OCS Study 

•

MMS 2001-006 

The Politics, Economics, and Ecology 

of Decommissioning Offshore Oil and 

Gas Structures 

Final Technical Summary 

Final Study Report 

U.S. Department of the Interior 

Minerals Management Service

Pacific OCS Region 

The Politics, Economics, and Ecology 

of Decommissioning Offshore Oil and 

Gas Structures 

Final Technical Summary 

Final Technical Report 

Authors 

Michael Vincent McGinnis 

Linda Fernandez 

Caroline Pomeroy 

Principal Investigators

Associated Authors 

Sam Hitz 

Carla Navarro 

Prepared under MMS Cooperative 

Agreement No. 14-35-0001-30761 

by 

Southern California Educational Initiative 

Marine Science Institute 

University of California 

Santa Barbara, CA 93106 

U.S. Department of the Interior 

Minerals Management Service Camarillo

Pacific OCS Region March 2001
Disclaimer 

This report has been reviewed by the Pacific Outer Continental Shelf Region, Minerals Management 

Service, U.S. Department of the Interior and approved for publication. The opinions, findings, 

conclusions, or recommendations in this report are those of the author, and do not necessarily reflect 

the views and policies of the Minerals Management Service. Mention of trade names or commercial 

products does not constitute an endorsement or recommendation for use. This report has not been 

edited for conformity with Minerals Management Service editorial standards. 

Availability of Report

Extra copies of the report may be obtained from: 

U.S. Dept. of the Interior 

Minerals Management Service 

Pacific OCS Region 

770 Paseo Camarillo 

Camarillo, CA 93010 

phone: 805-389-7621 

A PDF file of this report is available at: 

http://www.coastalresearchcenter.ucsb.edu/SCEI 

Suggested Citation 

The suggested citation for this report is: 

Michael Vincent McGinnis, Linda Fernandez, Caroline Pomeroy. The Politics, Economics, and 

Ecology of Decommissioning Offshore Oil and Gas Structures. MMS OCS Study 2001-006. Coastal 

Research Center, Marine Science Institute, University of California, Santa Barbara, California. MMS 

Cooperative Agreement Number 14-35-0001-30761. 98 pages. 
i 

Table of Contents 

FINAL TECHNICAL SUMMARY ....................................................................... 1 

FINAL TECHNICAL REPORT............................................................................ 7 

Section One: Introduction to the Report.............................................................. 7 

Section Two: The Organic Machines of the Southern California Bight........... 12 

 The Notion of Organic Machines ........................................................................ 14 

 California OCS Oil and Gas Activity.................................................................. 15 

 Undeveloped Leases...................................................................................... 17 

 Decommissioning of California Offshore Oil and Gas Structures................ 18 

 Current Regulatory Requirements ................................................................. 18 

 New Policy Initiatives ................................................................................... 19 

 The Ecology of the Offshore Oil Rigs................................................................. 19 

 Biogeography................................................................................................. 20 

 Transition Zones............................................................................................ 21 

 Changing Oceanographic Conditions............................................................ 21 

 Regime Disturbance in the SCB.................................................................... 22 

 The Relationship Between Regime Disturbance and the 

 Decommissioning Debate........................................................................ 25 

 The Political Ecology of Decommissioning........................................................ 25 

Section Three: Costs and Benefits of Options for California OCS Oil and 

 Gas Platforms............................................................................................... 27 

 Engineering and Planning Costs.......................................................................... 29 

 Permitting and Regulatory Compliance Costs..................................................... 32 

 Platform Preparation Costs.................................................................................. 36 

 Plugging and Abandonment Costs ...................................................................... 37 

 Conductor Severing and Removal Costs............................................................. 37 

 Mobilization/Demobilization Costs .................................................................... 38 

 Platform and Structural Removal Costs .............................................................. 39 

 Topsides Removal ......................................................................................... 39 

 Pile Cutting.................................................................................................... 41 

 Jacket Removal.............................................................................................. 41 

 Costs for Complete Removal .............................................................................. 41 

 Costs for Leave-in-place...................................................................................... 42 

 Costs for Partial Removal.................................................................................... 42 

 Notes about Further Research and Reuse............................................................ 43 

 Pipeline and Power Cable Decommissioning Costs............................................ 44 

 Materials Disposal Costs ..................................................................................... 45 

 Leave-in-Place..................................................................................................... 46 

 Partial Removal Schemes.................................................................................... 46 

 Site Clearance and Verification Costs................................................................. 47 

 Costs of Shell Mounds ........................................................................................ 48 

 Costs of Navigational Aids.................................................................................. 49 

 Onshore Facility Removal Costs ......................................................................... 49 

 Preface to Biology Benefits................................................................................. 49 
ii

 Commercial Fishing Benefits........................................................................ 50 

 Recreational Value ........................................................................................ 51 

 Habitat Value................................................................................................. 51 

Comparing Alternatives ............................................................................................ 57 

Section Four: California’s Artificial Reef Program and the 

 Rig-to-Reef Debate ...................................................................................... 58 

California’s Artificial Reef Program......................................................................... 59 

 The Early Investigative Period: 1958-1965........................................................ 59 

 Program Dormancy: 1965-1980......................................................................... 60 

 Program Renewal: 1980-1992............................................................................ 61 

 Ebb and Flow: 1992-present .............................................................................. 62 

Initial Rig-to-Reef efforts in California..................................................................... 62 

California’s Rig-to-Reef Policy Debate .................................................................... 64 

 The Problem Stream............................................................................................ 64 

 The Policy Stream ............................................................................................... 65 

 The Political Stream............................................................................................ 68 

 The Offshore Oil Industry ............................................................................. 69 

 Commercial Fisheries.................................................................................... 69 

 Environmental and Resource Conservation Interests.................................... 70 

 Federal Agencies ................................................................................................. 70 

 State Natural Resource Agencies ........................................................................ 71 

 Cities and Counties ............................................................................................. 71 

The Window of Opportunity..................................................................................... 71 

Section Five: Setting the Rigs-to-Reefs Policy Agenda: The Case of the 

 Gulf Experience........................................................................................... 73 

The Problem Stream: The Perceived Lack of “Natural” Habitat .............................. 74 

 The Ecology of the Gulf...................................................................................... 74 

 The History of Oil Development......................................................................... 75 

 The Political Ecology of Gulf Oil Development................................................. 77 

The Perceived Problem ............................................................................................. 78 

The Political Stream.................................................................................................. 80 

 Before the Act: Early Artificial Reef Program Development ............................ 80 

 Federal Resource Agencies ................................................................................. 81 

The Policy Stream ..................................................................................................... 82 

 The Role of the Scientific Community................................................................ 82 

 The Move to the Federal Level: Congressional Activity ................................... 84 

The Window of Opportunity: Passage of the National Fisheries Enhancement 

 Act of 1984.................................................................................................... 85 

 Federal Guidance and Assistance........................................................................ 86 

 State Artificial Reef Programs ............................................................................ 86 

Discussion: Unresolved Issues and Concerns .......................................................... 90 

Conclusion................................................................................................................. 91 

References................................................................................................................ 92 
iii

List of Tables 

Table 1. Active Units on Federal Leases off Santa Barbara County ..................... 15 

Table 2. Oil and Gas Production and Projections.................................................. 17 

Table 3. Costs Associated with Decommissioning Options.................................. 28 

Table 4. Platform Specifications. .......................................................................... 31 

Table 5. Platform Deck and Jacket Removal Times and Costs............................. 47 

Table 6. California Artificial Reef Program and Rig-to-Reef Chronology ........... 58 

Table 7. Installation and Removal of Production Platforms on the Federal 

 Outer Continental Shelf........................................................................... 76 

Table 8. Identified Fish Species Associated with Platforms in the Gulf of 

 Mexico OCS............................................................................................ 78 

Table 9. Commercial Landings Summary from 1955-1998.................................. 80 

Table 10. Major Broad-scale and interdisciplinary investigations of the U.S. Gulf 

 of Mexico Conducted Since 1960 by State and Federal Government 

 Agencies .................................................................................................. 83 

List of Figures 

Figure 1. Partial Removal Options ......................................................................... 32 

Figure 2. Factors Contributing to Range of Costs by Category.............................. 33 

Figure 3. Cost Ranges by Category for Leave-in-place Scenario ........................... 54 

Figure 4. Cost Ranges by Category for Complete Removal Scenario.................... 55 

Figure 5. Cost Ranges by Category for Reefing Offsite Scenario .......................... 55 

Figure 6. Cost Ranges by Category for Truncation Scenario ................................. 56 

Figure 7. Cost Ranges by Category for Topple-in-place Scenario.......................... 56 

List of Maps 

Map 1. Map of the Southern California Bight ..................................................... 5 

Map 2. Map of Active Federal Leases in the study area...................................... 6 

Map 3. Location of artificial reefs in Louisiana waters ....................................... 87 

