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s
ENVIRONMENTAL CONSIDERATIONS
. .
The installation and operation of offshore platforms has attracted
environmental attention for almost 40 years. From a historical
perspective, concerns, whether focused on the issue of offshore
leasing or on the environmental effects of drilling and production
operations, have been addressed through the regulatory process and
environmental law. Environmental concerns associated with the
disposition of offshore platforms are relatively new since only a
small number of structures have been removed. To define the conse-
quences and concerns, leading spokesmen from environmental interest
groups were surveyed, and public comments were obtained by the
Minerals Management Service (MHS) on the committee's behalf (see
preface and Appendix B.).
Disposing of offshore structures results in both positive (enhance-
ment) and adverse (disruption) environmental impacts. The positive
impacts are related to potential fisheries aggregation and enhancement
values of structural elements left in the marine environment. Poten-
tial adverse concerns include continuing navigational risks (which
could lead to pollution damage) as well as the appropriate cleaning of
structures, their physical removal, resulting bottom clean-up, the
logistics associated with transport, and ultimate disposition. While
each of these potential impacts is a subject of environmental concern,
properly executed disposition was not cited as a major problem by
those surveyed. Indeed, commentors expressed as much concern for
.~
Records of the following telephone conversat ions are in cocci t tee
files. Randy Lanctot, Louisiana Wildlife Federation, S December 1984;
Marsha Rockefeller, Massachusetts Aububon Soc iety, S December 1984;
Herman Rudenberg, Lone Star Chapter , S terra Club, 5 December 1984; Hal
Scott, Department of Interior OCS Policy Advisory Committee, 21
December 1984; Sharron Stewart, Texas Environmental Coalition, 21
December 1984; Michelle Perrault, Sierra Club, 13 January 1985; Sarah
Chasis Natural Resources Defense Council, 17 January 198S; Ralph
Rayburn, Texas Shrimp Association, 25 March 198S; and David Hickok,
Alaska Environmental Information Data Center, 27 March 1985. See also
letters from Sarah Chasis dated 26 April 1985 and David Hickok dated
30 April 1985.
45
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habitat loss as for all other impacts associated with disposition.
This probably reflects the regional perspective of the activity in the
Gulf of Mex i co .
Env i ronmental concerns were expres sed as to the mortgaging of
future opportunities at the expense of simple or cost-effective
platform removal options. For example, deep-water disposal was
generally considered shortsighted, recognizing potential future
impacts on other ocean users. Toppling in place received similar
expressions of concern, because reviewers were reluctant to make the
ocean a "junkyard." While disposition options received a broad array
of environmental expressions, they were often regionalized, reflecting
historical perspectives as well as the economic consequences apprec~-
ted by the respective respondents.
EFFECT OF OFFSHORE PLATFORMS ON BIOLOGICAL RESOURCES
When offshore structures are installed, they are colonized by a
diversity of marine life. These may include barnacles, oysters,
mussels, bryozoans, sponges, and (in subtropical or tropical waters)
corals. These organisms attach and grow on the structure and provide
a source of food and habitat for many invertebrates and fishes.
Collectively, these life forms comprise the structure's biofouling
community (Galloway and Lewbel, 1982~. This community typically
supports an assemblage of pelagic and demersal fishes that, in certain
circumstances, has implications for recreational and commercial
fisheries.
A diversity of fishes can be associated with offshore structures.
As Galloway and Lewbel point out:
The available data and information about these characteristic
fish assemblages seem to indicate that they are more dictated
by the physical factor of substrate than by biological inter-
relationships. If this is true, the fish assemblages associa-
ted with petroleum platforms are not true biological commun;-
ties, but rather only flexible confederations of species
loosely allied by a similar environmental requirement or
preference, i.e., the presence of structures.
The fisheries aggregation and enhancement values of offshore oil
and gas structures are well recognized in the Gulf of Mexico region.
Interests outside the Gulf of Mexico region, however, have questioned
these enhancement values in their respective regions. For example,
state agency officials on the east and west coasts generally consider
oil and gas structures as obstructions to navigation and commercial
fishing interests, and take positions that protect these traditional
industries. The diversity of regional perspectives is perhaps a
reflection of the historical experiences of commentators as well as
the uniqueness of regional fishery resources.
