Gulf of Mexico rigs-to-reefs program contested in letter to Interior Secretary and new e-book

By Benjamin Alexander-Bloch, | The Times-Picayune
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on July 30, 2014 at 2:49 PM, updated July 30, 2014 at 2:52 PM

As the federal government this summer considers revised rules on the decommissioning of Gulf of Mexico oil rigs, many environmental groups are pushing for a reexamination of the rigs-to-reefs program.

The program, extremely popular among most Louisiana anglers because the artificial reefs attract fish, allows some oil and gas companies to convert their decommissioned rigs to reefs instead of requiring the companies to remove them.

But on Wednesday, Clint Guidry, president of the Louisiana Shrimp Association, joined calls for the U.S. Department of the Interior’s Bureau of Safety and Environmental Enforcement (BSEE) to require the removal of rigs instead of converting them into such reefs.

There is debate about whether the artificial reefs promote aquatic life or simply attract fish, concentrating them for easy fishing access. And some environmental groups contend that their artificial habitats create more harm than good.

There are about 450 platforms in the Gulf that have been converted to permanent artificial reefs through the program that started in 1985. By far the majority of those reefs – more than 300 – are in Louisiana waters.

While the federal Idle Iron policy requires oil and gas companies “to dismantle and responsibly dispose of infrastructure after they plug non-producing wells,” the rigs-to-reefs programs allows some the decommissioned rigs to remain on the site as artificial marine habitats.

Guidry joined the authors of the recently released free e-book Bring Back the Gulf, which also advocates for requiring the removal of oil rigs.

Shrimpers often are against the artificial reefs, largely because the reefs can tangle their nets.

Guidry on Wednesday argued that the oil industry should “return Gulf bottoms to trawlable bottoms” and that that would “help everyone, not just shrimp fishermen, as it will help all users who have to navigate the Gulf.”

Last Wednesday (July 23), about 25 individuals, mainly representing environmental groups, signed a letter sent to Interior Secretary Sally Jewell urging “strong and consistent implementation of the Department of Interior’s Idle Iron policy requiring full decommissioning of spent oil and gas structures at the end of their useful economic life.”

“Industry has expanded their requests for Interior Department waivers to Idle Iron protocols – instead seeking permanent seabed disposal of disused oil and gas infrastructure throughout Gulf of Mexico waters under the misnomer of Rigs-to-Reefs projects,” the 7-page letter later continued. “The permanent seabed placement of obsolete oil and gas extraction infrastructure invites more ecosystem damage rather than restoring it as originally envisioned.”

The letter in part stated that the rigs’ deteriorating metal can harm “sensitive Gulf habitats.” It also states that, by attracting fish, the artificial reefs can cause overfishing of certain species and can expand habitat for invasive species.

Richard Charter, a senior fellow at The Ocean Foundation who co-authored the book Bring Back the Gulf that was released last week, said during a teleconference on Wednesday that oil and gas companies have an “obligation to return a reef bed to its natural state.”

Charter said “thousands of rigs due for decommissioning in the coming years” as some of the oldest deep-water wells reach the end of their lives. His his co-author, DeeVon Quirolo, added that the Gulf has reached “critical threshold of such artificial structures.”

In May, Jewell’s Chief of Staff Tommy Beaudreau said the agency this summer would be reviewing the regulations governing the decommissioning and related liability issues of old offshore oil infrastructure, according to Charter and Quirolo.

The Interior Department did not immediately return | The Times-Picayune questions on Wednesday about the status of that review, although Charter and Quirolo said that Interior is expected to hold public hearings on the matters as it move forward.

To see Charter and Quirolo free e-book, click here. There are iPad and Kindle versions available on their website,

Letter to Interior:

Bring Back the Gulf

July 23, 2014


Interior Secretary Sally Jewell

Office of the Secretary

United States Department of the Interior

1849 C Street, N.W.

Washington, D.C. 20240


Dear Ms. Jewell:


As our nation rightfully moves forward with necessary ecosystem restoration efforts aimed at bringing the Gulf of Mexico back to its full health and productivity in the wake of the BP Deepwater Horizon disaster, the following individuals and organizational representatives express our support for strong and consistent implementation of the Department of Interior’s Idle Iron policy requiring full decommissioning of spent oil and gas structures at the end of their useful economic life.


We are collectively committed to furthering the broad long-term restoration of the Gulf of Mexico in the context of reconstituting what has previously been one of the planet’s most productive ecological treasures. This view is consistent with the simple fact that our nation’s coastal and marine oil and gas infrastructure was always engineered and intended to be only temporarily deployed in our ocean waters and wetlands. As you know, each federal lease-sale for oil and gas development includes a contractual obligation to which industry has willingly committed, stipulating that all infrastructure must be removed and the seabed returned to its previous natural state at the end of the economic life cycle of each offshore production facility. This policy must be honored and acted upon in good faith.