Map 4. Location of artificial reefs in Texas waters ............................................. 88 

Map 5. Location of artificial reefs in Florida waters ........................................... 89 

Map 6. Location of artificial reefs in the Gulf of Mexico ................................... 90 
iv
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

1 

FINAL TECHNICAL SUMMARY 

STUDY TITLE: The Politics, Economics, and Ecology of Decommissioning Offshore Oil 

and Gas Structures

REPORT TITLE: The Politics, Economics, and Ecology of Decommissioning Offshore Oil 

and Gas Structures

CONTRACT NUMBER: 14-35-0001-30761 

SPONSORING OCS REGION: Pacific

APPLICABLE PLANNING AREA: Southern California

FISCAL YEAR(S) OF PROJECT FUNDING: FY99 

COMPLETION DATE OF THE REPORT: March 2001 

COST(S): FY 99 - $115,840, FY 2000 – no cost 

CUMULATIVE PROJECT COST: $115,840 

PROJECT MANAGER: Russell J. Schmitt

AFFILIATION: University of California, Santa Barbara

ADDRESS: Coastal Research Center, Marine Science Institute, University of California, 

Santa Barbara, CA 93106

PRINCIPAL INVESTIGATORS: 1

Micheal Vincent McGinnis, 2Linda Fernandez, 

3

Caroline Pomeroy 

AFFILIATION: 1

Ocean and Coastal Policy Center, University of California, Santa Barbara, 

2

Department of Environmental Sciences, University of California, Riverside, 3Institute for 

Marine Sciences, University of California, Santa Cruz 

ADDRESS: 1

Ocean and Coastal Policy Center, Marine Science Institute, University of 

California, Santa Barbara, California 93106, 2Department of Environmental Sciences, 

University of California, Riverside, California 92521, 3

Institute for Marine Sciences, 

University of California, Santa Cruz, California 95064 

ASSOCIATED AUTHORS: Carla Navarro, Sam Hitz 

RESEARCH ASSISTANT: Doug Reese

KEY WORDS: California Outer Continental Shelf; Marine Ecology; Marine Policy; Rigs-toReefs; Gulf Outer continental shelf; Artificial Reef Program; Oil and Gas Activity; 

Decommissioning; Southern California Bight; Commercial Fishing; Recreational Fishing; 

Garbage Can Model. 

BACKGROUND: California has entered a new era of outer continental shelf (OCS) oil and 

gas activity. The decommissioning of offshore oil and gas facilities is rapidly becoming an 
Final Technical Summary – McGinnis, Fernandez, Pomeroy 

2 

issue of public concern, scientific study, and policy debate. Government, scientists and 

special interest groups have proposed the rigs-to-reefs alternative to complete removal. We 

explore the history, economics, ecology, politics of the rigs-to-reefs option in the Gulf of 

Mexico and California. 

OBJECTIVES: (1) To identify the costs and benefits of various options to decommission 

California OCS oil and gas structure; (2) To describe the history of California's artificial reef 

program; (3) To characterize the political and ecological factors that have contributed to the 

policy debate over rigs-to-reefs as an alternative to complete removal of platforms slated for 

decommissioning; and (4) To characterize the political ecology of Gulf of Mexico’s state rigsto-reefs programs. 

DESCRIPTION: In general, the transition from exploration/development to 

decommissioning of offshore oil and gas facilities marks a fundamental change in the history 

of OCS oil and gas activity. This report describes the political, economic, ecological policyrelated factors that influence the debate over the rigs-to-reefs option to complete removal of 

California OCS oil and gas structures. We use John Kingdon’s “revised garbage can model”

and analytical framework to show that there is a political ecology to decommissioning 

policymaking in the Gulf and California OCS regions. Decommissioning policy (including 

the development of the rigs-to-reefs option) is shaped by the distinct ecological and political 

contexts of the Gulf and California. Section One is a brief introduction to the report. Section 

Two describes the ecological, political and historical context of California OCS oil and gas 

activity. Section Three describes the potential costs and benefits of various options to 

decommissioning of California OCS oil and gas structures. Section Four describes the history 

of California's artificial reef program and the policy debate over a rigs-to-reefs option to 

complete removal in the State Legislature. We also describe the political ecology and policy 

development of Gulf state rigs-to-reefs program. Section Five describes the ecology and 

history of the National Fisheries Enhancement Act of 1984, state artificial reef programs, and 

the adoption of the rigs-to-reef alternative in the Gulf of Mexico OCS Region. 

SIGNIFICANT CONCLUSIONS: We show that state and federal decommissioning 

policymaking is based on economic and ecological factors that reflect particular regional and 

political settings. In the Gulf region, the rigs-to-reefs “idea” was less an invention and more a 

mutation of an old idea. The rigs-to-reefs idea represented the coupling of an already familiar 

activity of building artificial reefs in the Gulf to enhance commercial and recreational 

fisheries. The use of familiar ideas, such as the idea of artificial reef building in the Gulf, by 

policy entrepreneurs and experts is referred to as the “act of recombination”. The rigs-to-reef 

policy idea represented a recombination of an old solution (the reliance on artificial reefs to 

enhance fisheries) to a perceived new problem (the lack of natural habitat and potential 

economic impacts associated with complete removal of OCS oil and gas structures). 

In southern California, the political debate over the decommissioning of oil and gas structures 

involves the intermingling of ecological information, economic factors, preferences and 

interests associated with OCS oil and gas activity. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

3 

The southern California context is much different from that of the Gulf experience. Gulf 

states are willing to accept the rigs-to-reefs alternative, and have developed state policy and 

programs. Gulf state rigs-to-reefs programs continue to serve the needs and interests of 

commercial and sports fishing industries. In California, State Senator Dede Alpert has reintroduced (for a third year in a row) legislation that may lead to the creation of a state rigs-toreefs program under the California Department of Fish and Game. We describe the 

ecological, economic and historical factors that are part of the California rigs-to-reefs debate. 

STUDY RESULTS: In the case of the Gulf, an advocacy coalition that combined the interests 

of the oil industry, recreation and commercial fishing, scientists, and resource managers 

supported the use of offshore rigs as artificial reefs. The development of oil and gas in the 

Gulf OCS led to an increase in commercial and sports fishing activity. Scientific reports and 

workshops spoke to the benefit of artificial reefs in the Gulf. States and local artificial reef 

programs had been established before the passage of the National Fisheries Enhancement Act 

(NFEA) of 1984. In passing the NFEA, the federal government granted discretionary 

authority to states to create their respective rigs to artificial reef program. Many of these 

programs were based on existing artificial reef programs. 

Despite the intent of the National Fisheries Enhancement Act of 1984, which fostered the 

development of Gulf state rigs-to-reefs programs, there remain a number of issues and 

concerns associated with the use of rigs as artificial reefs in California. The major issues and 

concerns that general public, the scientific community and policymakers are facing include the 

following: 

(1) The Liability Issue. Since the publication of the National Artificial Reef Plan, which 

recommended that the US Army Corps of Engineers develop specific permit standards and 

conditions, the issue of liability remains vague and unclear. The Corps has developed a policy 

requiring the permit holder of an artificial reef to prove adequate liability coverage. Gulf 

states with reefing programs have assumed the role of the permittee. This has necessitated a 

close review of the role of the states and localities in implementing the NFEA. Clarification 

of this issue would improve operational procedures and potentially reduce uncertainty about 

exposure on the part of state artificial reef managers. 

(2) Scientific Uncertainty: Production versus Aggregation. Scientists and policymakers 

remain concerned about the production versus aggregation question. It remains unclear if rigs 

attract or produce fishes. Some scientists and policy makers contend that too much emphasis 

has been placed on adult fishery enhancement activity associated with offshore structures, and 

not resources have been spent on restoring essential coastal processes, such as estuarine 

habitats and wetland ecosystems (the “nurseries of the sea”). 

(3) Limited Funding. Since the passage of the NFEA, Gulf state and California artificial reef 

programs have not received adequate funding. State artificial reef programs maintain an 

average staff size of 1 full-time employee. Most funds are generated from either state 

appropriations or Wallop-Breaux funds, which refer to the 1984 Wallop-Breaux Amendment 

to the Federal Aid in Sport Fish Restoration Act (16 U.S.C. sec. 777 (1988)). Oil companies 
Final Technical Summary – McGinnis, Fernandez, Pomeroy 

4 

that “donate” structures are asked to contribute half of the disposal savings realized to the 

Fund. In addition, monitoring of existing artificial reefs and regulatory compliance issues 

remain important concerns of state artificial reef managers. 

STUDY PRODUCTS: This final report is included in the UCSB’s Ocean and Coastal Policy 

Center’s webpage. In addition, the report has been submitted for peer review as a special 

symposium on decommissioning policymaking to the journal Policy Studies Review. 

