline - activities, which Sable argues fall within the scope of work authorized by a prior consent decree and falls within the existing development and production plan.  The California Coastal Commission subsequently filed a Cross-Complaint for Declaratory Judgment and Injunctive relief in which they argue that Sable (in March 2025) stated that it had undertaken steps to repair certain anomalies along its pipelines.  The Coastal Commission argued in its subsequently filed Motion for a Preliminary Injunction that this work is being performed under the permits issued by the County, and that Sable never applied for a Coastal Development Permit through the Coastal Commission - which would have required multiple other steps including the submission of plans to Coastal Commission staff.  A public Hearing was held before the Commission on April 10, 2025, and a Cease-and-Desist Order was subsequently issued.  A Hearing on a Preliminary Injunction seeking to prevent any further breaches of the CDO was then held on May 28, 2025, and the Court issued an Order on the same day Granting the Motion.  Shares of Sable Offshore Corp (SOC) moved down around 18% following this Order.  The Trial in this Case is currently scheduled to commence on October 16, 2025.  

In its Motion, Sable seeks a Stay of the Cease-and-Desist Order pending final resolution of this Case.  A preview of Sable's Arguments is below:

Sable provides a brief background in which they state that in 1986 the county issued Coastal Development Permits ("CDPs") that contemplated repair and maintenance activities. Sable argues that these CDPs were never appealed by any party, including the Coastal Commission. They argue that critical repairs could be stalled in protracted bureaucratic processes and are therefore critical to environmental safety as part of the original County permits. Sable writes that the County then confirmed on March 21, 2025, that anomaly repair work that was conducted in 2024 was authorized and that no new permits would be required. On April 10, 2025, the Commission issued a Cease-and-Desist Order which require an updated Coastal Development Permit ("CDP") within 30 days of the of the effective date - Sable argues that only the County has authority to issue these permits and has previously confirmed that the repair work was authorized. The Commission also issued a "Restoration Order" on April 10, 2025, which requires the submission of a full "restoration plan" within 60 days, and assessed a penalty of $18,022,500 against Plaintiff, which accrues an additional penalty for each day Plaintiff is in Violation. 

1. Staying the Commission's CDO is not against the public interest.
   1. Sable argues that all that is required for a Stay of the CDO is to show that doing so is not against the public interest. Sable argues that the Commission can issue a CDO only if: 1) The activity requires a permit, and one has not been secured; or 2) the activity is inconsistent with any permit previously issued by the Commission. Sable insists that the Commission has delegated its authority (back in 1986) to the County and therefore there is no "Commission issued permit" to violate. Such that the public interest does not weigh in favor of upholding an "unlawfully issued CDO." There are exceptions to the 2 requirements above in the Commission's authority to issue a CDO. Sable writes the following regarding those exceptions: 

"The only other circumstance where the Commission could issue a CDO to enforce the requirements of the County’s LCP is if: (1) County requests the Commission to assist with, or assume primary responsibility for, issuing a CDO; (2) the Commission requests, and the County declines to act or does not act in a timely manner, regarding an alleged violation which could cause significant damage to coastal resources; or (3) the County is a party to the violation. (See Pub. Res. Code, § 30810(a)(1)- (3).)  None of these exceptions are present here. Exception 1 does not apply because the County did not ask for the Commission’s assistance. Exception 2 fails as the County did take action, consistent with its delegated authority, by confirming expressly in correspondence to Plaintiffs and the Commission on February 12, 2025, and again on March 21, 2025, that the Plaintiffs’ anomaly repair activities do not require any new amended CDPs “from the Commission” and that “[n]o permits will be required.” (Rusch Decl., Exs. H and I.) Exception 3 does not apply as the County is not a party to any alleged violation." 

2. It is not against the public interest to Stay a CDO that unlawfully usurps the County's delegated exclusive permitting authority.
   1. Sable argues that the Commission has no inherent power since the commission delegated permitting authority to the County - which has "acted pursuant to that lawfully delegated authority." Sable argues that it is therefore not against the public interest to Stay the CDO since on its own, the Commission has "literally no power to act" and may not usurp the County's permitting and enforcement authority and require additional CDPs. Sable also argues that it is not against the public interest to Stay the CDO, because the Cease-and-Desist Order purports to restrict maintenance activities that have already been completed. 
3. A Stay of the CDO would Benefit the Environment and the Economy
   1. Sable argues that the CDO harms public interest, because it may prohibit Sable from completing its ongoing obligation to perform repairs. They state that their obligations include anomaly repair work immediately upon discovery, and that a failure to perform such repairs could greatly impact the environment. Similarly, Sable argues that the addition to Sable's oil production resulting from these required repairs would benefit consumers as it would stabilize oil prices and reduce reliance on foreign crude oil.  

In response, the Commission argues that Sable's Motion is improper, because it attempts to evade the requirement to show that there has been a material change of facts - which the Commission argues needs to be shown in order to dissolve a Preliminary Injunction. The Commission also argues that Sable's arguments are simply recycled from its argument against the Preliminary Injunction - the Commission questions why Sable seeks to have the Preliminary Injunction dissolved if it has already "completed the work that is enjoined." The Commission states that the only new argument is Sable's argument regarding higher gas prices and further harm to the environment.