Industry has expanded their requests for Interior Department waivers to Idle Iron protocols – instead seeking permanent seabed disposal of disused oil and gas infrastructure throughout Gulf of Mexico waters under the misnomer of Rigs-to-Reefs projects. The permanent seabed placement of obsolete oil and gas extraction infrastructure invites more ecosystem damage rather than restoring it as originally envisioned. The proposed additional discard of uncounted tons of deteriorating scrap metal into sensitive Gulf habitats will result in significant cumulative environmental degradation, including but not limited to more extensive overfishing, adverse impacts on migratory species, expanding opportunistic habitat for invasive species, and damaging impacts on deepwater corals and other marine life.


The primary beneficiary from such disposal methods is of course the oil and gas industry, which saves money and circumvents their liability on each waiver to the Rigs-to-Reefs programs in lieu of full decommissioning. Instead, we now need to apply our collective science-based efforts at true restoration measures. In this context, ocean dumping of spent rigs represents a huge step backward and is clearly contrary to responsible restoration of our Gulf waters.

Gulf residents and stakeholders have already experienced devastating loss of wetlands caused in large part by extensive dredging for oil and gas industry infrastructure. Marine debris is another growing problem to which the oil and gas industry has contributed for many years. Infrastructure conflicts with certain sectors of commercial and recreational fishing pose additional hazards leading to costly equipment loss and human safety issues.


We seriously question whether the criteria of the National Artificial Reef Plan are being met with respect to the use of decommissioned rigs as underwater artificial habitats. The environmental impacts of the proliferation of Rigs-to-Reefs proposals, in the greater context of the overall impacts of such extensive oil and gas development on Gulf of Mexico ecosystems, and the large numbers of rigs coming up for decommissioning in the next few years, are not now being adequately considered in any cumulative context. An emerging concern is the potential for considerable hurricane damage to these structures. Hurricanes and tropical storms have led in the past to oil leaks, expensive disposal challenges, questionable liability issues, hazards to navigation and shipping accidents. Some of the existing spent rigs are continuing to leak hydrocarbons into the ocean for years after their useful life.


Decisions now being made about whether hundreds of remaining spent oil rigs need to be fully removed and seabed drilling sites restored as promised have very broad implications for the future of the Gulf and its residents. We have reached the point where the Gulf likely will not accommodate hundreds of additional at-sea rig disposals without sustaining tangible damage to the ecological balance of the region. We are reaching a critical threshold for seabed disposal of such structures. The Gulf is already home to the largest underwater artificial reef system in the world. These sites are managed by Gulf States that have accepted significant liability for their continued maintenance. Yet because these sites are not marine reserves, many of the fish they may aggregate contributes to overfishing of key Gulf fisheries, making it difficult to implement effective management strategies for species such as red snapper.


Left alone by human intervention and absent new damage, the ocean environment is a powerful and pervasive self-healing mechanism. A compelling case can be made that the natural ecosystem design that preceded the era of offshore oil development was likely the most successful biological niche that could have evolved in that particular location.


The outcome of the present debate over the future fate of obsolete drilling structures throughout the Gulf of Mexico has implications affecting as-yet-undrilled waters far beyond the confines of the Gulf itself. The Interior Department and the oil companies are well aware that altering the subsequent “life cycle costing” considerations for a company as it evaluates whether or not to bid on a particular drill site can alter a future bidding decision considerably when the drilling company knows it will not be required to remove and recycle the rig itself at the end of its useful lifetime.


America knows how to constructively and safely accomplish full decommissioning of spent drilling rigs that have been very profitable to their owners and shareholders. Clearly, offshore operators should now follow through and step up to their legal responsibilities and fulfill the Idle Iron requirements to which they previously agreed.


Our organizations and our millions of members stand willing to work with the Department of Interior and all responsible parties of interest to ensure evenhanded enforcement of the Idle Iron policy to achieve responsible decommissioning of what were always intended to be temporary oil and gas structures and to move forward with restoration of the Gulf of Mexico to its full potential ecosystem productivity.


To achieve these goals, we ask the Interior Department to halt issuing waivers that enable spent rigs to remain on the ocean bottom and require restoration of the seabed to its original condition as required under the Idle Iron policy. This will promote fisheries management to reduce overfishing and help restore the Gulf of Mexico to its former vibrant health and productivity.   The states can manage the extensive existing “reef” sites that comprise the largest artificial reef structure in the world for recreational and commercial fishing and diving.