Michael Vincent McGinnis, Linda Fernandez, Caroline Pomeroy. The Politics, Economics, 

and Ecology of Decommissioning Offshore Oil and Gas Structures. MMS OCS Study 

2001-006. Coastal Research Center, Marine Science Institute, University of California, 

Santa Barbara, California. MMS Cooperative Agreement Number 14-35-0001-30761. 96 

pages. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

5 

Map 1. Map of the Southern California Bight, from Point Conception to the Mexican Border. 

California 
Final Technical Summary – McGinnis, Fernandez, Pomeroy 

6 

Map 2. Map of Active Federal Leases in the study area. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

7 

FINAL STUDY REPORT 

SECTION ONE 

INTRODUCTION TO THE REPORT 

By Michael Vincent McGinnis 

California has entered a new era of outer continental shelf (OCS) oil and gas activity. 

The decommissioning of offshore oil and gas facilities is rapidly becoming an issue of public 

concern, scientific study, and policy debate. This report describes the political, ecological, 

and economics of the decommissioning policymaking. The decommissioning issue is more 

than a matter of the technology-in-use. The politics of decommissioning policymaking is 

influenced by the context of the particular OCS region – the history of oil and gas activity, 

global economics and our reliance on fossil fuels, and marine science (studies of 

oceanography, ecology, biogeography, climate and biology). Decommissioning policymaking 

is influenced by regional ecological, economic and political factors. 

This report addresses three primary questions: 

(1) What are the potential costs and benefits of various options to 

decommission California OCS oil and gas structures? 

(2) What is the history of California's artificial reef program, and how does it 

fit into the current policy debate over rigs-to-reefs as an alternative to 

complete removal of platforms slated for decommissioning? 

(3) What is the policy history of state artificial reef and rigs-to-reefs programs 

in the Gulf of Mexico OCS? 

To address these questions, this report is divided into four sections: 

Section Two describes the ecological, political and historical context of California 

OCS oil and gas activity. In general, the transition from exploration/development to 

decommissioning of offshore oil and gas facilities marks a fundamental change in the history 

of California OCS oil and gas activity. The debate over the rigs-to-reefs option to complete 

removal of OCS oil and gas structures is situated in a particular political and ecological 

setting, which is very different from the Gulf OCS Region. Rather than construction and 

operation of oil and gas facilities (or what one Minerals Management Service employee 

ironically referred to as the development of the “oil and gas ecosystem”), the oil industry is 

mandated by international, federal and state law to completely remove offshore oil and gas 

structures. Currently, a number of representatives from government resource agencies and 

interest groups are proposing the “rigs-to-reef” alternative. We refer to the offshore oil rigs as 

“organic machines” – some oil rigs include tons of biomass. In this sense, the offshore 

structures of the Southern California Bight include organic material. 

Section Three describes the potential costs and benefits of various options to 

decommissioning of California OCS oil and gas structures. Per the recommendation of the 

MMS Pacific OCS Region staff, this section analyzes three decommissioning options: 

"Complete Removal", "Partial Removal" (such as removing the platform from one marine 

location to another) and "Leave-in-Place". We identified variables that are associated with the 

costs and benefits of these three alternatives. We also determined monetary values to quantify 

these costs and benefits, then compared those costs and benefits of each alternative within and 

across categories. 
Final Study Report – McGinnis, Fernandez, Pomeroy 

8 

We found a range of values associated with each alternative, suggesting that they can 

be compared relatively, with low and high bounds of the ranges enabling the ranking of 

alternatives. The range for Partial Removal has an upper bound that makes accounting for 

two sites (original platform site and site where rig is transported to) less attractive than the 

Complete Removal and Leave-in-Place alternatives. The overlap of ranges for Complete 

Removal versus Leave-in-Place means it is more likely that each platform should be 

considered individually in order to derive more specific estimates of costs and benefits to 

weigh alternatives. However, economies of scale from grouping platforms together for 

Complete Removal can be considered by accounting for spreading the costs from the 

engineering and planning, mobilization and demobilization, and platform and structural 

removal across several platforms. 

Since this part of the study is an objective information document, we do not rank 

alternatives. Instead, our results identify the factors associated with decommissioning 

alternatives, especially for platforms standing in varied water depths that often exceed the 

depth of platforms that have been decommissioned in other geographic areas such as the Gulf 

of Mexico. 

One category of interest that is not quantified here is liability. The oil producer retains 

all liability for the platform and wells under each of the decommissioning options.1

 Liability 

for accidents during lease clearance and abandonment is a cost to contend with in terms of 

personal injury, property damage and environmental damages for the Complete Removal 

alternative. Platforms can become top-heavy from biofouling growth that supports fisheries 

habitat. For both the Partial Removal and Leave-in-Place alternatives, liability for any 

recreational or fishing accident that might occur constitutes an additional cost. The liability 

issue remains a concern in California decommissioning policymaking. This lingering liability 

suggests that platform operators need to reserve financial resources to cover these potential 

costs. 

Sections Four and Five employ the model developed by John Kingdon in his book, 

Agendas, Alternatives and Public Policy (1995). Kingdon provides a useful framework to 

characterize the policy developments. He uses a revised version of a classic essay by CohenMarch-Olsen (1972) on the “garbage can model of organizational choice“ to explain the 

politics of agenda setting and policy generation. 

 Kingdon (1995) describes the policy making process as chaotic and turbulent. Public 

choices are not always based on scientific understanding. This type of political process 

operates on the basis of “trial and error”, “learning from accidents of past experiences, “ or on 

the basis of “inventions of necessity” (Cohen, March and Olsen 1972: 1). Choices are based 

on a variety of “inconsistent and ill-defined preferences”, according to Cohen, March and 

Olsen (1972: 1-2), “To understand processes ... one can view a choice opportunity as in a 

garbage can into which various kinds of problems and solutions are dumped by participants as 

they are generated.” 

 Ideas are generated by policy “entrepreneurs”, specialists, techno-experts in 

government, industry or non-government organization. Kingdon (1995) and other social 

scientists (such as Anton 1989 among others) describe the policy entrepreneur as an advocate 

who plays the fundamental role in “opening” a policy window by offering a solution to a 

 

1

 In the Gulf of Mexico, liability is transferred to the state at the point the structure is accepted by the state as an 

artificial reef, under the state’s respective artificial reef programs (See Section Four of this report). The oil 

structure is transferred to the state (or, in some cases, another public entity) after the state has obtained a Corps of 

Engineers permit for an artificial reef development. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

9 

perceived problem. These solutions are not only based on some level of scientific information 

but perceptions and values as well. This process of exchange of information, partisan mutual 

adjustment, and communication is dynamic and fluid. Political elites and other participants in 

the process can act as policy entrepreneurs. 

 The specialist, technocrat, bureaucrat, policy elite, and expert play the role of policy 

entrepreneur. “Many ideas are possible in principle,” notes Kingdon (1995: 19), “and float 

around in a primeval soup in which specialists try out their ideas in a variety of ways – bill 

introductions, speeches, testimony, papers and conversation.” The policy entrepreneur 

identifies the problem and offers solutions. Without the entrepreneur, the idea will remain 

floating in the “primeval soup”. Experts, specialists, and policy elites couple solutions to 

problems and couple “problems and solutions to politics” (Kingdon 1995: 20). 

The capability of the entrepreneur to open “policy windows” and set government 

agendas depends on three separate, but interrelated, processes: 

• Problems: the set of issues in particular public policy areas that come to capture 

the attention of those in and around government at any one time; 

• Policy articulation: a process involving gradual accumulation of knowledge and 

perspectives among specialists in a policy area, and the resulting generation of policy 

proposals by those specialists; 

• Politics: trends and events in the overall political environments, such as interest 

group campaigns and administrative changes. 

Kingdon metaphorically refers to these processes as separate “streams” -- the political, 

problem and policy stream.2 Policy change can occur when the streams join to form a “policy 

window of opportunity”. The window opens when the political climate is ripe for policy 

change, when a problem is recognized by political elites, and when a solution is successfully 

developed and proposed by policy “entrepreneurs”. 

 We use Kingdon’s model and framework to show that there is a political ecology to 

decommissioning policymaking in the Gulf OCS and California OCS. Decommissioning 

policy (including the development of the rigs-to-reefs option) is shaped by the distinct 

ecological and political contexts of the Gulf and California. The next section turns to an 

analysis of the costs and benefits of California OCS decommissioning options. 

