Rigs-to-Reefs

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Rigs-to-Reefs (RTR) is a nationwide program developed by the former Minerals Management Service (MMS) [1], now Bureau of Safety and Environmental Enforcement (BSEE), of the U.S. Department of the Interior to turn decommissioned offshore oil and petroleum rigs into artificial reefs.

Overview

The United States began mining oil offshore in the early 20th Century;[2] yet the concern over abandoned oil rigs surfaced only in the 1980s. "Today over 4,500 offshore oil and gas platforms have been installed supplying 25% of the United States' production of natural gas and 10% of its oil."[3] These platforms continue to function as long as the reservoirs underneath them provide oil at a profitable rate. At the end of their productive lives they must be decommissioned and removed within one year.[4]

An alternative to removal is to turn the rig into a reef through the Rigs-to-Reef (RTR) program. All coastal states have such artificial reef programs in the interest of increasing ocean fisheries but not all participate in RTR.[5][6] The rig's steel structures are stable and durable.[7] They create shelter for marine life in open waters where there was none.

Process

Once a rig stops producing economic quantities of oil, the site is usually abandoned.[8] The Minerals Management Service (MMS) requires the operator to remove the rig within a year of abandonment (stopped production[8]) and lease end.[4] MMS supports and encourages RTR as an alternative to total removal.[4] RTR recognizes that during a rig's productive years, significant marine life comes to live on and around its structure. RTR preserves much of that marine life and encourages further growth. The operator benefits by avoiding the substantial cost of removal. Cumulative costs of removal had reached an estimated $1 billion by the year 2000.[7] The shape and complexity of the structure may lead to significant species diversity.

Decommissioning a platform

Officially, decommissioning an oil rig is the act of removal according to regulatory requirements and includes flushing, plugging and cementing wells to make them safe.[8] Decommissioning is complicated by factors such as cost, safety, operational duration, environmental issues, risk, experience, and historical relationship between operator and state.[8]

As part of decommissioning, the operator must deal with the shell mound that collects on the bottom surrounding the rig. The mound consists of shells that have fallen from the rig, material that has fallen and/or leaked from the platform, mixed with well seepage. Mounds can contain significant levels of toxic metals including, arsenic, cadmium, chromium, copper, nickel, PCBs, lead, zinc, and poly-nuclear hydrocarbons. Removing the rig structure does not eliminate the need to address the mound.[9]

The method of decommissioning depends on water depth and structure type[10] and is a three step process that includes planning, permitting, and implementation.[11] A party other than the operator usually administers the process.

In Louisiana, costs as well as the risk involved are the primary factors in determining how to decommission rigs. If the savings are large enough, the operator typically chooses reefing and donates 1/2 the savings to maintain the reef.[8] Decommissioning a shallow water rig typically costs $10–15 million[12] so the amounts can be substantial.[13] The Louisiana Artificial Reef program from its inception through 1998 received roughly $9.7 million in donations and has not taken taxpayer money.[14]

Methods of reefing

Severing the rig from the bottom using explosives is the easiest approach, but has the potential to harm marine life. This potential is greatly reduced if the explosives are all placed deep below the seafloor. Current requirements place the explosives a minimum of 5 metres (16 ft) below the seafloor which eliminates the threat to all but the closest sea turtles. National Oceanographic and Atmospheric Administration (NOAA) National Marine Fisheries Service (NMFS) marine observers and helicopter surveys hours preceding the event keep most sea turtles away from the area. Alternatively, commercial divers can use mechanical and abrasive cutters, which preserves marine life, but places the divers at considerable risk.[8]

Reefing involves one of three methods.:

  • Tow and Place: Sever the structure from the sea floor and tow it to a state-approved location.
  • Partial Removal: Remove the top portion of the submerged platform and either place it on the sea floor or tow it to another site.[7] Partial removal can result in a loss of the shell mound community and fish that live in the top section but the rest (the majority) of the habitat remains intact.[11]
  • Toppling: Toppling involves uses explosives to sever the base of the structure below the mud line. Then it simply falls over. Toppling eliminates shallow and mid-ocean habitats. However, these portions of the rig are quickly occupied by other creatures.[11]

