Rigs to Reefs Workshop



Offshore California there are 33 oil facilities, 10 in State waters and 23 in Federal waters (Table 1-page 5). Six of the State facilities are islands. All the other facilities are steel platforms. There are four platforms north of Point Conception in the Santa Maria Basin, 17 platforms in the Santa Barbara Channel and 12 platforms in San Pedro Bay. Water depths of the platforms range from 22 to 1198 feet.

While only one facility (Belmont Island in Orange County) is currently slated for removal (decommissioning), it is expected that other facilities will reach the end of their useful life in the next 5-20 years. Under the terms of the current state and federal leases, it is anticipated that the platforms will be completely removed. However, it has been suggested that using the structures for artificial reefs may provide significant benefits and alternative removal strategies should be considered. The reefs could provide habitat for fish and other marine life as well as recreational opportunities for sport fishers and divers.

There have been proposals to use drilling platforms for artificial reefs since the first platform was removed in 1974. However, no reefs have been built because of debates about the productivity of reefs built from structural steel and concern about such issues as hazards to navigation and liability. In the case of Platform Harry, the platform abandoned in 1974, the proposal to build an artificial reef was abandoned because of siting issues and concerns about navigation. Platform Harry was located approximately a mile offshore of Point Conception in 100 feet of water. This site is too remote to be accessible to most fishermen. In addition, the Coast Guard required the removal of structures to a water depth of 85 feet. In the end, the main structure was towed away for reuse and the legs were scrapped.

In 1988, during the decommissioning of Platforms Helen and Herman, approximately 30 miles west of Goleta in the Santa Barbara Channel, a proposal was made to use the platform jacket to build an artificial reef in Santa Monica Bay. However, since there was significant opposition to the proposal, the platforms were scrapped onshore in Long Beach. When the permitting process for decommissioning platforms Heidi, Hope, Hilda and Hazel off of Carpinteria began in 1992, an option to use the material for an artificial reef was discussed with the California Coastal Commission and the California Department of Fish and Wildlife. However, it was concluded that the material was not suitable for reef construction. In 1994, a proposal was made to use portions of the structure to build test reefs in the Sycamore Canyon Ecological Reserve near Port Hueneme. The reefs would have been used to study reef productivity and the value of steel as a construction material. Again, this option was not pursued because the proposal was controversial and would have resulted in delays in the removal of the platforms. For these reasons, Chevron, the leaseholder, decided to scrap the platforms.

Issues to be Resolved

Given the need to complete projects in a timely manner, it has been difficult to pursue options for building artificial reefs in the permitting process. However, it is generally agreed that it is worthwhile to study alternative decommissioning strategies, including building artificial reefs.

The issues that need to be resolved include permitting as well as scientific and technical and institutional issues. The primary permit issue to be resolved involves conditions that have been put on the use of public lands. The Commission's leases for oil and gas development provide discretion to the Commission as to whether "permanent improvements" remain in place or are removed at the end of the lease. Any decision to abandon a platform in place or develop an artificial reef on site would require the Commission's approval. Environmental groups have stated that they agreed to oil development, in part, because of the expectation that all oil and gas related facilities would be removed upon abandonment. They have expressed concern that a "Rigs-to-Reef' Program will conflict with State and federal policies that require site restoration. Trawlers state that they, too, agreed to oil development thinking that fishing grounds would be restored in the long run. They have expressed a concern about the effects of a "Rigs-to-Reef' Program.

Many of the technical issues that need to be resolved relate to the habitat value of the reef. It is well known that oil platforms and artificial reefs have abundant fish populations. However, it is debatable whether the structures attract fish and make them easier to catch or are producing more fish and sustaining a larger fishery. How and where the reefs are built are also important factors affecting habitat value. The open lattice of a standing oil platform is a very different habitat than an intertwined pile of steel on the bottom. Since different fish and invertebrate species live in shallow and in deep water and in clear and turbid water, the value of the habitat will depend on siting. Siting will also affect the use of the reef. Reefs near urban areas will be visited more often than more distant reefs. In order for a reef to be an attraction for recreational divers, it will need to be built in less than 150 feet of water.

