Bring Back the Gulf

It is time to fully restore Gulf of Mexico ecosystems and fisheries to their former natural productivity.

• Idle Iron policy: The U.S. Interior Department’s Idle Iron policy requires that once oil and gas structures end their useful life, they are to be decommissioned and removed in order to return the seabed to as near its natural pre-drilling state as feasible. This contractual obligation is written into each Outer Continental Shelf oil and gas lease. There are more than 6,000 active leases in the Gulf of Mexico as of December 2013. This Idle Iron policy is consistent with current efforts in the post-Deepwater Horizon oil spill era to restore Gulf of Mexico ecosystems.

• Rigs-to-Reefs: Many temporary oil structures have now become a permanent part of the seascape under what’s being called the Rigs-to-Reefs program. The U.S. Department of the Interior provides a “waiver” from the Idle Iron Policy that allows a state to place a retired oil structure in a permanent “reefing site.” In the next few years, many rigs will reach the end of their useful life and will require decommissioning, both in the Gulf of Mexico and off the California coast. Efforts are underway by the oil industry to save themselves decommissioning costs by expanding the Rigs-to-Reefs program. But it is questionable whether these underwater artificial habitats meet the criteria of NOAA’s National Artificial Reef Plan.

• Hurricane Damage & Leaky Rigs: The removal of spent rigs is critical because many rigs are damaged during hurricanes and become underwater hazards to navigation to boaters and large vessel traffic. Other abandoned rigs continue to leak hydrocarbons into the ocean if not removed in a thorough and timely manner.

• Overfishing: Despite the fact that the rigs may sometimes provide habitat for fish and therefore attract fishermen and divers, there is no scientific consensus that abandoned rigs contribute to maintaining fisheries stocks, or achieve fisheries management goals. Instead, the spent rigs simply aggregate fish, thereby contributing to overfishing. The most abundant fish on the rigs, red snapper, are already considered “overfished” in the Gulf of Mexico. Habitat of this type is not needed to support fisheries goals.

• Impact on migratory species: The effect of offshore rigs as fish-attracting devices also impacts management of highly migratory fish species, including yellowfin and bluefin tunas and broadbill swordfish, and interferes with the natural feeding and spawning patterns of many species.

• Invasive Species: Idle Iron structures that remain in place present an opportunity for invasive species to establish themselves in new locations, especially in deeper waters. Two of the six non-indigenous species now found in the Gulf, the brown mussel and the white crust tunicate (ascidian), currently cause a range of problems. Although not yet listed as a “Non-Indigenous Species”, the source dinoflagellates for the dangerous ciguatera have recently been found on oil platforms in the Gulf, and tubastraea, another invasive species, has established itself on the spent rig within the Texas Flower Garden Banks National Marine Sanctuary.

• Impact on Deepwater Corals & Other Marine Life: The biodiversity of deep sea corals, fish and macroinvertebrates in deep water is poorly understood and the potential for negative impacts from deepwater drilling and for simply allowing oil companies to discard their spent rigs on the ocean floor is a growing concern.

• Stakeholder Issues: The extensive oil and gas structures in the Gulf of Mexico present user conflicts with certain sectors of commercial and recreational fishing such as upper-ocean trolling, mixed-depth long lining, and deep-bottom trawling, and the abandoned infrastructure poses environmental hazards leading to costly equipment loss and threats to human safety. NOAA has set up the Fisherman’s Compensation Fund to compensate fishermen who have experienced gear and vessel losses due to navigational hazards from oil and gas operations. Small vessel captains can also find maneuvering their vessels among the oil rigs to be a dangerous proposition.

• Loss of Wetlands: Residents of the Gulf have endured extensive environmental degradation to coastal areas, in addition to loss of wetlands caused in large part by extensive dredging for drilling access and installation of infrastructure for the oil and gas industry. Marine debris also is a growing problem that affects environmental quality of life throughout the Gulf, with up to 10% of all debris at Padre Island National Seashore attributed to oil and gas operations. Fish, birds, and wildlife, including endangered species of sea turtles, also suffer due to loss of habitat and interference from marine debris.

• Critical threshold: Approximately 5% of the habitat in the Gulf of Mexico is now comprised of state-designated “reefing sites,” which fail to equal natural coral reefs in biological diversity. The Gulf may be reaching a critical mass of discarded infrastructure. The current trend toward installing oil and gas rigs in deeper water will make future Rigs-to Reefs sites inaccessible to coastal fishermen and divers. Deepwater drilling also presents unique abandonment difficulties and raises new questions concerning artificial reef planning.

• Oil Industry Saves Billions at Our Expense: The main beneficiary of the Rig-to-Reefs program is the oil and gas industry because the program saves rig owners billions of dollars on decommissioning expenses. Plus, it relieves them of all liability for these temporary structures that may be toppled in place, sited in place, or hauled to a designated “reefing site” in exchange for transfer of ownership and a donation by the oil companies to the state trust fund that commits to maintaining them in perpetuity. This lax reefing policy cuts the oil companies’ decommissioning costs by roughly one-half and transfers liability for future problems to the public. Future decisions about new offshore drilling plans in areas of the Outer Continental Shelf also may be affected by this cost-avoidance opportunity if rigs that generate massive profits for their owners can be simply dumped in the ocean when operations cease.

We ask the Interior Department to require restoration of the seabed to its original condition as required under the Idle Iron policy and halt the practice of issuing waivers that enable spent rigs to remain on the ocean bottom. This will promote fisheries management that can constructively reduce overfishing and thereby help to restore the Gulf of Mexico to vibrant health and productivity. The states can then manage the extensive existing “reef” sites that already comprise the largest artificial reef structure in the world, and oversee recreational and commercial fishing and diving within these sites. The economic valuation of a vibrant future Gulf of Mexico that boasts sustainable seafood harvests, safe navigation, ecological stability, and healthy quality of life for its residents is worth pursuing, in contrast to the 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.

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 biological processes that are vulnerable to impacts accompanying the growth of deepwater drilling

• Renewed 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.

For more information, contact:

DeeVon Quirolo at dquirolo@gmail.com or Richard Charter at www.oceanfdn.org.