History

In the early 1900s coastal oil exploration and drilling began around the United States. Initially, no laws governed this activity. In 1979, Exxon relocated their experimental subsea production system from offshore Louisiana to a permitted artificial reef site off Apalachicola, Florida.[15] The first platform jacket was donated by Tenneco and towed from Louisiana to Pensacola, Florida.[15]

By 2000, companies had donated 141 platforms to the effort.[15]

Legislation

Congress passed the Submerged Lands Act in 1953 to clarify responsibilities between state and federal government.[16][17] This was immediately followed by the Outer Continental Shelf Lands Act (OCSLA)[18] used to control leasing of exploration rights in the Outer Continental Shelf (OCS).[16] The OCSLA did not contain any real environmental provisions associated with drilling and in 1969 an explosion at a drilling location off of California's coast triggered the National Environmental Policy Act (NEPA).[19] NEPA concluded that every major federal action (i.e.: oil exploration on the OCS) required an Environmental Impact Statement (EIS).[16] In 1982, The U.S. Department of the Interior created the Mineral Management Service (MMS) to monitor development on the Outer Continental Shelf.[16] The MMS leases submerged federal lands and assesses the environmental effects of exploration and drilling (by issuing an EIS).[16] In 1984 Congress passed the National Fishing Enhancement Act (NFEA) which provided the basis for artificial reef programs.[16] The NFEA spawned the National Artificial Reef Plan of 1985. This plan cleared the way for government-endorsed artificial reef projects and subsequently the Minerals Management Services' Rigs-to-Reef program.[1]

Trends

Rigs-to-Reefs was first explored in 1979 when the first oil rig was transported from Louisiana to a Florida site.[20] This rig was the first of 5 Rigs-to-Reefs towed to Florida's coast. Louisiana was the first state to develop a program that allowed transfer of liability and ownership from the operator to the state.[8] Texas later followed this example. Rigs-to-Reef is now the core of both Louisiana and Texas' artificial reef programs.[3] From 1987-1995, of the over 941 platforms removed from Louisiana and Texas waters, 90 became artificial reefs.[21] By November 2000, 151 platforms had been recycled as artificial reefs in the Gulf of Mexico from states such as Texas, Louisiana, Mississippi, Alabama, and Florida.[22] Federal law now requires rigs to be demolished for safety reasons, although discussion continues about their potential.[23]

Debates

Opposition, and also support, for Rigs-to-Reefs came from environmentalists, fisherman, oil companies, and others. California and the North Sea are each debating RTR. In California, legislation was proposed during the 2010 session to clear legal hurdles for RTR; the Coastal Commission held hearings, but then the legislation was tabled.[24] Even with the RTR successes in the Gulf of Mexico and Philippines,[25] differences in terrain, government entities, and concerned citizens generated conflict.

Fisheries

A 2000 MMS report lists research that shows fish densities 20 to 50 times higher around oil and gas platforms than in nearby open water.[4] Divers assess fish populations surrounding platforms.[26] The report encourages recreational fisherman, divers and others who benefit from the increased density. Opponents claim that the greater density comes from an influx of nearby fish rather than increased total population.[7] Research observing rockfish populations on oil rigs supports both theories.[2]

Liability

Commercial fisherman who trawl sometimes oppose RTR because their nets may snag a rig, creating a hazardous situation.[27] Several fisherman have reported tangling their nets on submerged rigs.[9] Navigational mishaps and diving accidents may also occur around an artificial reef. Gulf of Mexico Rigs-to-Reefs participants have not yet reported any liability problems.[27]