The institutional issues that need to be resolved relate primarily to the maintenance and management of the reefs and potential interference with other uses of the ocean, specifically commercial fishing (trawlers primarily) and navigation. In order for a structure to be left in place or removed in pieces to an alternate site, some agency or entity will have to assume management responsibility and liability. Some of the alternative disposal strategies, such as abandonment in place, would require significant programmatic support. At the present time, there is no State "Rigs-to-Reef' program in California. The California Department of Fish and Wildlife (CDFW) has an artificial reef program that is designed to create new habitat and enhance opportunities for sport fishing. It is possible that material from drilling rigs could be used in this program, depending on resolution of use conflicts, long-term management, budget and habitat quality issues. Furthermore, there is no State legislation that would allow CDFW to manage artificial reefs in federal waters. To date federal agencies have been unwilling to accept management responsibility and liability for artificial reefs in federal waters.

Louisiana, Texas and Mississippi have passed specific legislation to establish programs for building artificial reefs from oil platforms. The legislation provides a mechanism to transfer ownership and liability from the oil companies to the state. The legislation provides some protection from liability for the state provided the program conforms to terms and conditions in Federal legislation authorizing artificial reefs. The Louisiana legislation also establishes a trust fund for the program. Historically, when an oil company donates a platform under the Louisiana program, it is requested to donate a portion of the savings realized by its participating in the program to the trust fund. In the Texas program, it is expected that any donation of artificial reef material will be accompanied by at least 50% of the monies saved by the donor.

Current Decommissioning Activities

Given the interest in finding beneficial uses for the oil structures, there are ongoing efforts to investigate and resolve the issues. In September 1997, the Minerals Management Service (MMS) and the California State Lands Commission (CSLC) sponsored a public workshop entitled "Decommissioning and Removal of Oil and Gas Facilities Offshore California: Recent Experience and Future Deepwater Challenges." The workshop and proceedings provided valuable information on technical and environmental issues.

Federal, state and local agencies have formed the Interagency Decommissioning Working Group (IDWG) to collect, synthesize and disseminate information and facilitate discussion. The IDWG has representatives from the Minerals Management Service, National Marine Fisheries Service, U.S. Army Corps of Engineers, U.S. Coast Guard, California State Lands Commission, California Department of Fish and Wildlife, California Coastal Commission, Santa Barbara County and Ventura County. The IDWG has developed an "Action Plan" to identify and define decommissioning issues. This plan does not attempt to resolve policy issues, but does identify information needs that need to be addressed. The IDWG continues to meet on a regular basis and will be involved in technical aspects of decommissioning activities.

Senator Dede Alpert has proposed legislation to establish a Rigs-to-Reef program in California and has asked the President of the University of California and Chancellor of the California State University system for technical assistance on decommissioning issues. The University of California Marine Council, whose members include directors of three campus marine science institutes and representatives from the Scripps Institute of Oceanography and the California Sea Grant College, have appointed a Select Scientific Advisory Committee on Decommissioning Alternatives. The Committee includes Dr. Sally Holbrook as Chair and five other distinguished UC scientists. The first meeting of the Committee is scheduled for November and a report is anticipated this spring.

Chevron has formed a nonprofit public benefit corporation called the California Artificial Reef Enhancement (CARE) Program. The goal of CARE is to facilitate and disseminate credible research on artificial reefs and their role in the marine ecosystem. Members of the Board of Directors include representatives from Chevron, United Anglers Association, Diving Unlimited International and the Professional Association of Diving Instructors. Chevron has provided initial seed money to begin the effort and will provide the results of research to the Select Scientific Advisory Committee on Decommissioning Alternatives, agencies and the general public.

The CSLC is actively involved in all these efforts and is working diligently to resolve the issues. We expect that significant progress will be made in the next year.

Table 1. Oil Production Facilities Offshore California - 1999