Section Four describes the history of California's artificial reef program and the policy 

debate over a rigs-to-reefs option to complete removal in the State Legislature. Although the 

California Department of Fish and Game (CDFG) began a program of artificial reef research 

and development in 1958, legislation providing for the formal establishment of the program 

and allocation of (limited) personnel and financial resources did not occur until 1985. CDFG 

initiated its program of artificial reef development in the late 1950s in the interest of 

enhancing nearshore sport fishing opportunities in southern California. Using donated 

 

2

 Kingdon’s model is based on the earlier work of Michael Cohen, James March and Johan Olsen, “A Garbage 

Can Model of Organizational Choice, “ Administrative Science Quarterly 17 (March 1972): 1-25. Cohen et al. 

argue that “...organizations can be viewed for some purposes as collections of choices looking for problems, 

issues and feelings looking for decision situations in which they might be aired, solutions looking for issues to 

which they might be an answer, and decision makers looking for work.” The Cohen et al. “garbage can model” is 

the foundation for Kingdon’s framework to study agenda setting. For a critique of the “garbage can model” see 

Gary Mucciaroni, “The Garbage Can Model and the Study of Policy Making: A Critique,” Polity, Vol. 24, 3 

(Spring 1992): 459-482. 
Final Study Report – McGinnis, Fernandez, Pomeroy 

10

materials (due to a lack of funding), the Department oversaw the construction of several 

artificial reefs (such as at Paradise Cove in Northern Santa Monica Bay and Redondo Beach). 

CDFG biologists used these reefs to test the effectiveness of such structures in attracting fish; 

the study showed aggregation of fishes at both “reef” sites. This success led to a program to 

investigate the cost-effectiveness and practicality of different reef materials using a series of 

"replication reefs” in Santa Monica Bay. These studies determined that quarry rock was the 

most effective material (Lewis and McKee 1989:3). 

From the late 1960s through 1980, little systematic study was done on these or newly 

placed reefs. In 1980, however, CDFG began a major program of artificial reef construction 

and research in connection with Southern California Edison's required mitigation for the 

negative impacts of warm water discharge on coastal kelp beds. That mitigation plan included 

a 6-year cooperative project with CDFG for the construction of Pendleton Artificial Reef (in 

northern San Diego County) and studies to evaluate the reef's potential for enhancing marine 

resources (Lewis and McKee 1989:3). Although it was clear that the reefs attracted fish, there 

were concerns this could lead to increased local fishing pressure and resultant negative effects 

on populations. Next, the program turned to an emphasis on designs that would promote 

production (by augmenting shelter and forage), as well as attraction. Research has shown that 

high relief, open structures serve best to attract fish, and better enable fishery exploitation, 

while low relief, complex structured reefs provide better nurseries and afford more diverse 

assemblages of fish and other organisms. An anonymous CDFG biologist noted, a drawback 

to rigs as reefs is that they are high relief, which works against survival of young-of-the-year 

fish, suggesting they may not be a source of production but rather simply an attraction site. 

Artificial reef construction thus became one aspect of CDFG's Nearshore Sportfish 

Habitat Enhancement Program for restoring or enhancing sportfish habitat along the southern 

California coastline (Lewis and McKee 1989:1). The program's objective is to maintain 

sportfishing success in the face of the effects of increasing fishing pressure as well as 

negative impacts on the nearshore ecosystem (Lewis and McKee 1989:1). It is supported, in 

part, by Dingell-Johnson/Wallop-Breaux Federal Aid in Sport Fish Restoration Act Funds. 

Although CDFG is charged with managing the state's artificial reefs and the program, 

several other agencies play a role in the pre-construction permitting process. Siting artificial 

reefs in California waters requires a (federal) permit from the U.S. Army Corp of Engineers 

(under Public Law 98-623. Title II); a coastal development permit from the California Coastal 

Commission (CCC); and a lease from the State Lands Commission (SLC) for activity on 

submerged state lands. In waters outside the three-mile state jurisdiction, an SLC permit is 

not required, but the CCC must issue a consistency finding before the Corps of Engineers will 

issue a permit. Other agencies that may be involved in the process include the U.S. Coast 

Guard (for navigation) and the MMS (when the proposed project involves an oil and gas 

structure). Any decision will require an environmental analysis performed by the lead agency. 

At present, there are some 35 artificial reefs consisting of hundreds of modules off the 

coast of California. In general, administrative resources to support monitoring these sites and 

the CDFG's program are quite limited. Three CDFG personnel are assigned to the program 

part-time. There are no funds available for building new reefs, so materials for any new 

construction come from demolition projects or other donations. The CDFG maintains a keen 

interest, however, in building several large reefs. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

11

Meanwhile, CDFG periodically monitors and continues to augment two artificial reefs 

outside of state waters. These reefs were permitted prior to any public discussion about 

CDFG's role in a rigs-to-reefs program. When CDFG lawyers started looking at rigs-to-reefs, 

they informed CDFG personnel that they have no legal standing beyond California state 

waters, with the exception of the two above-mentioned reefs. 

In 2000, for a second year in a row, Senate Bill (SB) 241 failed to come to a vote in 

the California Legislature. SB 241 would have created a voluntary program whereby platform 

operators would yield to a portion of cost savings from partially removing or leaving a 

platform in place to support fisheries mitigation projects. SB 241 would not release operators 

from liability, but has provisions that essentially limit or constrain liability. The issue of 

liability could reduce the incentives for platform operators to pursue the rigs-to-reefs option. 

Section Five describes the political ecology and history of the National Fisheries 

Enhancement Act of 1984 (NFEA), state artificial reef programs, and the adoption of the rigsto-reef option in the Gulf of Mexico OCS Region. The section also uses the conceptual 

framework developed by Kingdon (1995). 

The NFEA includes the following: 1) the recognition of social and economic values in 

developing artificial reefs, 2) establishment of national standards for artificial reef 

development, 3) calls for creation of a National Artificial Reef Plan under leadership of the 

Department of Commerce, and 4) establishment of a reef-permitting systems under the US 

Army Corps of Engineers that limits the liability of participants in the program. The law 

strongly encourages the development of artificial reefs but authorizes no direct appropriations 

for administration, planning, construction, enforcement, monitoring, or research on artificial 

reefs. 

The NFEA was enabling legislation that allowed Gulf states to develop and implement 

rigs-to-reefs programs. State programs have been developed out of existing artificial reef 

programs and the NFEA with scarce resources and little administrative support (Murray 

1994). 

Soon after the MMS established an artificial reef policy that encourages the conversion 

of selected obsolete oil and gas structures to artificial reefs on the OCS with the particular 

focus on the value of fishery enhancement. The Gulf states and the federal government took a 

keen interest in developing rigs-to-reefs programs because of the economic values associated 

with recreational and commercial fisheries near rigs. In June 1986, Louisiana enacted 

legislation (Act 100--The Louisiana Fishing Enhancement Act) authorizing a state-directed 

rigs-to-reefs program. The program is administered by the Louisiana Department of Wildlife 

and Fisheries and conducted jointly with staff from Louisiana State University. Texas has a 

rigs-to-reefs program. There are more than 150 permitted artificial reefs off Florida, 

Alabama, Mississippi, and Texas. 

Several artificial reef policy-related issues remain vague and unclear. Based on the 

findings of Murray (1994), this section concludes with a brief discussion of the problematic 

nature of the liability issue, the scientific dispute and debate over attraction versus production, 

and the concern over artificial reef administration and funding. These issues and concerns 

should be resolved if states are going to effectively and responsibly develop and implement 

artificial (and rigs-to-reefs) programs. 
Final Study Report – McGinnis, Fernandez, Pomeroy 

12

SECTION TWO 

THE ORGANIC MACHINES OF THE SOUTHERN CALIFORNIA BIGHT 

by Michael Vincent McGinnis 

This section describes the political ecology of decommissioning of California OCS oil 

and gas rigs. In general, the transition from exploration/development to decommissioning of 

OCS oil and gas facilities marks a fundamental change in the history of California OCS oil 

and gas activity. The debate over the rigs-to-reefs alternative to complete removal is shaped 

by political, ecological, ethical and economic considerations. California OCS oil and gas 

structures should be thought of as “organic machines”.

3

 An organic machine is a metaphor for 

the combination of organic (living) material and machinery.4

There are currently 27 offshore platforms in southern California. The focus of this 

section is on those offshore platforms in the Santa Barbara Channel. Many of these 

mechanical structures have nearly reached the end of their economic production. Some of 

these mechanical structures are the size of the Empire State Building, and include some 

75,000 tons of metal, concrete and wood. These structures also exist in a complex and 

dynamic ecological context that is shaped by biology, oceanography and climate-related 

factors (McGinnis 2000). 

Because of the ambiguous relationship between marine life and offshore structures, a 

political and scientific debate over the rigs-to-reefs option to complete removal of offshore oil 

and gas structures is inescapable. There are potential ecological, economic, and political 

consequences to decommissioning. The National Research Council (NRC 1985) estimates 

that the cumulative costs for removal of all platforms in the OCS could total $2.9 billion by 

2005 and $9.9 billion by 2020. The Governmental Account Office (GAO 1994) reviewed 

offshore structure removal operations and concluded that we need to better understand the risk 

of ecosystem damage posed by certain decommissioning practices, such as the use of 

explosives as a removal technique. 