The MMS does not release an operator from liability unless another entity accepts ongoing liability for the rig.[4] If the reef is in state waters, the state typically accepts liability. In federal waters, liability typically goes to a private entity or to another MMS-approved agency.[11] Critics claim that the primary reason that operators support RTR is their desire to offload decommissioning costs and liability.[12]

Liability is divisible, however. In 2001, the California legislature passed, although the governor then vetoed, a bill that would allow operators to transfer liability to another entity, while retaining liability for any pollution from the underlying well.[12]

Ethics

As with cap-and-trade and ecotourism, RTR attempts to enlist the private sector in helping the environment. In the minds of many environmentalists, such efforts are fundamentally suspect. Environmental groups have long opposed oil companies and frame their critique around distrusting these parties.[16] "No other industry is allowed to leave a toxic mess for the state to manage and maintain at taxpayer expense" said Linda Krop, Chief council for the Santa Barbara based Environmental Defense Center.[27]

See also

References

  1. ↑ 1.0 1.1 "Rigs-to-Reefs Information: What is Rigs-to-Reefs and how does it relate to the mission of the Bureau of Safety and Environmental Enforcement?". http://www.gomr.mms.gov/homepg/regulate/environ/rigs-to-reefs/information.html. Retrieved 2009-03-06.
  2. ↑ 2.0 2.1 Script error
  3. ↑ 3.0 3.1 [1] Louisiana Department of Wildlife and Fisheries
  4. ↑ 4.0 4.1 4.2 4.3 4.4 Script error
  5. ↑ U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region. Rigs-to-Reefs Policy, Progress, and Perspective (Report). OCS Report MMS 2000-073. http://www.gomr.mms.gov/homepg/whatsnew/techann/000073.html. Retrieved 2009-03-06.
  6. ↑ [2] State of California State and Lands Commission
  7. ↑ 7.0 7.1 7.2 7.3 Script error
  8. ↑ 8.0 8.1 8.2 8.3 8.4 8.5 8.6 Script error
  9. ↑ 9.0 9.1 "Oil watchdog". http://www.oilwatchdog.org/articles/?storyId=24233.
  10. ↑ Sector Notebook Project; Office of Enforcement and Compliance Assurance, October 2000
  11. ↑ 11.0 11.1 11.2 11.3 Script error
  12. ↑ 12.0 12.1 12.2 "Rigs-to-Reefs issues". http://www.dailynexus.com/article.php?a=1394.
  13. ↑ [3] CA.gov Rigs-to-Reefs Workshop
  14. ↑ [4] The Greater Baton Rouge Business Report 1998
  15. ↑ 15.0 15.1 15.2 Script error
  16. ↑ 16.0 16.1 16.2 16.3 16.4 16.5 16.6 Script error
  17. ↑ [5][dead link]
  18. ↑ http://www.mms.gov/aboutmms/OCSLA/ocslahistory.htm
  19. ↑ "Basic Information | Compliance and Enforcement | U.S. EPA". Epa.gov. http://www.epa.gov/oecaerth/basics/nepa.html. Retrieved 2012-06-19.
  20. ↑ [6] Mineral Management Service: History of Rigs to Reefs offshore Florida
  21. ↑ [7] Summary of The Political Economy of the Rigs-to-Reef Option for Decommissioning Oil and Gas Structures
  22. ↑ [8] API Energy: Rigs to Reef Programs Create Valuable Fish Habitat
  23. ↑ [9]
  24. ↑ Baine, Mark. “Short Communication: The North Sea Rigs-to-Reef debate,” Journal of Marine Science 59 (2002): S277-S280.
  25. ↑ Ranjith, M.W.; De Silva, N., “The Coastal Resources Management Program in Brunei Darussalam. Ocean and Coastal Management 38 (1998) 147-160
  26. ↑ Script error
  27. ↑ 27.0 27.1 27.2 [10] CDNN-"California Rigs to Reefs Battle Creates Strange Alliances"


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