We further recommend:

  • That a broad representation of the full range of public interests be more inclusively involved in the relevant federal and state decision-making processes regarding spent oil and gas structures
  • Monitoring of state Rigs-to-Reefs programs to ensure ecological integrity in maintenance and future deployments
  • Independent scientific research that is not unduly influenced by the oil and gas industry, especially for deep-sea processes that are vulnerable to impacts accompanying the growth of deepwater drilling
  • Enforcement of existing environmental laws that can help ensure a healthy Gulf of Mexico
  • Support effective management of all fisheries for long-term, ecosystem-based resilience and sustainability
  • Creation of deepwater preserves to protect biologic diversity and provide research opportunities through a Gulf-wide monitoring effort, especially in the northern Gulf, where oil production remains concentrated.


The most optimistic and compelling goal of successful restoration would be to achieve strong economic valuation and full ecosystem productivity by anticipating rather than impeding future sustainable use. The value of a Gulf of Mexico that boasts sustainable seafood harvests, safe navigation, ecological stability, and a healthy quality of life for its residents is worth protecting. The alternative is massive fiscal and ecological liabilities that will fall to the public as a result of an expansion of the practice of simply discarding retired rigs on the seabed. The decisions now before us about whether or not to restore the Gulf will ultimately determine the fate of much of our global ocean. We can either restore it to its former vitality, or allow it to become a junkyard of epic proportions.


Thank you for your consideration,


Richard Charter

Senior Fellow

The Ocean Foundation, Coastal Coordination Project

1320 19th St, NW, 5th Floor

Washington, D.C. 20036


DeeVon Quirolo

Marine Conservation Consultant

222 East Liberty Street

Brooksville, Florida 34601


Athan Manuel

Director, Lands Protection Program

Sierra Club

50 F Sst. NW, Eighth Floor

Washington, D.C. 20001


Robert W. Hastings

Chair, Alabama Chapter of the Sierra Club

141 N. Northington Street

Prattville, AL 36067


Cynthia Sartou, Executive Director

Gulf Restoration Network

P.O. Box 2245

541 Julia Street

New Orleans, Lousiana 70130


Miyoko Sakashita, Oceans Director

Center for Biologic Diversity

351 California St., Ste. 600
San Francisco, California 94104


John Hocevar, Oceans Campaign Director

Greenpeace USA

702 H Street, NW, Suite 300

Washington, D.C. 20001


Linda Young, Executive Director

Florida Clean Water Network

P.O. Box 5124

Navarre, Florida 32566


Gary Appleson, Policy Coordinator

Sea Turtle Conservancy

4424 NW 13th St, Ste B-11
Gainesville, Florida 32605



Meredith Dowling, Gulf Program Director

Southwings Gulf Office

5500 Prytania Streeet, #532

New Orleans, Louisiana 70115


George Barisich, President

United Commercial Fishermen’s Association

3413 Don Redden Court

Baton Rouge, Louisiana 70820


John W. Day, Jr. Ph.D.

Distinguished Professor, Dept. of Oceanography and Coastal Sciences and Coastal Ecology Institute, School of the Coast & Environment

Louisiana State University, Baton Rouge, Louisiana 70803


Len Bahr, Ph.D.
Homer Hitt Alumni Center – 2nd Floor Ballroom

2000 Lakeshore Drive
New Orleans, Louisiana 70148


John McManus, Ph.D.

Professor, Department of Marine Biology and Ecology

University of Miami
4600 Rickenbacker Causeway
Miami, Florida 33149

Stephen Bradberry, Executive Director

Alliance Institute,

3321 Tulane Avenue

New Orleans, Lousiana 70119


Michael Tritico, President


P.O.Box 233

Longville, Louisiana 70652-0233


Robert G. Bea, Ph.D. Professor Emeritus

Center for Catastrophic Risk Management

University of California Berkeley

212 McLaughlin Hall

Berkeley, California 94720




Luiz Rodrigues, Executive Director

ECOMB (Environmental Coalition of Miami Beach)

210 Second Street

Miami Beach, Florida 33139


Colette Pichon Battle, Director/Attorney

Gulf Coast Center for Law & Policy

620 Oak Harbor Boulevard Ste. 203

Slidell, Louisiana 70803


Dede Shelton

Executive Director

Hands Across the Sand

2917 E. Indian Creek Drive

Meridian, Idaho 83742


Michael Stocker


Ocean Conservation Research

P.O. Box 559

Lagunitas, California 94938


Kathi Koontz

Ocean Consultant

1736 Cedar St

Berkeley, California 94703


Delci Calcote

Executive Director

Alaska Inter-Tribal Council

P.O. Box 243237

Anchorage, Alaska 99524


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