Rigs-to-Reefs
Encyclopedia
Rigs-to-Reefs is a nationwide program developed by the Minerals Management Service
Minerals Management Service
The Bureau of Ocean Energy Management, Regulation and Enforcement , formerly known as the Minerals Management Service , was an agency of the United States Department of the Interior that managed the nation's natural gas, oil and other mineral resources on the outer continental shelf...

 (MMS) of the U.S. Department of the Interior to turn decommissioned offshore oil and petroleum rigs into artificial reef
Artificial reef
An artificial reef is a human-made underwater structure, typically built to promote marine life in areas with a generally featureless bottom, control erosion, block ship passage, or improve surfing....

s.

Overview

The United States began mining oil offshore in the early 20th Century; 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
Natural gas
Natural gas is a naturally occurring gas mixture consisting primarily of methane, typically with 0–20% higher hydrocarbons . It is found associated with other hydrocarbon fuel, in coal beds, as methane clathrates, and is an important fuel source and a major feedstock for fertilizers.Most natural...

 and 10% of its oil." 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.

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
Artificial reef
An artificial reef is a human-made underwater structure, typically built to promote marine life in areas with a generally featureless bottom, control erosion, block ship passage, or improve surfing....

 programs in the interest of increasing ocean fisheries
Fishery
Generally, a fishery is an entity engaged in raising or harvesting fish which is determined by some authority to be a fishery. According to the FAO, a fishery is typically defined in terms of the "people involved, species or type of fish, area of water or seabed, method of fishing, class of boats,...

 but not all participate in RTR. The rig's steel structures are stable and durable. They create shelter for marine life in open waters where there was none.

Rigs-to-Reefs Process

Once a rig stops producing economic quantities of oil, the site is usually abandoned. The Minerals Management Service
Minerals Management Service
The Bureau of Ocean Energy Management, Regulation and Enforcement , formerly known as the Minerals Management Service , was an agency of the United States Department of the Interior that managed the nation's natural gas, oil and other mineral resources on the outer continental shelf...

 (MMS) requires the operator to remove the rig within a year of abandonment (stopped production) and lease end. MMS supports and encourages RTR as an alternative to total removal. 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. 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. Decommissioning is complicated by factors such as cost, safety, operational duration, environmental issues, risk, experience, and historical relationship between operator and state.

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
Arsenic
Arsenic is a chemical element with the symbol As, atomic number 33 and relative atomic mass 74.92. Arsenic occurs in many minerals, usually in conjunction with sulfur and metals, and also as a pure elemental crystal. It was first documented by Albertus Magnus in 1250.Arsenic is a metalloid...

, cadmium
Cadmium
Cadmium is a chemical element with the symbol Cd and atomic number 48. This soft, bluish-white metal is chemically similar to the two other stable metals in group 12, zinc and mercury. Similar to zinc, it prefers oxidation state +2 in most of its compounds and similar to mercury it shows a low...

, chromium
Chromium
Chromium is a chemical element which has the symbol Cr and atomic number 24. It is the first element in Group 6. It is a steely-gray, lustrous, hard metal that takes a high polish and has a high melting point. It is also odorless, tasteless, and malleable...

, copper
Copper
Copper is a chemical element with the symbol Cu and atomic number 29. It is a ductile metal with very high thermal and electrical conductivity. Pure copper is soft and malleable; an exposed surface has a reddish-orange tarnish...

, nickel
Nickel
Nickel is a chemical element with the chemical symbol Ni and atomic number 28. It is a silvery-white lustrous metal with a slight golden tinge. Nickel belongs to the transition metals and is hard and ductile...

, PCB
Polychlorinated biphenyl
Polychlorinated biphenyls are a class of organic compounds with 2 to 10 chlorine atoms attached to biphenyl, which is a molecule composed of two benzene rings. The chemical formula for PCBs is C12H10-xClx...

s, lead
Lead
Lead is a main-group element in the carbon group with the symbol Pb and atomic number 82. Lead is a soft, malleable poor metal. It is also counted as one of the heavy metals. Metallic lead has a bluish-white color after being freshly cut, but it soon tarnishes to a dull grayish color when exposed...

, zinc
Zinc
Zinc , or spelter , is a metallic chemical element; it has the symbol Zn and atomic number 30. It is the first element in group 12 of the periodic table. Zinc is, in some respects, chemically similar to magnesium, because its ion is of similar size and its only common oxidation state is +2...

, and poly-nuclear hydrocarbon
Hydrocarbon
In organic chemistry, a hydrocarbon is an organic compound consisting entirely of hydrogen and carbon. Hydrocarbons from which one hydrogen atom has been removed are functional groups, called hydrocarbyls....

s. Removing the rig structure does not eliminate the need to address the mound.

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

In Louisiana
Louisiana
Louisiana is a state located in the southern region of the United States of America. Its capital is Baton Rouge and largest city is New Orleans. Louisiana is the only state in the U.S. with political subdivisions termed parishes, which are local governments equivalent to counties...

, 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. Decommissioning a shallow water rig typically costs $10–15 million so the amounts can be substantial. The Louisiana Artificial Reef program from its inception through 1998 received roughly $9.7 million in donations and has not taken taxpayer money.