Petroleum platforms in the Gulf of Mexico serve as aggregation
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points for large numbers of fish of many species. However, the extent
to which this aggregation increases exploitation (greater catch par
unit of effort), possibly to the point of overexploitation, is of
concern to fisheries managers. Where reefs enhance fisheries, manage-
ment regimes are necessary to avoid this possibility. States with
active offshore development (i.e., Louisiana and Texas) are now
concerned that when production ceases, they may lose valuable
fisheries habitat (in place or emplaced elsewhere) and are working to
identify critical habitat areas. Some states bordering the Gulf of
Mexico, including some without offshore oil and gas development, are
working to secure obsolete structures for deployment as artificial
reefs off their coasts.
ENVIRONMENTAL RAMIFICATIONS OF DISPOSAL OPTIONS
Complete Removal With Disposal Onshore
When a structure is removed from the OCS, as under current regula-
tions, organisms that have attached and grown on the structure are
destroyed. Also, the substrate that has attracted important recrea-
tional and commercial fisheries is lost. As these losses occur, the
fish are attracted elsewhere for food and shelter. Fishermen likewise
must seek new fishing locations that are within their operational
constraints. The significance of these losses is perhaps best under-
stood in light of a proposal several years ago to have the Shell Oil
Buccaneer Field designated a marine sanctuary. Though the associated
marine life is attached to the man-made structures, the reef-like
communities are comparable to natural reefs and, it can be argued,
worth keeping as a sanctuary area. During onshore dismantling opera-
tions, there is the possibility of air pollution and environmental
degradation. There are opportunity losses, as well. At a time when
suitable reef materials are in short supply, onshore disposal
eliminates the possibility entirely that these materials can be used
as reefs.
There are, however, gains associated with onshore disposal. Not
the least of these is the removal of a potential hazard to naviga-
tion. When the structure is removed for transport to shore, the
bottom is to be restored so that trawl fishermen can again make use of
the site without the prospect of destroying their nets. If the
structure was in an area once heavily used for trawling, this gain can
be an important benefit. The "remove to shore" alternative is almost
universally favored by environmental interests located outside the
Gulf of Mexico area who reject the reef benefits of structures as not
relevant to circumstances in their regions. This option is also
favored by fishermen who use new gear types that may be adversely
affected by underwater obstructions. Included here are such items as
bottom longlines, deep-water traps, and underwater trawls. Some of
this gear may be used in depths as great as 1,000 meters.
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Ocean Dumping of Obsolete Structures
A letter to the committee from the Environmental Protection Agency
(EPA) states that the EPA has a policy of recycle and reuse of
offshore platforms. This includes the options of onshore disposal
(with recycling of salvaged materials) and the use of platforms as
artificial reefs once removed from the production site. Ocean
disposal of offshore platforms has to date only been permitted where
safety is an issue or there has been an emergency. In February 1984,
for example, SPA issued a permit for ocean disposal of a platform that
had been damaged as the result of collision with a tanker in 1980.
The current practice, therefore, is to place the burden of proof on
the platform owner to demonstrate why reuse and recycling are not
feasible, that the public safety is threatened, and that there is good
and sufficient reason for ocean disposal as an alternative of last
resort. However, the letter from EPA does state, "We are considering
a general permit for those platforms or jackets damaged by storms or
collision, etc. and [which] are creating a hazard to navigation as
determined by the Coast Guard and/or the Corps of Engineers, and [for
which] disposal in a better location would be more advantageous "
Environmental spokesmen generally opposed ocean dumping of obsolete
platforms, or they expressed caution because of a lack of informa-
tion. Most viewed it as misusing the ocean as a "junkyard" and saw
platform disposal as a bad precedent. They were deeply concerned with
safety and navigation hazards because of the potential environmental
harm that often accompanies accidents. Consequently, there was little
support for ocean dumping of structures except as an emergency provi-
sion. Those who believe that artificial reefs are in the public
interest argued that dumping is a poor use of materials that could
otherwise be used as reef building material.
Ocean dumping is regulated under the EPA Ocean Dumping Regulations
and Criteria (40 CFR 220-229), as has been described. Specific
environmental concerns are addressed through requirements for siting,
predisposal cleanup, and monitoring. The general concern about
conflict with other ocean uses is not so eas fly addressed. The
practice of ocean dumping, even if carefully sited and controlled,
could preclude future deep-sea mining and fishing activities, for
example .
A related point of interest is the disparity in the environmental
policy and requirements that apply to the disposition of offshore
structures as compared with those that apply to the disposition of
obsolete ships. A general permit for the ocean disposal of obsolete
ships is in effect (40 CFR 229.3). The terms of the permit require
that (except in emergencies) the dumper provide advance notice to the
EPA, that the operation be supervised by the Coast Guard, and that the
vessel be cleaned of possible pollutants. Other requirements of the
Letter of 27 November 1984 from Tudor Davies, EPA to W. M. Benkert.
