Analysis Report on the Resumption of Equinor's New York Offshore Wind Power Project

I have now collected sufficient information, let me conduct a comprehensive analysis for you.

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Empire Wind 1 is a large-scale offshore wind power project developed by Equinor in New York State, U.S., located in federal waters approximately 14 miles southeast of Long Island [1][4]. The project has the following core characteristics:

Project Indicators	Specific Data
Installed Capacity	810 MW
Number of Wind Turbines	54 Vestas 15MW wind turbines
Total Investment	Approximately $5.5 billion
Funds Already Invested	Over $4 billion
Project Progress	Approximately 60% completed
Power Generation Capacity	Can provide power to approximately 500,000 households
Expected Commissioning	First power generation by the end of 2026, full operation in 2027
Job Creation	Creates nearly 4,000 jobs during the construction phase

The project also includes the expansion and upgrade of the South Brooklyn Marine Terminal [1][3].

On December 22, 2025, the U.S. Department of the Interior issued a Stop-Work Order to Equinor on the grounds of “national security risks”, requiring the project to suspend all activities on the continental shelf for 90 days [2][5]. This order was part of the Trump administration’s comprehensive actions targeting the U.S. offshore wind power industry [6].

• December 22, 2025
  : The Department of the Interior issued the stop-work order
• January 9, 2026
  : The New York State Attorney General filed a lawsuit challenging the legality of the stop-work order [2]
• January 14, 2026
  : U.S. District Court for the District of Columbia Judge Carl Nichols delayed the ruling
• January 15, 2026
  : The court granted a preliminary injunction allowing Equinor to resume construction [7]

Equinor has clearly stated that although its overall renewable energy investment target has been adjusted, it has not abandoned its strategic core projects. In 2025, the company reduced its renewable energy investment by 50% to $5 billion, but

[3]. Empire Wind 1 is precisely the flagship project after this strategic adjustment.

Equinor has become the first offshore wind power developer to directly supply power to New York City through the Empire Wind project [4]. New York State requires an additional 5-7 GW of offshore wind power installed capacity by 2040, and the project’s resumption allows Equinor to lock in this strategic market position [2].

The court ruling indicates that the administrative stop-work order lacks legal basis (ruled as “arbitrary and capricious”, violating the Administrative Procedure Act) [5][6]. This legal victory provides an important reference for policy risks for Equinor and other offshore wind power developers.

Equinor has invested over $4 billion [1][3], and termination of the project would result in huge sunk costs. Resuming the project preserves the upfront investment and avoids asset impairment losses.

According to court documents, Equinor faces strict time constraints [1][7]:

“If construction activities do not resume by January 16, 2026, and critical lifting operations do not start by January 26, the specialized construction vessel will have to leave, and the project will lose access to this vessel for at least one year. Another vessel used for commissioning the offshore substation has a lease term ending in late June 2026, and will not be available for use for five years after that.”

The timely approval of the preliminary injunction avoided the risk of the project “becoming uneconomical quickly” [2], ensuring that the project can complete critical construction milestones within the availability window of key equipment.

• The project has a 25-year power purchase agreement with NYSERDA, providing a stable long-term revenue source [2]
• New York State is actively promoting renewable energy transition, and the project’s power absorption is guaranteed by policies
• New York City’s electricity demand is growing rapidly, and the project can provide important support for grid reliability

• Litigation will continue, and policy risks have not been fully eliminated [7]
• If a new stop-work order is issued subsequently, it may lead to further delays and cost overruns
• Asset impairment risk: As of September 30, 2025, the total book value of the Empire Wind project (including terminal assets) was approximately $3.1 billion, and approximately $2.8 billion in project financing loans had been drawn down as of November 30 [1]

Equinor’s 2025 financial performance was robust:

Financial Indicators	Q2 2025	Q3 2025	Year-over-Year Change
Adjusted Operating Revenue	$6.53 billion	$6.21 billion	Down 5%
After-Tax Profit	$1.74 billion	$1.51 billion	Down 13%
Earnings Per Share (EPS)	$0.64	$0.37	Down 42%
Cash Flow from Operations	$2.477 billion	$6.346 billion	Substantial Growth

The U.S. business performed particularly prominently: U.S. oil and gas production in the second quarter of 2025 increased by 28% year-over-year, mainly benefiting from the U.S. onshore assets acquired in 2024 and higher natural gas prices [8][9]. This trend indicates that the contribution of the U.S. market to Equinor’s overall profitability is increasing.