There are a number of important ecological and economic factors that are influencing 

the debate (McGinnis 1998). The question of costs and benefits associated with 

decommissioning options is the focus of Section Three. Rock fish represent $3 billion in 

sports fishing values and between $200 to 300 million annually in commercial landings. 

Preliminary evidence from Love (1997) and Love et al. (1999) show that between 90 to 95% 

of fish near rigs are rock fish. Populations of rockfish off southern California -- an area within 

the Southern California Bight that includes about 70 species of fish harvested by both 

recreational and commercial fisherman -- have dropped to 8% of their 1960 populations 

(Love, Caselle and Van Buskirk 1998; Love et al. in press). The significant decline of several 

rock fish species is not only a sign of the current low-nutrient regime (which began in 1977) 

but also a sign that rock fish have been over-fished by recreational and commercial fishers 

(Love, personal correspondence 2001). Field studies show that some rigs in the Santa Barbara 

Channel include juvenile Bocaccio, which may be listed as a threatened species in accordance 

 

3

 We agree with Kristin Shrader-Frechette and Mike McCoy (1994) who argue that the science of ecology 

includes categorical values. Our general use of the term “ecology”, therefore, implies both science and 

sensibility. 

4

 Drs. Jenny Dugan, Mark Page and others are currently investigating the biomass associated with some offshore 

oil rigs. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

13

to the U.S. Endangered Species Act (Pacific Marine Conservation Council 1999).5 There is 

also evidence that suggests that the largest Bocaccio exist near the bottom of offshore rigs. 

There is currently a political debate over the future of California offshore oil rigs. The 

political debate is shaped by the ecological setting of the Southern California Bight, the 

economics of platform removal, and the uncertainty over the potential “fishery-related values”

that may be associated with particular rigs in the Santa Barbara Channel. The debate is “transscientific”; it involves the intermingling of values and scientific information.6

 There is no 

easy answer or policy-related resolution to the debate over the future of California offshore oil 

rigs. Nevertheless, given the ecology of the Southern California Bight, the recent Scientific 

Advisory Committee on Decommissioning from the University of California (Holbrook, 

Ambrose, Botsford, Carr, Raimondi, and Tegner 2000: 3-5) wrote: 

There is not any sound scientific evidence (that the Committee is aware of) to 

support the idea that platforms enhance (or reduce) regional stocks of marine 

species. The primary reason for this conclusion is that the 27 platforms 

represent a tiny fraction of the available hard substrate in the Southern 

California Bight, so their contribution to stocks of most reef organisms is likely 

to be small relative to the contribution from natural reefs ... The Committee 

found that the possible regional effects on a stock of habitat removal are much 

harder to assess than the short-term ecological impacts localized at the site of 

the platform because most marine species are composed of a series of local 

populations that are connected via larval dispersal of young stages. Thus, 

populations are interdependent, and impacts at any one location (a reef or 

platform) must be viewed in the context of the regional set of local 

populations. Regional effects cannot be projected at present because we do not 

fully understand how local populations are connected (such as we know that 

larvae are transported and older individuals move between various reefs, 

artificial reefs and oil platforms, but we do not understand specific links among 

local populations) nor do we know the degree to which populations on artificial 

structures are self-sustaining ... 

 

5

 In February 2001, the Center for Marine Conservation, the National Resources Defense Council and the Center 

for Biodiversity sued the National Marine Fisheries Service for failing to list the Bocaccio as a threatened species 

in accordance to the U.S. Endangered Species Act. The abundance of Bocaccio is less than 5% of their historical 

population in the northern Channel Islands. The Bocaccio is one species among several species of rockfish that 

are showing serious signs of decline in abundance and distribution in the Bight (Love, et al. 2001). 6

 Marine managers and planners cannot depend on scientific information to resolve the debate over the merits of 

the rigs-to-reefs alternative for the following general reasons: 1) There exists a mismatch between scales of 

atmospheric and oceanographic processes and the spatial and temporal dimensions of biological studies and 

research (such as McGowan, et al. 1998). As McGowan, et al. (1998: 210) write in their published article in 

Science, “Much of the biological, observational evidence is disconnected spatially and often discontinuous 

temporally ... we must accept less than ideal data in our attempt to understand what is happening”; 2) Marine 

science has yet to link information on oceanographic regimes with information on habitat distribution and marine 

biodiversity. Studies do not show how larger-scale conditions affect the general health of the local populations 

and marine habitats; and 3) There are few long-term and interdisciplinary studies of marine ecosystems. Marine 

scientists tend to focus on the distribution and abundance of marine species and habitats. In summary, we know 

very little about the function, processes and structures of marine systems (Costanza et al. 1998; NRC 1999 

among others). 
Final Study Report – McGinnis, Fernandez, Pomeroy 

14

Thus, in light of the strong evidence of the benefit and the relatively small 

contribution of platforms to reef habitat in the region, evaluation of 

decommissioning alternatives in our opinion should not be based on the 

assumption that platforms currently enhance marine resources [emphasis 

added]. 

Over 70% of the natural rocky reef habitat of the Southern California Bight exists 

around the Channel Islands (Dailey, et al. 1993). Given the ecology of the Southern 

California Bight and the presence of natural rocky reef habitats, the Committee proposes that 

the ecological benefits associated with artificial habitats around offshore platforms may not 

warrant a rigs-to-reefs alternative to complete removal.7 In many respects, the ecology of the 

Bight is shaping the politics over decommissioning policymaking. 

The politics of California decommissioning policy includes such issues as the question 

of “attraction versus production”, liability considerations, and funding to administer a 

potential California rigs-to-reefs program. These issues are described further in Section Four 

by Carrie Pomeroy. The political and ecological setting of California OCS oil and gas activity 

is shaping the debate over how to deal with the organic machines of the Bight. 

The Notion of Organic Machines 

In The Organic Machine, Richard White (1995) describes the relationship between 

human beings and hydropower development of the Columbia River. According to White 

(1995), the river has been transformed into an organic machine that can literally be turned on 

or off, like a house faucet. The “river” also includes several species of endangered and 

threatened plants and animals. In this sense, the organic machine combines both natural and 

artificial or mechanical components. Since the 1930s, White (1995) shows that hydropower 

development has denatured the once wild, free-flowing river into an organic machine. 

 White’s notion of the organic machine is a useful metaphor to describe the relationship 

between marine ecology (oceanography, biogeography and climate-related factors of the SCB) 

and OCS oil and gas activity. For some, the first mechanical act is the denaturing of nature, 

such as the threats posed by industrial development to species diversity (McGinnis 1999). For 

others, the machine has become “natural habitat” worthy of further study or protection as 

refuge (UCLA 1999; Alpert 1999). 

 Recent evidence in the decline of several marine species during the warm water 

regime, such as rock fishes, has led to arguments in favor of the rigs-to-reefs alternative to 

complete removal. Some advocates of the rigs-to-reefs alternative turn to the Gulf region as 

an example. But the political ecology of the Gulf of Mexico, which is briefly described in 

Section Five, is very different from the political ecology of the Bight. The significant level of 

offshore oil and gas development in the Gulf has led to a dependence of offshore structures as 

recreational and commercial fishing areas. Historically, the level of public support for oil and 

gas development has been accepted by local communities and states of the Gulf while 

residents of southern California have attempted to “get oil out” . To protect fishing interests, 

commercial and recreational fishing groups, state and federal resource agencies in the Gulf 

lobbied for a federal law to allow a rigs-to-reefs alternative to complete removal of offshore 

structures. States like Alabama do not have natural hard bottom habitat and now depend on 

artificial reefs to create fisheries, such as red snapper. This is not the case in southern 

California. There is a limited amount of natural marine habitat in the Gulf of Mexico. This is 

 

7

 The Committee’s report is supported by Love, et al. (2001), The Ecological Role of Natural Reefs and Oil and 

Gas Production Platforms in Rocky Reef Fishes in Southern California 1998-1999 Survey Report. US 

Department of the Interior. US Geological Survey. Biological Resources Division. Minerals Management 

Service. Pacific OCS Region. OCS Study MMS 2001-028. March. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

15

not the case in the Bight. In short, the political ecology that is associated with each region 

often shapes the politics of how to treat the organic machines of the Gulf of Mexico and the 

Bight. 

California OCS Oil and Gas Activity 

 A comprehensive survey of the early history of oil and gas development in Santa 

Barbara County is found in Lima (1994). Industrial histories for the region can also be found 

in the work of Molotch and colleagues (MMS 1998a, b, c). 

 Offshore oil and gas development has occurred in leased tracts in California waters 

(hereafter referred to as State waters) from the mean high tide line to 3 miles offshore, and 

Federal waters (from 3 to 200 miles offshore). 

 There is six offshore oil structures in California waters. These structures were 

installed prior to the passage of the National Environmental Policy Act of 1969 and the 

California Coast Act of 1972. 