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 (16.4 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
National Marine Fisheries Service
The National Marine Fisheries Service is a United States federal agency. A division of the National Oceanic and Atmospheric Administration and the Department of Commerce, NMFS is responsible for the stewardship and management of the nation's living marine resources and their habitat within the...

 (NMFS) marine observers and helicopter
Helicopter
A helicopter is a type of rotorcraft in which lift and thrust are supplied by one or more engine-driven rotors. This allows the helicopter to take off and land vertically, to hover, and to fly forwards, backwards, and laterally...

 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.

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. 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.

  • 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.

History

In the early 1900s coastal oil exploration and drilling began around the United States. Initially, no laws governed this activity. In 1979, Exxon
Exxon
Exxon is a chain of gas stations as well as a brand of motor fuel and related products by ExxonMobil. From 1972 to 1999, Exxon was the corporate name of the company previously known as Standard Oil Company of New Jersey or Jersey Standard....

 relocated their experimental subsea production system from offshore Louisiana to a permitted artificial reef site off Apalachicola, Florida
Apalachicola, Florida
Apalachicola is a city in Franklin County, Florida, on US 98 about southwest of Tallahassee. The population was 2,334 at the 2000 census. The 2005 census estimated the city's population at 2,340...

. The first platform jacket was donated by Tenneco
Tenneco
Tenneco is a $6.2 billion Fortune 500 company that has been publicly traded on the NYSE since November 5, 1999 under the symbol TEN...

 and towed from Louisiana to Pensacola, Florida
Pensacola, Florida
Pensacola is the westernmost city in the Florida Panhandle and the county seat of Escambia County, Florida, United States of America. As of the 2000 census, the city had a total population of 56,255 and as of 2009, the estimated population was 53,752...

.

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

Legislation

Congress passed the Submerged Lands Act
Submerged Lands Act
The Submerged Lands Act of 1953 is a U.S. federal law that grants states title to all submerged navigable lands within their boundaries. This includes navigable water ways, such as rivers, as well as marine waters within the state's boundaries—generally three geographical miles from the coastline....

 in 1953 to clarify responsibilities between state and federal government. This was immediately followed by the Outer Continental Shelf Lands Act (OCSLA) used to control leasing
Offshore oil and gas in the United States
Offshore oil and gas in the United States provides a large portion of the nation’s oil and gas supply. Large oil and gas reservoirs are found in the sea nearby Louisiana, Texas, California, and Alaska...

 of exploration rights in the Outer Continental Shelf
Outer Continental Shelf
The Outer Continental Shelf is a peculiarity of the political geography of the United States and is the part of the internationally recognized continental shelf of the United States which does not fall under the jurisdictions of the individual U.S...

 (OCS). 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
National Environmental Policy Act
The National Environmental Policy Act is a United States environmental law that established a U.S. national policy promoting the enhancement of the environment and also established the President's Council on Environmental Quality ....

 (NEPA). NEPA concluded that every major federal action (i.e.: oil exploration on the OCS) required an Environmental Impact Statement (EIS). In 1982, The U.S. Department of the Interior created the Mineral Management Service (MMS) to monitor development on the Outer Continental Shelf
Outer Continental Shelf
The Outer Continental Shelf is a peculiarity of the political geography of the United States and is the part of the internationally recognized continental shelf of the United States which does not fall under the jurisdictions of the individual U.S...

. The MMS leases submerged federal lands and assesses the environmental effects of exploration and drilling (by issuing an EIS). In 1984 Congress passed the National Fishing Enhancement Act (NFEA) which provided the basis for artificial reef programs. 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.

Trends

Rigs-to-Reefs was first explored in 1979 when the first oil rig was transported from Louisiana to a Florida site. 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. Texas later followed this example. Rigs-to-Reef is now the core of both Louisiana and Texas' artificial reef programs. From 1987-1995, of the over 941 platforms removed from Louisiana and Texas waters, 90 became artificial reefs. 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.

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
California Coastal Commission
The California Coastal Commission is a state agency in the U.S. state of California with quasi-judicial regulatory oversight over land use and public access in the California coastal zone....

 held hearings, but then the legislation was tabled. Even with the RTR successes in the Gulf of Mexico and Philippines, 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. Divers assess fish
Fish
Fish are a paraphyletic group of organisms that consist of all gill-bearing aquatic vertebrate animals that lack limbs with digits. Included in this definition are the living hagfish, lampreys, and cartilaginous and bony fish, as well as various extinct related groups...

 populations surrounding platforms. 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. Research observing rockfish populations on oil rigs supports both theories.

Liability

Commercial fisherman who trawl sometimes oppose RTR because their nets may snag a rig, creating a hazardous situation. Several fisherman have reported tangling their nets on submerged rigs. 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.

The MMS does not release an operator from liability unless another entity accepts ongoing liability for the rig. 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. Critics claim that the primary reason that operators support RTR is their desire to offload decommissioning costs and liability.

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.

Ethics

As with cap-and-trade and ecotourism
Ecotourism
Ecotourism is a form of tourism visiting fragile, pristine, and usually protected areas, intended as a low impact and often small scale alternative to standard commercial tourism...

, 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. "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.
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