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general permit pertain to the choice and charting of sites for
disposing of ships and the method of sinking.
The Leave-in-Place Option
The leave-in-place option is not feasible given legal requirements
for the removal of obsolete structures. There has been public support
for this option as evidenced by an EMS notice of interpretation
published in the Federal Resister (Notice of Interpretation, 1983~.
Generally speaking, when a platform is left in place the reef-like
community that has developed on the structure remains to sustain fish
populat ions at all levels in the water column . As substrate in the
water column is removed, environmental benefits are lost. While the
leave-in-place option is biologically appealing, there are questions
as to who will bear the liability and funding responsibilities for
maintenance. There are concerns about navigational hazards and a need
to restore trawlable bottoms for commercial fishermen Some of the
environmental spokesmen were skeptical and saw the leave-in-place
option as providing the oil and gas industry with unwarranted and
uncompensated relief from a major (and costly) obligation.
Environmental spokesmen in the Gulf of Mexico recognized that
existing structures provide important habitat benefits and that
efforts should be made to perpetuate these benefits. While existing
structures all provide substrate and a reef community to some extent,
depending on the age and location of the structure, it is recognized
that they do not all provide the same level of fisheries benefits.
This was supported in a recent study by Ditton and Auyong (1984) which
showed that all structures do not receive the same level of use.
Some, because of their proximity to shore access points, are used more
by recreational f ishermen than others located further offshore.
A case can be made for limited application of this option in the
Gulf of Mexico. The leave-in-place option would be appropriate in
close proximity to an onshore recreational fishing access point (10 to
20 miles offshore) or where extensive recreational fishing use is
documented. The exclusion mapping procedures developed by the Sport
Fishing Institute (Anon., 1984) currently being implemented in the
Gulf of Mexico with support from the National Marine Fisheries
Service, are useful for identifying the structures that have the
greatest probability of use and where conflict with other marine U9QS
can be avoided. This option merits consideration to the extent that
liability and maintenance issues are handled, conflicts with other
uses of ocean space are avoided, and constituent support is demon-
strated.
The Partial Removal Options
The partial removal options are accompanied by the losses of
substrate-related reef community and a diverse fishery. Though
fisheries would continue to be enhanced to a limited degree, partial
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removal in some instances would reduce the public benefits associated
with recreational fishing activity. Only fishermen with radio naviga-
tion capability would be able to locate and fish the habitat, unless
the art i f i c i al reef was marked wi th a buoy, wh i ch would need to be
maintained. Commercial fishermen would likely be opposed to any
removal options that would exacerbate the problem of bottom hangs and
debris on the bottom. Under the partial removal option, there would
either be little recreatonal fishing because of the distance from
shore required to attain the necessary navigation clearance, or, in
the case of structures closer to shore, there would be little profile
remaining to support a diverse fish population.
The Topple-In-Place Option
When an obsolete structure is toppled, the resultant benthic reef
would have a much less diverse fishery than previously when the struc-
ture was in place and provided substrate at all depths. The topple-
in-place option could lead to a distribution of additional materials
on the bottom that could lead to increased snagging of fishermen's
nets. Commercial fishermen would favor the restoration of trawlable
bottoms. Persons contacted by the committee with ~ knowledge of
structures in the Gulf of Mexico and their associated enhancement
benefits felt that the topple-in-place option could pose a hazard to
navigation as well as problems for commercial fishermen. To the
extent that toppling in place could be implemented judiciously
following established procedures (Sport Fishing Institute, 1984) for
artificial reef planning, this opposition could be overcome.
The Emplace Elsewhere Option
To date , there have been three cases where obsolete oil and gas
structures have been removed, transported to a new location, and
deployed as a reef for fishing enhancement purposes at a permitted
site. Although there are environmental costs associated with the
conversion of a standing platform to a benthic reef, there are
numerous benefits as well if reef deployment is conducted in a
well-planned manner. If platform reefs are sited on the basis of the
best combination of physical, biological, social, and economic
considerations rather than expedience, tangible benefits are likely.
When a platform is removed and redeployed as a reef near a major
population center or tourism destination in conjunction with a formal
plan, economic benefits associated with increased recreation and
tourism activity will be forthcoming for the adjacent community. The
economic impacts associated with artificial reefs are well documented
in the technical literature. Environmental spokesmen in the Gulf
region favored this option because they were aware of the biological
and economic benefits involved. They also appreciate the reduction of
user conflicts that occurs as a result of the permitting process.
