Oil Platform Decommissioning

Rigs to reefs

Fish Farm on the Rigs? At the federal level, the oil and gas industry continues to allow decommissioned oil rigs to be converted to other industrial uses, such as open ocean aquaculture facilities (also known as "fish farms"). This use has an array of known environmental impacts that EDC evaluated in a comprehensive report for the Channel Islands National Marine Sanctuary in 2007. This study was catalyzed by a 2003 Chevron-sponsored proposal (now defunct) to convert Platform Grace offshore Ventura County into an aquaculture facility for several species of fish and mollusks.

Until recently, law required that “decommissioned” oil and gas platforms be removed at the end of production, and the surrounding marine environment be cleaned up and restored to a natural condition.  These obligations were known to the oil industry when the platforms were installed.  However, for several years, the industry lobbied to change existing law to allow abandonment of offshore platforms in place after production ceases. Industry's motivation was to avoid the costs for this previously agreed-to remediation. 

Beginning in 1996, after the State of California required Chevron to remove four platforms offshore Summerland in Southern Santa Barbara County, Chevron joined with other oil corporations to lobby the State legislature to amend the law and allow platforms to be abandoned in place. 

To protect the marine environment, EDC led three successful efforts to defeat such legislation and hold the oil and gas industry to the responsibilities it had previously agreed to.

Our opposition was based on the following concerns:

• Pollution
  Oil platforms contain toxic materials and are surrounded by contaminated debris. Leaving them in place defers full clean up and threatens the ocean environment with long-term pollution impacts.
• Marine Resources
  The University of California Marine Council found that research does not indicate that oil and gas platforms enhance marine resources.
• Invasive Species
  Oil and gas platforms can host non-native species that threaten the surrounding environment and native fisheries.
• Safety Hazards
  Leaving debris in the ocean creates a safety hazard for boaters, fishermen, and divers.
• Liability to California
  If the platforms are left in place, the State of California would be left with the liability of accidents or further mitigation efforts. Financial liability for abandoned platforms could thus result in significant, ongoing costs for the state.

If consideration of alternate uses for decommissioned offshore oil and gas facilities were to occur, EDC noted that the following issues should be addressed:

• Science-Based
  The decision must be made based on objective scientific research addressing the potential ecological implications platforms may have on regional fish populations (e.g. UC Marine Council Report)
• Costs and Benefits
  The full breadth and extent of environmental costs and benefits are considered
• Site Specific Analysis
  Platform decommissioning is considered for each individual platform
• Burden of Costs
  Platform owner should not be freed of costs associated with platform removal and remediation.

If an artificial reef program is to be pursued, it should follow the State of California’s established guidelines for artificial reef design and construction, such as mimicking in size and substrate (e.g. rock and concrete) the reefs that naturally produce and maintain greater numbers of fish, and incorporating various rock and crevice sizes in order to help fishes recruit from the water column, find shelter, and reproduce. In many cases, platform structures do not follow these guidelines.

(See References Below)

The Future of Decommissioning

The California Natural Resources Agency (CNRA) and California Department of Fish and Game (CDFG) expressed an interest in developing a State rigs-to-reefs program, in part to generate revenue for environmental programs.  AB 2503, like its predecessors, would require the oil industry to share its savings (from not having to completely remove platforms and clean up the seafloor around the platforms) with the State.  The CNRA contracted with the Ocean Science Trust (OST) to work with a consultant and develop a report regarding decommissioning options, and to analyze the issues that had been raised regarding a rigs-to-reefs program. This report was released in June 2010. With 27 of the 20 oil and gas platforms in Santa Barbara County the discussion about oil and gas platform decommissioning is very important for our area. EDC and our clients have raised serious concerns (read EDC's comments) about the impacts associated with leaving abandoned oil platforms in the ocean including concerns about the environmental, safety and legal implications of a rigs-to-reefs program. We also raised concerns regarding the in complete nature of the report, and the fact that many questions remain unanswered.

Despite the fact that the State Legislature had rejected rigs-to-reefs proposals three times, a new bill was introduced in 2010.  EDC and other groups opposed the bill (AB 2503: California Marine Life Legacy Act), due to the need for more scientific analysis and further evaluation of the safety, management and economic ramifications of a state-sponsored rigs-to-reefs program. See EDC's letter in opposition to A.B. 2503.  AB 2503 was signed into law on September 13, 2010.

Are rigs the ideal location for citing artificial reefs? Deliberate site selection for artificial reefs is also identified by the State as an important factor in their functionality, and thus should be prioritized over opportunistic reef siting embodied by defining platforms as reefs. EDC encourages the State to follow these steps before considering a rigs-to-reefs program; California should focus our resources and efforts on fisheries restoration driven by the needs of the fish and their ecosystems, not the oil industry.

References and Resources •Linda Krop's PowerPoint presentation from the 2010 California and the World Ocean Conference on unanswered questions about environmental, safety, and liability issues surrounding decommissioning offshore oil platforms. •Environmental Review of Chevron platform debris mounds, California State Lands Commission •UC Marine Council Report •Study on non-native species by the Marine Science Institute at UC Santa Barbara •EDC’s comprehensive report for the Channel Islands National Marine Sanctuary •California Department of Fish and Game Guidelines for artificial reef design and construction Ocean Science Trust, Decommissioning Study Webpage •Technical Report, Minerals Management Service •EDC’s SB1 Fact Sheet •EDC’s Comment Letter on Alternatives for Platform Decommissioning (3.15.10), prior to Release of the Ocean Science Trust Report  •EDC's Comment Letter on Alternatives for Platform Decommissioning (6.24.10), after Release of the Ocean Science Trust Report