 The MMS issues leases for natural gas and oil exploration in Federal waters off 

California. The only leases remaining are off southern California. These include 79 leases 

offshore San Luis Obispo, Santa Barbara and Ventura Counties. In 1999, forty-three of these 

leases are producing a total of 125,000 barrels per day of oil and over 215,000 cubic feet of 

gas per day. 

 There are currently 27 platforms in the Bight and approximately 200 miles of 

associated pipelines. The field, platform, installation date (year), and depth of the platform of 

oil and gas activity are found in Table 1. Both the installation date and platform depth should 

be recognized as important factors related to decommissioning. For example, 

decommissioning costs vary by water depth (MMS 1999). As noted in Table 1 a few of the 

offshore structures are over 1,000 feet deep. 

Table 1. Active Units on Federal Leases off Santa Barbara County.

Field Platform(s) Installation Platform Depth 

Date (meters/feet) 

Hueneme Gina 1980 29/95 

Santa Clara Gilda 1981 62/205 

 Grace 1979 96/318 

Dos Cuadras Hillhouse 1969 58/190 

 A 1968 58/190 

 B 1968 58/190 

 C 1977 58/190 

Carpinteria Henry 1979 52/174 

 Hogan 1967 47/154 

 Houchin 1968 49/163 

Sockeye Gail 1987 224/739 

Pitas Point Habitat 1981 88/290 

South Ellwood* Holly 1966 66/211 

Hondo Hondo 1976 255/842 

 Harmony 1989 363/1,200 

Pescado Heritage 1989 326/1,075 

Point Arguello Hermosa 1985 184/603 

 Harvest 1985 205/675 

 Hidalgo 1986 130/430 

Point Pedernales Irene 1985 73/242 

Based on information from California Offshore Oil and Gas Energy Resources Baseline Conditions & Future 

Development Scenarios (1999): 2-16 – 2-44 and California Coastal Commission (1999). Note, there are 

additional platforms at various depths off Orange County, including Edith (49m), Elly (80m), Ellen (80m), and 

Eureka (212m) in Federal waters, and Emy, Eva and Esther in State waters. 

* oil and gas development on California State Leases. 
Final Study Report – McGinnis, Fernandez, Pomeroy 

16

A brief characterization of each developed field offshore Santa Barbara County follows. 

• The Hueneme Field is located in the eastern Santa Barbara Basin approximately four miles 

southwest of Port Hueneme. The field is produced from Platform Gina, which is located 

approximately 6 miles from shore. This field is in a mature stage of development and 

production is declining. 

• The Santa Clara Field is located in the eastern Santa Barbara Basin approximately 7 miles 

west of Oxnard. The field is produced from Platforms Gilda and Grace. Gilda is located 

approximately 10 miles from shore. Grace is located in the eastern Santa Barbara Basin, 

and is located approximately 10 miles north of Anacapa Island. As of August 1998, the 

Minerals Management Service (MMS) indicates that the operator has shut in or plugged 

and abandoned all the production wells at Platform Grace. The Santa Clara Field is in a 

mature development stage with total production declining. 

• The majority of the West Montalvo Field is located onshore. The field extends offshore 

into the California State submerged lands. The field is produced from onshore wells, 

some of which are directionally drilled under the ocean. There are no platforms or drilling 

islands used to produce these offshore reserves, and the onshore wells produce from State 

leases. 

• The Rincon Field is located in State waters. Eight onshore wells and an artificial island 

are used to produce from State leases. The current owner is evaluating methods to 

increase production of this field. 

• The Dos Cuadros Field is located in the eastern Santa Barbara Basin, approximately 6 

miles southwest of Carpinteria. The field is produced from four platforms including 

Platform Hillhouse, Platforms A, B, and C. All platforms are located 6 miles from shore. 

The field has reached a mature stage and most wells exhibit a decline in production. 

• The Carpinteria Field is located in the eastern Santa Barbara Basin, approximately 4 miles 

south of Carpinteria. The field is developed from both State and Federal leases. The State 

leases were produced by Platforms Hope and Heidi. These two platforms were removed 

in early 1996. Federal leases are produced from Platforms Hogan, Houchin, and Henry. 

This field is a mature and in an advanced stage of depletion. 

• The Sockeye Field is produced from Platform Gail, approximately 11 miles west of Port 

Hueneme. This field has reached a mature development stage. 

• The Pitas Point Field is produced from Platform Habitat, approximately 8 miles from 

shore. The field is in decline and has a limited future productive life. 

• The South Ellwood Field is located in State waters near Goleta, and is produced from 

Platform Holly, approximately 2 miles from shore. There is indication that this field is 

also in a mature level of development. 

• The Hondo Field is produced from Platforms Hondo and Harmony in Federal waters, 

approximately 6 miles from shore. 

• The Pescado Field is produced from Platform Heritage, approximately 8 miles from 

Gaviota. 

• The Point Arguello Field is located in the southern part of the Santa Maria Basin, 

approximately 6 miles from shore. Platforms Hermosa, Harvest and Hidalgo are used to 

produce the field’s oil. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

17

• The Point Pedernales Field is located in the southern Santa Maria Basin, approximately 6 

miles west of Point Pedernales. The field is produced from Platform Irene. 

The total production and future projection of oil and gas production for the period 1995 to 

the end of 2015 is found in Table 2. California OCS oil and gas production is expected to 

decline by the year 2015. 

Table 2. Oil and Gas Production and Projections.

 Year Oil (MMSTB) Gas(BCF) 

 1995 73.99 57.69 

 2000 48.65 83.15 

 2015 4.38 35.00 

Source: California Offshore Oil and Gas Energy Resources Baseline Conditions & Future Development 

Scenarios. January 30, 1999. 

MMSTB = million stock tank barrels 

BCF = billion cubic feet 

Undeveloped Leases 

 Commencing in the 1920s, the California State Legislature placed most of the 

California coast off limits to oil and gas leasing and development through a variety of oil and 

gas “sanctuary” statutes. However, large areas of the coast and submerged lands (0 to 3 miles 

offshore) remained unprotected. By 1989, the State Lands Commission filed in the remaining 

gaps in California “sanctuary statutes” and administratively foreclosed the possibility of new 

oil and gas leasing in State coastal waters, with few exceptions. This administrative sanctuary 

was later incorporated by the legislature in its comprehensive ban on new oil and gas leasing, 

through the California Coastal Sanctuary Act of 1994 (California Coastal Commission 1999). 

Pursuant to this California statute, all state coastal waters, except those under lease on January 

1, 1995, are permanently protected from development. 

 Except for the limited geographic area of waters within the National Marine 

Sanctuaries, no portion of the federal Outer continental shelf (OCS) has a permanent 

moratorium on oil and gas leasing and development (California Coastal Commission 1999).8

 

A temporary moratoria have been in place since 1982 (California Coastal Commission 1999). 

In addition to Congressional moratoria, the Bush and Clinton administrations issued directives 

under the OCS Lands Act to restrict leasing of new offshore areas. In 1990, President Bush 

directed that all areas protected by Congressional moratoria be deferred for leasing 

consideration until after the year 2002. This deferral included the federal OCS offshore of 

California. In June 1998, President Clinton also issued a directive under the OCS Lands Act 

that prevents the leasing of any area currently under moratorium for oil and gas exploration 

and development prior to June 30, 2012. These OCS “presidential deferrals” can be reversed 

by subsequent administrations. 

 The existing Congressional moratoria and presidential leasing deferrals do not restrict 

development of already federally leased areas. Thirty-six federal leases remain in a “nonproducing” status. These 36 leases were leased between 1968 and 1984. These 36 tracts are 

 

8

 There is also the Federal Ecological Preserve and Buffer Zone offshore Santa Barbara County. 
Final Study Report – McGinnis, Fernandez, Pomeroy 

18

in the Santa Barbara Channel or the Santa Maria Basin. This means that there are several 

undeveloped leases that are not producing natural gas and/or oil, although some of these 

leases have been explored. 

 A few new platforms may be needed to develop the following federal leases 

(California Coastal Commission 1999: 23): Santa Maria, Purisma Point, and Point Sal. The 

MMS has granted a series of lease suspensions or extensions upon lessees’ requests or 

directed suspension by the MMS Regional Director. When MMS receives a request for 

suspension, its options are to either approve or deny the request based upon the criteria in the 

MMS regulations. The future of these undeveloped leases is currently the subject of debate 

between policy makers. For a comprehensive review and summary of this issue, see 

California Coastal Commission (1999), California Offshore Oil and Gas Leasing and 

Development Status Report. 

Decommissioning of California Offshore Oil and Gas Structures 

 Early development of onshore oil and gas wells in San Luis Obispo, Santa Barbara and 

Ventura Counties was not accompanied by adequate policies or techniques for abandonment 

or decommissioning of these onshore oil and gas structures (Muller 1997). Some of these 

wells pose health and environmental risks, remain a major source of oil seepage, and are 

recreational hazards (County of Santa Barbara Planning and Development Department, 

undated). 

