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APPENDIX ~
POSITIONS OF THE DEPARTMENT OF DEFENSE AND TlIE OIL INDUSTRIES
INTERNATIONAL EXPLORATION AND PRODUCTION FORUM
( Exchange of Correspondence )
76
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/tr~
6
.
DIE SECR ETAR Y OF DEf EASE
w^5~1 NGSo - . T~ D'S~R'CT oF ALUM I
Hr . Char Me ~ . DIBona
American Petroleum Snat$tute
~ 2 20 L Street, H. W.
Washington, D. C. 2000S
J/^
Dear tin DiB~
2 2 Ells 19~
AUG ~ ? RECK
- //~7
INSOLES J. Oi8Ol~
Shank you for your letter of July 27, l9B4 regarding the
need for appropriate international ·tenderde for the removal
of abandoned offshore ·tructures. As you noted, because of
it. triplications for nevigat$on, this issue is of particular
Importance to us. Maritime mobility ts vitel to the V.~.
national security, and our submerged forces are ~ critice1
component in our efforts to ensure strategic deterrence.
From a global perepective, the proliferation of nonpro-
ducing offshore structures could seriously degrade the mobility
and flexibility of our ·eaborne forces . Therefore, we agree
fu l ly that international removal ·tendarde are required .
To be effective. the resoo~1 ·tandarde must be binding,
a" coastal state discretion must be - inimised. Without these
elements, coastal states could come to their own conclus$one
as to what is ~ressonable., which would defeat the very purpose
of unt formity that internationa ~ standlar~le are want to serve .
Only globally established standards, which carefully delimit
minimum and maximum depths for rental, can protect against
abuse by other countries.
For this reason ~ here recommended the attached draft
standerde for interagency con~t~eration. The draft standards
have been carefully crafted to ensure that writhe mobility
will be protected, while providing industry with a more fIesible
alternative to the current Entirely remove. standard. Your
input ~ ill be extremely helpful In fine-tuning our proposal
be fore it ts submitted to the International 1laritime Organisa-
tion.
~ welcome your offer to work closely with my staff on
thi s important tes ue . My replies entat ive for Ocean Pol icy
Affable, Mr. Hugh O'Nelll (694-~7}, will be contacting you
for that purpose.
Attachment
Si~f9el', ,
~G:
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proposed Minimum Standards for
the Removal of Offshore
Structures and Installations
- All fixed structures utilized in the EEZ or on the continental
shelf shall. as an essential component of their design, provide
for their effective and expeditious removal.
- It shall be the obligation of the coastal state to require that
the corporate entity, individual or government under whose control
the structure existed to ensure that it is removed and disposed of
when no longer used for hydrocarbon recovery.
- In order to maintain an environment suitable for all forms of
navigation and other uses of the sea, removed shall be to within 5
meters above the sea floor in waters less than 400 meters' to
within 15 meters above the sea floor in waters less than 2000
meters and greater than 400 meters.
- All structures not entirely removed shall at ~ minimum be
modified to the above height and depth standards, shell be
indicated on marine charts prepared by ache coastal state and,
under guidelines provided by IMO, appropriate publicity shell be
Siven regarding the depth, position, and dimensions of any
installations or structures not entirely removed.
- When removing structures and installations components may remain
or be installed in or on the sea floor as necessary to protect the
environment or prevent interference with other uses of the sea.
Components remaining or installed for this purpose must not exceed
the distance above the sea flog: stated above.
- Nothing shall preclude any coastal stance depositing
concer~trations of removed structures in special areas for living
resource sanctuaries or related purposes so long as such placement
does not interfere with navigational and other non-fishing
acacia ities.
- Except in archipelegic sealanes and in international straits,
nothing shall preclude the coes~cal stance, in its territorial sea
{up to ~ limit not exceeding 12nm) or in waters less then 20
meters in depth, from permitting exemptions from these provisions.
- Nothing shall preclude the cosste1 state from imposing more
stringent removal standards for new or existing fixed structures.
- Structures existing prior to the adoption of these standards may
be grandfa~hered into the new standards' thereby avoiding the
restively removed. 1958 Geneva standard.
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Amerlcan Petrotoum Inetltute
1220 L St reef. loots ~ est
wsChtnQton D C cantos; ~
20- 682-8100 ], _
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The HonoraLl e
Ca spa r W. heinberger
Secretary of Defense
The Pentagon
Washington, D. C. 20301
July 27, 1984
Re: Appropriate International Standards for the Removal of
Abandoned Offshore Structures
Dear Mr. Secretary:
Over the past several years, both the oi ~ industry and the
Department of the Navy have wrestled with the issue of
appropriate removal requirements for offshore petroleum
structures once they have ceased operations. This matter has
arisen, inter alla, in the context of the Department of the
~-
Interior~s efforts to implement a ~Rigs to Reefe.' program. See,
48 Fed. - . 31397 (July 8, 1983). The question of removal is
particularly important to the Navy because of its implications
for navigation. Obviously, the issue of what internatione1
removal standards are or should be is of significant concern to
the American petroleum industry, as well as to our counterparts
throughout the world.