Equinor clearly identifies offshore wind power as a core pillar of its transition from traditional oil and gas to clean energy. Despite facing short-term policy uncertainty, the company has adopted an investment strategy of

[3]. The Empire Wind 1 project:

• Secured over $3 billion in project financing [3]
• Completed over 60% of engineering construction
• Signed a long-term power purchase agreement

These characteristics make it meet Equinor’s definition of a “high-value, de-risked asset”, and the project’s resumption further confirms the correctness of this investment decision.

Equinor’s victory is not an isolated case. On December 8, 2025, U.S. District Court for the District of Massachusetts Judge Patti B. Saris ruled that the president’s January 20 executive memorandum suspending wind energy development was illegal [5]. On January 12, 2026, Judge Royce Lamberth granted a preliminary injunction for Ørsted’s Revolution Wind project [5][6].

This series of rulings indicates that federal courts generally believe that administrative agencies lack legal basis to intervene in legally approved energy projects beyond their authority.

New York State Attorney General Letitia James emphasized that the Empire Wind 1 and Sunrise Wind projects have undergone over a decade of comprehensive federal, state, and local reviews, including environmental impact analysis, public comment periods, and coordination with multiple federal agencies including the Department of Defense [2]. New York State described the project suspension as

[2].

The removal of legal barriers for Equinor’s New York offshore wind power project Empire Wind 1 has a

impact on the expansion of the company’s U.S. clean energy business and long-term profitability:

1. Protected the upfront investment of over $4 billion, avoiding asset impairment
2. Confirmed the project’s policy status as part of New York State’s energy strategy
3. Verified the illegality of the administrative stop-work order through legal means, reducing policy uncertainty
4. Maintained the possibility of completing the project within the availability window of key equipment

1. Litigation will continue, and policy risks have not been fully eliminated
2. Potential political risks still need to be continuously addressed after the project is completed
3. The global offshore wind power industry faces cost pressures and supply chain challenges

For investors evaluating Equinor’s U.S. clean energy business, the resumption of the Empire Wind 1 project should be viewed as:

• Elimination of short-term uncertainty
  : The critical construction window is legally guaranteed
• Confirmation of medium-term cash flow
  : The 25-year power purchase agreement provides long-term revenue visibility
• Verification of long-term strategy
  : Demonstrates Equinor’s first-mover advantage and technical capabilities in the U.S. offshore wind power market

If the project can be fully operational in 2027 as planned, it will bring a stable clean energy revenue stream to Equinor, further diversifying the company’s revenue structure and reducing its dependence on oil and gas prices.

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[1] Equinor Official Announcement - “Empire receives stop work order from US Department of the Interior” (December 22, 2025) https://www.equinor.com/news/20251222-us-wind-lease-paused
[2] New York State Attorney General’s Office - “State of New York v. Doug Burgum et al Empire Complaint” (January 9, 2026) https://ag.ny.gov/sites/default/files/court-filings/state-of-new-york-new-york-state-energy-research-and-development-authority-v-douglas-j-burgum-et-al-empire-complaint-2026.pdf
[3] Enkiai - “Equinor Offshore Wind Initiatives for 2025: Key Projects, Strategies and Partnerships” (2025) https://enkiai.com/equinor-offshore-wind-initiatives-for-2025-key-projects-strategies-and-partnerships
[4] Offshore Wind Biz - “New York Attorney General Files Lawsuits Against Trump Admin’s Stop-Work Orders” (January 12, 2026) https://www.offshorewind.biz/2026/01/12/new-york-attorney-general-files-lawsuits-against-trump-administrations-stop-work-orders-for-empire-wind-sunrise-wind/
[5] Spencer Fane - “Revolution Wind May Proceed With Its Offshore Wind Energy Project” (January 14, 2026) https://www.spencerfane.com/insight/revolution-wind-may-proceed-with-its-offshore-wind-energy-project-the-trump-administration-loses-another-court-battle/
[6] Engineering News-Record - “Revolution Wind, Empire Wind Sue to Reverse Trump Halt of Five Offshore Wind Projects” (January 2026) https://www.enr.com/articles/62295-new-update-revolution-wind-empire-wind-sue-to-reverse-trump-halt-of-five-offshore-wind-projects
[7] Equinor Official Announcement - “Empire Wind granted preliminary injunction allowing construction to resume” (January 15, 2026) https://www.equinor.com/news/20260115-empire-wind-granted-preliminary-injunction
[8] Equinor Official Announcement - “Equinor second quarter 2025 results” (2025) https://www.equinor.com/news/equinor-second-quarter-2025-results
[9] Equinor Official Announcement - “Equinor third quarter 2025 results” (2025) https://www.equinor.com/news/equinor-third-quarter-2025-results