 California OCS oil and gas production has occurred since the mid-1960s (Lima 1994). 

Advances in modern technology fostered the development of OCS oil and gas reserves (Lima 

1994). These oil platforms have a finite economic lifespan; several platforms are nearing the 

end of the economic operation. Most of California OCS oil and gas platforms and structures 

will need to be decommissioned within the next 15 years. 

 To date, only seven relatively small structures have been decommissioned; all were 

located in State waters. The most recent project occurred in 1996 when Chevron removed 

Platforms Hope, Heidi, Hilda and Hazel. These platforms were in water depths ranging from 

100 to 140 feet. One hundred and thirty-four wells were plugged and abandoned on these 

platforms. In order to remove the rigs to be brought ashore for recycling and disposal, 

explosives and heavy machinery were used to tear the rigs from their foundations. The 

biomass that accumulated around these OCS oil and gas structures was destroyed during the 

decommissioning activity (MMS 1998d). 

Current Regulatory Requirements 

 As of May 2000, international, federal and California law requires the complete 

removal of offshore oil and gas structures. A comprehensive review of the regulatory 

requirements is found in Minerals Management Service (1998d), California Coastal 

Commission (1999) and Santa Barbara County Energy Division (2000). As a brief overview, 

the regulatory compliance requirements are as follows: 

• US Minerals Management Service: Federal regulation (30 CFR 250) requires 

the plugging and abandonment of wells; full removal of well conductors and 

platform jackets to 15 feet below the mudline; decommissioning and full 

removal of platform decks; decommissioning and removal of pipelines and 

power cables as appropriate; and site clearance. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

19

• California Department of Conservation, Division of Oil, Gas and Geothermal 

Resources: The basic plugging requirements are found in the California Code 

of Regulations Title 14 Division 2, Chapter 4, Section 1745. 

• California State Lands Commission: The basic plugging requirements are 

found in the California Code of Regulations Title 2 Section 2128(q). 

 There are also lease and permit requirements that must be met during 

decommissioning of offshore oil and gas structures. Provisions of federal and state oil leases 

and MMS regulations can be changed by the state and federal government to allow the federal 

government to consider and approve methods of rig decommissioning other than complete 

removal, as evidenced in the Gulf of Mexico. With respect to California, Carolita Kallaur 

(Kallaur 1998: 10), the Associate Director for Offshore Minerals Management with the U.S. 

Department of the Interior, MMS writes, “MMS does not have a position one way or the other 

as to the rigs-to-reefs program here in California. We believe that is an issue that falls 

primarily within the regulatory jurisdiction of the California Department of Fish and Game, 

Army Corps of Engineers, and the California Coastal Commission.” California’s Department 

of Fish and Game (CDFG), the agency with oversight over the state’s artificial reef program, 

has policy guidelines in place for artificial reefs with a preference for those structures that 

provide “good” habitat. 

New Policy Initiatives 

Legislation introduced in the California legislature by Dede Alpert for a third 

consecutive year seeks to incorporate the provisions of the federal National Fisheries 

Enhancement Act of 1984 (33 U.S.C. Sec. 2101 et seq.). The National Artificial Reef Plan, 

developed pursuant to the National Fisheries Enhancement Act of 1984, identifies oil and gas 

structures as materials for development of offshore artificial reefs. 

There is approximately 4000 OCS oil and gas platforms in the Gulf of Mexico. 

Approximately 100 platforms per year are decommissioned in the Gulf. Some of these 

platforms, in accordance to the Act and existing state artificial reef programs, are used as 

artificial reefs. Louisiana has established reef zones, such that platforms are completely 

removed, the sites “restored”, and platform components are deposited at a designated reef 

zone and enhanced with habitat-forming materials. In some instances in the Gulf, platforms 

are toppled in place if all government and non-government parties agree. The Gulf States 

(primarily Louisiana and Texas) assume full liability for the artificial reefs. It is important to 

note that the culture and socioeconomic characteristics of Gulf States and the biophysical 

features of the Gulf of Mexico are very different from those of southern California. 

The Ecology of the Offshore Oil Rigs 

 The ecology of the Southern California Bight (SCB) is a contributing factor in the 

scientific and political debate over the future of oil rigs. OCS Oil and gas activity should not 

be understood in isolation from the ecology of the SCB. California OCS oil and gas structures 

are located and embedded in the SCB, a marine ecosystem that includes an area between Point 

Conception (in south-central California) and Punta Banda (south of Ensenada, Baja

California, Mexico) (Dailey, et al. 1993). 

 The SCB is a system of relationships between circulating water masses and currents, 

various geochemical processes, oceanographic processes, microorganisms, phytoplankton, 

zooplankton, fishes, a rich flora of benthic macroalgae and seagrasses, benthic invertebrates, 
Final Study Report – McGinnis, Fernandez, Pomeroy 

20

an abundance of nutrients and other organisms.9 Where a rig or platform is in this 

oceanographic system of the SCB is one factor that can shape the level of biomass and organic 

matter associated with a rig. 

 The biomass associated with California OCS oil and gas structures often depends on 

the relationship between the biology of the structure and the oceanographic setting. This is a 

dynamic setting influenced by changing ecological patterns, oceanographic currents, and 

climate-related events, such as El Niño or La Niña. Ocean-climate variability is an important 

factor contributing to the ecology of the Bight.10 Life around a platform should not be thought 

of as a “steady state”. As the University of California’s Scientific Advisory Committee on 

Decommissioning (Holbrook, et al. 2000: 4) note, “The particular species present at any given 

platform depend on the biogeographic setting of the platform and its depth, as well as other 

factors.” The biogeographic setting of each rig can change over time. The character to marine 

life that we witness around the rigs today can change as the complex relationship between 

oceanography, biology and climate-related factors as changes. Life around a platform may 

change in a context of ocean-climate variability.11 A decommissioning policy option that 

treats all 27 platforms the same across spatial and temporal scales would be unwise because it 

would fail to understand the impacts at any one rig in the dynamic and complex ecological 

context of the Bight (Holbrook, et al. 2000). 

Biogeography 

 Offshore structures are embedded in one or more of these biogeographical provinces. 

The spatio-temporal scale of the biogeographical provinces change in accordance to 

hydrographic conditions of the SCB and climate perturbation. Rigid classification of these 

three biogeographical provinces is not recommended because such a classification inevitably 

de-emphasizes the complex and shifting interrelationships of these regimes (Horn and Allen 

1978). 

 Offshore oil and gas structures are situated within one of three biogeographical 

provinces of the SCB. The northern Channel Islands straddle two faunal provinces and 

respective oceanographic regimes (such as the warm and cold temperate) (Murray and Littler 

1981). San Miguel lies in the colder waters of the Oregonian Province, while Anacapa and 

Santa Barbara Islands are embedded in the warmer Californian Province. The eastern side of 

Santa Rosa Island and Santa Cruz Island lie in the transition zone between the two provinces. 

The transition zone is described as a third biogeographical province that affects the 

ecosystems of the islands (Murray and Bray 1993). The transition zone shifts position with 

time depending on the relative strengths of the causal processes. 

 Other studies of distribution patterns of species support the presence of two primary 

faunal regimes. California fish fauna assemblages may be classified into two groups -- those 

associated with cold- and warm-water masses (Horn and Allen 1978). 

 

9

 The spatio-temporal scale of dynamic and complex marine systems is difficult for human beings to predict. 

Hydrographic circulation patterns and climate events, such as El Niño, span scales of up to thousands of 

kilometers. The large range of spatial and temporal features of marine systems make it difficult to predict and 

understand ecological relationships and linkage. 

10 Human activity, such as pollution, oil development and fishing influence the ecology of the SCB (McGinnis 

under review). 

11 I have proposed the idea of a “living permit” as one response to variability (McGinnis 1998). 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

21

Transition Zones 

 Some offshore structures are embedded in a transition zone between these two water 

masses. This is particularly true for those oil and gas structures that are located within the 

Santa Barbara Channel. A transition zone involves an active interaction between two or more 

systems across their respective “boundaries”. This interaction between provinces results in a 

transition zone that includes properties from both systems. It can also result in a high-level of 

marine species diversity. 

 Marine scientists provide evidence for the transitional nature of the entire SCB using 

quantitative analyses of compositions of insular and mainland intertidal floras, which appear 

to show affinities of both warm- and cold- temperate biotas (Murray and Littler 1981). 

 The SB Channel includes patterns of warm, saline water from the Southern California 

Countercurrent and the colder water from the California Current. Upwelling often occurs 

where these water masses meet, near the massive headlands of Point Arguello and Point 

Conception, as well as along much of the California coast, depending on the season. 

Upwelling plumes expand southward from headlands and frequently enter the SB Channel on 

the southern side of the western mouth (Atkinson et al. 1986). There can be a channelwide 

response to upwelling north of Point Conception (Auad et al. 1998). Oceanographic thermal 

fronts are abundant in the SB Channel and form as a consequence of upwelling and of current 

shear between the two primary currents (Harms and Winant 1998). 

