Rigs-to-Reefs

Background

In 1984, Congress passed the National Fishing Enhancement Act which created standards and an outline for a National Artificial Reef Plan, to “promote and facilitate responsible and effective efforts to establish artificial reefs in waters covered under this title.” Under this act, the Bureau of Safety and Environmental Enforcement (BSEE) can permit oil and gas structures scheduled for decommissioning to be transferred from the owning company to the respective state’s Rigs-to-Reefs program, provided certain conditions are met, including any associated wells are capped and abandoned just as they would if they were scrapped on shore. Once the state agencies acquire the appropriate permit from the U.S. Army Corps of Engineers for reefing the structure at a specified location, the states accept the structure and assume liability and maintenance of the structure indefinitely. The oil companies “donate” the rigs but also pay the state agencies a portion of their decommissioning cost savings to assume liability and maintenance of the donated structure.

There are three common methods of converting oil and gas structures into reefs after decommissioning. The tow and place method involves detaching the entire “jacket” or structure on which the deck rests from the sea floor and moving it to an approved artificial reef location. Additionally, the topple and place method detaches the entire structure and lays it on its side. Lastly, the partial removal method is when the “top portion of the structure is severed at a permitted navigational depth, typically 85 feet deep, and placed on the sea floor next to the base of the remaining structure.” The partial removal method typically uses mechanical separation rather than explosives, and studies have found that this method is most successful at maintaining the already established marine habitat and organisms with the least disturbance.

Unfortunately, of the near 7,000 rigs once in the Gulf of Mexico over time, only 1,533 structures, 1,179 of which are oil and gas platforms, remain as of July 2023. Of those, 356 currently have decommissioning applications submitted to BSEE. Only 74 are slated to be donated to a state’s Rigs-to-Reefs program. With many more rigs eligible for decommissioning currently and in the near future, the loss of reef habitat and important fishing destinations in the form of offshore rigs could be accelerated in the next few years.

Points of Interest

• Rigs, whether in production or decommissioned to the Rigs-to-Reefs program, have the potential to function as “steppingstones” between isolated reefs and aid in reef-associated species persistence and resilience.
• While some have argued that artificial reefs, including rigs, simply congregate existing biomass, there is a large body of evidence that these novel hard structures increase carrying capacity and serve as producers of additional biomass locally.
• The additional carrying capacity provided by artificial reef structures is a critical factor in sustaining and supporting key species, particularly reef fishes such as red snapper, vermilion snapper, greater amberjack, almaco jack, and scamp.
• Of 11 species of corals found on rigs in the northern Gulf, 9 are commonly found in the Florida Keys and the Caribbean, and 3 are considered endangered or critically endangered by the IUCN.
• Companies donating structures to the Rigs-to-Reefs program pay the states a portion of the cost savings. States in the Gulf typically receive up to 50% of the projected cost savings. However, California requires a donation of up to 80% of the would-be removal costs, which is likely the reason California has yet to receive a donated platform.
• Because the Rigs-to-Reefs programs’ success is predicated on oil companies saving money, the distance they must tow a structure to a reef zone and the amount that they are required to pay has potential impacts on the number of structures that are donated to the program.
• Alabama: Presently, the state has been granted 1,260 square miles of designated reef permit zones by the U.S. Army Corp of Engineers. Alabama currently has 12 decommissioned oil rigs and jackets serving as artificial reef habitat.
• Florida: The first ever rig conversion to a reef took place in 1979 when a rig was moved from Louisiana to off the coast of Florida, but as of today, Florida only has 3 decommissioned rigs serving as reefs.
• Louisiana: Louisiana currently has the most platforms converted to reefs, with 350 as of 2017. This is directly related to the state’s efforts to coordinate with oil and gas companies to incentivize reefing rather than removal, even in nearshore waters when it would normally be more cost effective for companies to remove the structure but were habitat is particularly beneficial.
• Mississippi: Developed its own artificial reef program in 1972, after the passing of PL 92-402, which authorized the conversion of “liberty ships” into artificial reefs. Since then, the Mississippi artificial reef program has converted 8 decommissioned rigs into reefs.
• Texas: The Texas Rigs-to-Reefs program has converted over 140 donated rigs since beginning in 1990.
• California: The state requires that the oil companies pay as much as 80% of savings costs to the state for the state to assume liability for the structure. As of 2023, there are 23 oil rigs off the coast of California, 8 of which are scheduled to be decommissioned and removed.

Moving Forward

Currently, it can take 2 – 4 years to complete the permitting required for donating a rig to a state’s Rigs-to-Reefs program. As a result, with hundreds of rigs slated for removal in the next few years, there simply is not enough time to convert a majority of these structures to permanent habitat. State policymakers are encouraged to work with their Congressional Delegations to support legislation that will ease regulatory burdens and facilitate the transfer of more offshore oil and gas platforms to state Rigs-to-Reef programs when established reef fish communities are present.