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Environmental spokesmen outside the Gulf area generally rejected
these benefits, primarily because of the lack of demand for reef
development to enhance fisheries or because the concept was considered
inappropriate to their regions. To the extent that obsolete
structures are poorly sited as reefs and public use benefits are
limited, it can be argued that this option is often little more than
ocean dumping.
To avoid misuse of the emplace elsewhere option, the state of the
art of artificial reef planning needs to be improved. In this regard
there are several positive forces at work: (1) the recently passed
National Fishing Enhancement Act (P.L. 98-623), (2) the National
Artificial Reef Plan to be implemented as a result of this Act, (3)
the work of the National Artificial Reef Development Center of the
Sport Fishing Institute to rationalize the reef planning process, and
(4) the general permit for artificial reef development recently
developed in the Jacksonville , Florida office of the U.S. Army Corps
of Eng i nears ~
There appear to be fewer problems associated with the emplace
elsewhere option. Liability problems remain to the extent that the
reef deviates from permit requirements. Siting problems can be over-
come through communication and negotiation in the permitting process.
Funding still presents problems for the reef sponsor as well as the
oil company with a disposal problem. Mechanisms are needed for
funding reef maintenance in perpetuity. Likewise, oil companies need
incentives above and beyond "good public relations" to implement this
disposal option on a long-term basis. This option is likely to be
pursued only to the extent that the cost to the structure owner for
artificial reef development does not exceed the cost of other options.
REGIONAL CONSIDERATIONS
Support for reuse of offshore structures is limited primarily to
the Gulf of Mexico because that is where the problems and the oppor-
tunities lie. There are no offshore oil platforms in the Atlantic OCS
to date. While 14 platforms in Alaska state waters are approaching
retirement, the waters themselves are heavily laden with glacial silt
and subject to high currents. The platforms do not support local
fish populations, and there is no recreational fishery around them.
Off California, the number of current and projected offshore platforms
is small, in relation to the Gulf of Mexico. Thus, the size of the
recreational fishery that targets the platforms is also much smaller.
It should be noted, however, that at least one company harvests
mussels off California platforms for sale to restaurants.
Decisions on ultimate disposition should properly reflect environ-
mental benefits and costs on a case-by-case basis. Where intensive
letter and attachment from David M. Hickok, Alaska Environmental
Information Data Center, to C. A. Bookman, Marine Board, dated 30
April 1985.
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recreational fishing use can be documented (and where there are no
other structures available to attract fish), where important regional
economic impact losses are foreseen due to removal, and where
constituent pressure is brought to bear, alternatives to onshore
disposal should be considered. Competing uses of the area for
commercial fishing and navigation need to be fully considered as
well. For the foreseeable future, the coloration of aging platforms
with this combination of circumstances is found only in portions of
the Gulf of Mexico. Under other circumstances in other regions, it
may be appropriate to consider innovative uses of obsolete
platforms--for example, for weather observation, mariculture
fisheries, and research.
REFERENCES
Ditton, Robert 8., and Janice Auyong. 1984. Fishing Offshore
Platforms--Central Gulf of Mexico: An Analysis of Use at 164 Major
Petroleum Structures . Iletairie, La.: Minerals Management
Service. OCS Monograph MMS 84-0006.
Ditton, Robert B., and Alan Graefe. 1977. Recreational Fishing Use
of Artificial Reefs on the Texas Coast. Prepared for the Texas
Coastal and Marine Council, Austin, Texas. Contract Report (77-79)
080S.
Galloway, Benny J., and George Lewbel. 1982. The Ecology of
Petroleum Platforms in the Northwestern Gulf Of Mexico: A
Community Profile. New Orleans, La.: Bureau of Land Management,
Gulf of Mexico OCS Regional Office. Open File Report 82-03.
Anon . 1984 . Procedures for Exclus ion Mapping to Guide Future
State-Level and Local Artificial Reef Planning and Siting Efforts
in the Gulf of Mexico. Washington, D.C.: Sport Fishing
Ins t i tute . Unpubl i shed Report .
Notice of Interpretation. FR Yol. 48, No. 132, 81 July 1983.
Department of Interior, Minerals Management Service . 30 CFR Part
250, OCS; Interpretation Concerning Authority to Depart from OCS
Requirements. Signed 29 June 1983 by David C. Russell, acting
director of Minerals Management Service.
U. S. Congress, Public Law 98-623. National Fishing Enhancement Act of
1984 .
Representative terms from entire chapter:
artificial reef