In early 1983 the American Petroleum Institute (API), the
National Ocean Industries Association, and several of their
member companies met with representatives of the Depar~nents of
Defense, State, Interior and Transportation. At that time we
expressed our concern about precipitous U. S. action concerning
the development of an i nternationa~ removal s tandard . We were
assured that no such action was imminent and that a dialogue with
industry or. its views regarding an appropriate standard would be
encourage_. Over the intervening months industry, through the ESP
Forum, has developed a consensus vies on thi s matter . As a member
of the For='Ti, API herewith formally submits the views of the E&P
Forum to your Department for its consideration (Attachment 1 ) .
The recent 'y concluded Convention on the Lax of the Sea includes
a provi sio-. which serves to make current the removal requi remeets
app] icabl ~ to abandoned offshore structures (Article 60. 3 ~ . The
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The Honorable
Caspar A'. ~'~inberger
July 27, 1984
Page 2
Convention recognizes that appropriate international standards to
ensure safes>, of navigation are to be developed by "the competent
international organization." Although undefined, it i 6 believed
that this term refers to the International Maritime Organization
(ICON. Irrespective of the U.S. refusal to sign the Convention
on the Law of the Sea and the uncertainty attendant to the
Convention ever going into force, we understand that efforts may
be mounting to address this issue in the loo, an organizatic~n of
which the 1!. S. is a member.
Fearful of premature consideration of this issue before the IMO
and cognizant of the desirability of industry reaching a
consensus on appropriate removal requirements, the EsP Forum
began considering this issue in late 1982. The E&P Forum is an
international organization comprised of public and private oil
companies and trade associations Membership list: Attachment
2~. Significantly, the ELP Forum has consultative status with
the IMO.
Given the strong possibility that this issue will be discussed at
an international level, API supports the prompt development of a
coherent Administration position on this issue and bel ieves that
the position developed by the E&P Forum would be a useful tool to
aid this process. In addition, the Forum will soon finalize a
series of background papers that will address:
world wide cost implications of various removal scenarios
· legal issues
· utility of abandoned structures for man-made reefs
· water depth requirements of present and future
maritime craft
· submarine lurking area risks
· fisheries concerns
· safety aspects of structure removal
A composite briefing package containing these materials will be
available and forwarded to you in the fall. These materials
should be useful in future discussions between governmental
agencies and the private sector.
The American Petroleum Institute would welcome the opportunity to
discuss this matter with you or appropriate members of your
staff. Although some background materials will not be available
for several months to come, the removal standard is of sufficient
importance that the development of any administration position in
this matte- should include early consideration of industries
views. Farther, He solicit any comments you may have on the
attached r sp Forur, position paper.
The industry presented its views to the Departments of State and
Interior G-. July 13, and we look foreyard to an opportunity, to do
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Representative terms from entire chapter:
american petroleum
The Honorab} e
Caspar a;. we i nberger
3u ~ y 2 7, ~ 9134
Page 3
so with your Department· In this vein, we request that your
staff contact us to arrange a meeting to
E&P Forum
REMOVAL OF OFFSHORE INSTALLATIONS
-
AN INDUSTRY POSITION PAPER
Whilst every ef fort has been made to ensure the accuracy of the
information contained in this publication, neither E ~ P Forum, nor
any of its members will assume liability for any use made thereof.
May 1984
E&P Forum
I N T R O D U C T I O N
Following the completion of the E ~ P Forum questionnaire and the
results of the technical workshop it was clear there was a broad
industry consensus on the technical and cost aspects of platform
removal. This was recorded in the Fosum's paper "The Development
and Promotion of an Industry Position on Platform Removal".
Further consideration of the reasons whereby this technical consensus
could be translated into satisfactory removal standarts/requirements
indicated that two papers were called for:
i) Our Legal Committee advise that the international removal
standard which it envisages will be developed in IMO
should only address the issue of safety of navigation.
This has been reflected in the text of Annex 1.
ii) The other paper, Annex 2, addressing all other relevant
issues should be regarded as a general statement of
objectives to be achieved in discussions with coastal
states and regional authorities.
Hembers may wish to use these papers at thelr discretion when discussing
the matter of platform removal with either national or international
agencies.
May 1384
E&P Forum
ANNEX 1
STANDARDS ON REMOVAL OF OFFSHORE INSTALLATIONS
FOR SAFETY OF NAVIGATION
In order to ensure safety of navigation in the waters of its EEZ and
above its Continental Shelf, each Coastal State in considering removal
of installations and structures (hereinafter called installations) in
such waters upon their abandonment or permanent disuse shall take into
account the following standards:
Any installation shall be removed, in so far as it protrudes above
the seabed, if and to the extent necessary to ensure safety of
navigation in the relevant waters,
provided that no other means are available which are
reasonable in all the circumstances (taking into account inter
alla the risk and cost of removal) to achieve the same without
removing such installation or part thereof
and further provided that, if on the basis of the foregoing
removal is necessary, in water depths of more than 40 metres
measured at lowest astronomical tide such removal shall ensure
an unobstructed water column of at least 40 metres measured as
aforesaid .
