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Mineral Resources Management Division - Rigs to Reefs Workshop

Frank E. Holmes

Mr. Holmes is the Coastal Coordinator for the Western States Petroleum Association

~Submitted by Mr. Holmes ~

The Western States Petroleum Association – known as WSPA - is a non-profit trade association dedicated to ensuring that Americans continue to have reliable access to petroleum products through policies that are socially, economically and environmentally responsible.

We recognize that there is a great deal of interest and concern regarding the decommissioning of offshore oil platforms located on the Outer Continental Shelf in California 

WSPA agrees with many aspects of Senate Bill 241 by Senator DeDe Alpert. The bill does not require that any platform remain as a reef. Rather, it gives the state another alternative -- leaving the rigs in place to continue serving as artificial reefs. 

SB 241 balances environmental concerns, technological feasibility, health and safety, and the significant cost involved in decommissioning idle platforms. 

It also provides the means to preserve, protect and enhance viable marine habitats that already exist on the platform jackets and provides funding for new scientific research.

By way of background, approximately 30 offshore oil platforms have been put in place. 

During the production life span of these offshore platforms, thriving ecosystems of marine life have developed on the platform structures, providing valuable habitat for literally millions of creatures. 

We have now reached the time when these platforms will begin the decommissioning process as they phase out of service over the next 15 years. 

There are a number of different ways to remove and dispose of these platforms, and there are extensive national and international regulatory guidelines that control the process. 

It is the substructure, which contains no oil or other residues and rests on the ocean floor, where new options present themselves. 

These options include 1) complete removal of the platform for disposal on land or 2) leaving the substructure in place, allowing it to continue flourishing as an artificial reef. 

Twenty years of experience in the Gulf Coast and Florida has shown that the platforms do create thriving new habitats for marine animals and plants. If the structures are removed, the existing habitat would be destroyed. 

Preservation -- not destruction -- works, and has proven to be successful in other states. I urge you to consider the facts and the real-world experiences of Texas, Louisiana and Florida, all of which have dealt with this same issue. 

Research on artificial reef ecosystems in Louisiana, Texas and Florida has found that reefs harbor 20 to 50 times more fish than nearby soft-bottom environments and that the reefs have benefited commercial fishermen, divers and the sport fishing industry. 

In these states, more than 100 platforms in the gulf of Mexico have been preserved as artificial reefs and now attract thriving marine life that benefits the ecosystem and the economy by attracting divers and fishermen. 

In Texas, 31 platforms have been donated as artificial reefs.

There are four sites that exist in Florida, where the reefs have benefited the coastal communities economically. Commercial and recreational fishing, scuba diving and tourism have prospered from these projects.

In Louisiana, nearly 40 artificial reefs are in existence. These artificial reefs are the destination of more than 75 percent of all saltwater fishing trips originating in Louisiana. 

In California, it is beyond question that platforms have already become the foundation for artificial reefs that are an essential part of the habitat in the surrounding area.  Currently, millions of sea creatures consider these reefs home – it is literally a lifeline for the existing marine animals – and has become a vital part of our offshore coastal ecosystem. 

SB 241 provides a mechanism to protect the marine habitat from the devastating impacts of complete removal.

Beyond coordinating with the Department of Fish and Game, the Coastal Commission, the State Lands Commission and other appropriate federal agencies, SB 241 would require each owner and operator of certain offshore oil platforms to donate a substantial sum – some percentage of the savings --- to the California Endowment for Marine Preservation.

The fund would come from the money saved by leaving the underwater portion of the platforms in place. The endowment’s charter is to fund projects and research that protect and enhance California’s marine resources.

Finally, the oil companies would have no control over how the endowment fund is used and would retain liable for any future oil and gas well related issues that may arise.

SB 241 has the potential to create a win-win alternative for the oil industry and the environment,