2.
3.
Removal shall be performed as soon as reasonably practicable after
abandonment or permanent disuse of such installation.
Removal operations shall be performed in such a way that they cause
no significant adverse effects upon navigation.
4. The above standards do not apply to pipelines.
In addition the Coastal State concerned shall ensure that the position,
depth and dimensions of each installation which has not been wholly
removed after abandonment or permanent disuse is marked on charts
maintained by the appropriate international maritime bodies.
E&P Forum
ANNEX 2
GENERAL REQUIREMENTS ON REMOVAL OF OFFSHORE INSTALLATIONS
In considering removal of installations and structures (hereinaf ter
called installations) in such waters of the EEZ and above the
Continental Shelf upon their abandonment or permanent disuse, the
following shall be taken into account :-
1. In water depths of less than 40 metres any installation shall be
completely removed to the extent it protrudes above the seabed
except in the following circumstances:-
(i) it is manifest that such removal would serve no significant
legitimate interest existing or foreseeable at that time,
including but not limited to the safety of navigation, the
enhancement or protection of the marine environment, the
conduct of fisheries, mining operations or the exercise of
other legitimate uses of the sea, the seabed or subsoil; or
(ii) the adverse effects of non removal are small and the risks and
costs of removal are disproportionate in relation to such
adverse effects, or
(iii) it is proposed that the facility be retained in place for
alternative use.
Any installations in water depths greater than 40 metres shall be
~ cleared of obst N ction to navigation upon cessation of approved
activities in such a way that there is a depth of at least 40
metres of unobstructed water. at lowest astronomical tide (l.a.t.)
above any remaining residues, except in the exceptional
circumstances specified in 1.
The Coastal State shall ensure that such removal operations as are
required shall be performed as soon as reasonably practicable after
abandonment or permanent disuse of such installations.
4. Installations or parts thereof which are removed may be disposed
of in manners which include:-
(i) disposal on site , and
(ii) disposal in areas designated by Coastal States as artificial
reef sites,
provided that there shall, except in the exceptional circumstances
specified in paragraph ~ and 4 (ii), be an unobstructed water column
at lowest astronomical tide (~.a.t.) of at least 40 metres above
anything so disposed and provided further that anything so disposed
may not create a significant risk to the marine environment, or
cause undue conflict with the interests of other users of the sea.
States shall require the owner to ensure that the position and size
of any installations remaining after the removal operation shall be
marked on navigational charts.
6. States shall require the owner to ensure that removal and disposal
operations are executed in such a way that they cause no
significant adverse effects on the marine environment, with due
regard to fishing activities.
7. Compliance with these and any additional requirements imposed by 8
Coastal State shall be a full discharge of all continuing
liabilities and obligations in respect of installations and any
parts thereof.
B. The above does not apply to pipelines.
Mcmbers of E & P Fon~m and their Represen~tives
Member
Arp s.p.~.
AmeTican Pctrolcum Instirute
Amoco Production Compan! Intern~nonal
Arabi~n Amcrican Oil Compan'
Britoil p.1.c.
BP Pctroicum Dcsclopmcnt Limitcd
Burm~h Oi] E>;ploration Limited
Compa~ic Francaisc des Pct~oles (TOTAL)
Chambre Synd~calc dc tz Rccherchc ct dc la
Production du Pctroic et du Gaz blaturc]
Chevron Pcuoicum (UK) Lunitcd
Conoco lnc
D~nsk Borescisk~b A/S
Exxon Corporation
Gulf Arc~ Oi} Companics Murua] Aid
Organ~setion (GAOC~AO)
Gulf Oi] Corporetion
H~sp~nia de Pctroicos S.A.
Insotut Franca~s du Pcnolc
]span National Oi! Corporation
Kuwait Oi] Comp~ny (K.S.C.)
M=athon Oil Company
Mobi! Oi] Corporation
Norsk Industriforcn~ng for
Operatirselskaper (NIFO)
NcderIandsc Olic cn Ges Exploratic en
Produktic Associetic (NOGEPA)
Occidental Pctroleum Corporation
Petrofins S.A.
Pc~olcos dc Vcnezucia S.A.
Phillips Pcuoicum Compan)
Shel] Intcrnationale Pc~oicum
Maatschappi: B.\'.
Socictc Nationalc Elf Aquiraine
Sun Oi] Compans
Ic>;aco ln~crna~ional Pc~rolcum Comp~n
L'~ Offshorc Opcrators Associaric~n
Lim.ted (t'};C)OA)
U irtschafts~ c. band Erdol- und
Erdgas~cu inricng e V. (~ E G )
Countr'
ltals
USA
USA
Saudi Arabia
UK
UK
Francc
France
UK
VSA
Dcnmark
USA
Bahr~in
VSA
Sp3m
Fran cc
]ap"
Kuwait
USA
USA
Norway
Thc Nc~herIands
USA
Beigium
\'cnc~ucia
l''SA
The Netheriands
Prancc
L'S.A
L'S.A
L'L
FRG