 The extent to which cold water enters the SB Channel is variable (Harms and Winant 

1998). Moreover, the SB Channel includes mesoscale eddies that are important to the general 

health of particular species and organisms in the region. The changing character of the SB 

Channel eddy, for example, and its potential role in enhancing survivorship of fishes during El 

Niño events has been observed (Nishimoto and Washburn, under review). Nishimoto and 

Washburn (under review: 8) propose that persistent cyclonic eddies in the SB Channel are 

“important local mechanisms for offsetting large-scale declines in marine populations 

associated with climate variations.”

 The importance of the SB Channel as a transition zone is linked to spatial and 

temporal variability observed in fish assemblages within habitats of the marine environment. 

Cross and Allen (1993) review the ecology of fishes in the major habitats of the SCB. In 

addition, Schroeder (1999) provides preliminary evidence that the large amount of spatial and 

temporal variability observed in fish assemblages within habitats is primarily associated with 

the SB Channel’s dynamic oceanography. In addition, recently published evidence 

(Nishimoto 1999) suggests that mesoscale spatial distributional patterns of pelagic juvenile 

fishes reflect hydrography and circulation in the SB Channel. Nishimoto and Washburn 

(under review) provide evidence that the closed circulation of persistent eddies can retain 

fishes through their early life histories. Behavioral responses to abiotic and biotic factors 

associated with eddies in the SB Channel may also be important in distribution, recruitment 

and survival (Love et al. 1999). 

Changing Oceanographic Conditions 

The mean circulation in the SCB is dominated by the poleward-flowing Southern 

California Countercurrent (Harms and Winant 1998). The California Current, which is fed by 

the West Wind Drift, is the eastern limb of the North Pacific gyre. This current turns 

shoreward near the southern US border, and a branch of the current turns poleward into the 

SCB, where it is known as the Southern California Countercurrent. The Southern California 
Final Study Report – McGinnis, Fernandez, Pomeroy 

22

Countercurrent flows equatorward along the west coast of the US throughout the year. This 

countercurrent is strongest in summer and winter. This counter current draws warmer water 

from the south and forces the water northwest through the Channel Islands. 

 The confluence of the California Current and the Southern California Countercurrent 

has been shown to affect the abundance and distribution of marine species (Dailey, et al. 

1993). The systems of the SCB, including the Channel Islands and the biology of offshore oil 

and gas structures depend on relationships between circulating water masses and currents. 

Because the oceanography and climate of the SCB changes, the spatio-temporal character of 

marine life on or around particular offshore oil and gas structures will change. 

Regime Disturbance in the SCB 

 The SCB is one of the most studied marine systems in the world (Hickey 1993). 

Members of the California Cooperative Oceanic Fisheries Investigations (CalCOFI) have 

studied the SCB since 1950 (Scheiber 1995). CalCOFI information provides an up-to-date 

characterization of some of the major ecological components and trends of the SCB. 

CalCOFI studies show that circulation within the SCB is highly variable in time and space, 

and is determined by the relative strengths of wind stress and oceanographic pressure 

gradients through the Santa Barbara Channel (SB Channel). For example, El Niño Southern 

Oscillation (ENSO) events have had dramatic effects on the flow patterns of the SCB 

(Chelton et al. 1992). Changes in the flow patterns have been shown to have a number of 

biological impacts: 

• population shifts in commercially-harvested species, such as squid, rockfish and 

lobster; 

• transport of enormous volumes of sediments and suspended materials from the 

mainland to coastal and offshore waters; 

• disturbance to critical marine habitats, notably storm and water temperature 

damage to kelp forests. 

 Marine scientists show that large-scale changes, or what is referred to as a regime shift, 

in the physical and biological processes can lead to change in the distribution and abundance 

of some marine species. A regime shift changes the basic nature of marine ecology for several 

decades at a time (or on the order of several human generations). McGowan, et al. (1998) 

state that the last regime shift occurred in 1977. Based on an analysis of CalCOFI data,12

Roemmich and McGowan (1995a, b) document large-scale changes in primary and secondary 

productivity throughout the SCB between 1951 and 1993. Hayward et al. (1996) and 

McGowan, et al. (1998) show that large-scale biological responses in marine ecology due to 

climatic variations in the atmosphere has resulted in changes in geographical ranges and 

spatial patterns of species and in community structure. This evidence suggests that the 

maintenance of community structure and patterns of native species diversity has changed in 

accordance to hydrographic perturbations and climate-ocean variability. A summary of the 

changes described by marine scientists is below (McGinnis 2000, under review): 

• The Euphotic Zone (upper sunlight zone of the sea, less than 120 m thick): Smith 

and Kaufmann (1994) show a long-term deficit in the supply of food necessary to 

 

12 CalCOFI has compiled several spatially and temporally comprehensive data sets for the SCB from strategically 

located offshore stations (Hickey 1993: 21-25). 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

23

meet the metabolic demands of the sediment community. The long-term increase 

in sea surface and upper water column temperatures and physical stratification in 

the system has resulted in a lower rate of supply of nutrients to the euphotic zone; a 

decrease in productivity and a general decline of zooplankton and other species 

(such as larval fish production, sea birds, kelp production and a shift in benthic, 

intertidal community structure.) Despite this decline in food supply, the food 

demand of the deep-benthic sea community remained constant.13

• Macrozooplankton: Since the late 1970s, macrozooplankton volume in the 

California Current has declined over 70%, in concert with increasing sea surface 

temperatures (Roemmich and McGowan 1995a, b; McGowan, et al. 1998). 

Reduced macrozooplankton has a major impact at higher trophic levels by 

changing the nature of the food supply.14

• Fishes and Invertebrates: Dugan and Davis (1993) document the general decline in 

long-term productivity in 19 species of nearshore fishes and invertebrates in 

California from 1947 to 1986. Data from the California Department of Fish and 

Game (CDFG) show decreases in harvest for most categories of groundfish, 

California sea urchin landings, landings of swordfish and selected shark species, 

Pacific Mackerel, Pacific Herring, California halibut, market squid (for the period 

1997-1998) among others (such as CalCOFI 1995, 1998). Long-term trends in the 

SCB commercial fishing vessel rockfish shows a substantial decline from 1980 to 

1996, with extremely low catches from 1993 to 1996 (Pacific Marine Conservation 

Council 1996). 

• The estimated abundance in streams south of Point Conception of steelhead 

rainbow trout is probably on the order of a 100 - 300 adults (Pacific Fishery 

Management Council 1999). 

• Southern Sea Otter: The southern sea otter population is below equilibrium and 

listed as endangered under the Endangered Species Act (Bodkin et al. 1996; Estes 

et al. 1996). 

 

13 In an investigation of food supply and demand in the eastern North Pacific off the central California coast 

between 1989 and 1996, Smith and Kaufmann (1994) show a long-term increase in sea surface and upper water 

column temperatures and physical stratification in the system. Because of this stratification, the depth of mixing 

nutrient-rich water has shoaled off, resulting in a lower rate of supply of nutrients to the euphotic zone; a 

decrease in productivity and a general decline of zooplankton and other species (such as larval fish production, 

sea birds, kelp production and a shift in benthic, intertidal community structure.) The investigators show that a 

long-term deficit in the supply of food necessary to meet the metabolic demands of the sediment community is 

unsustainable. Despite the decline in food supply, the food demand of the deep-benthic sea community remained 

constant. This issue is also addressed and critically reviewed by Druffel and Robison (1994). 

 The data suggests that if long-term climate change continues, one result will be a continued reduction in 

the supply of food to the deep-sea benthos. This reduction could produce a concomitant shift in the 

characteristics and in the composition of the abyssal community. 

14 Temperature of the water is described as playing a prominent role in determining faunal/floral distributions 

(Horn and Allen 1978). Hydrographic patterns affect the dispersal of organisms (and pollutants). For example, 

because most nearshore fishes, invertebrates, and macroalgae have planktonic phases in their life histories, the 

spatial and temporal variability of their recruitment is linked to physical oceanographic processes, such as 

currents, eddies and upwelling (Roughgarden et al. 1988). 
Final Study Report – McGinnis, Fernandez, Pomeroy 

24

• Oceanic Birds: Ecological theory predicts that in a stable ecosystem those species 

occupying high trophic levels maintain native species diversity and community 

structure. Upper trophic level animals such as pelagic birds are indicators of the 

health of the marine environment (Veit et al. 1996). Evidence suggests that the 

abundance of oceanic birds in the region and the SCB have declined steadily since 

1988 (Veit et al. 1996, 1997). Veit et al. (1996) believe that this reduction reflects 

considerable biological change within the California Current System. Veit et al. 

(1996, 1997) indicate that ocean warming and climatic events change pelagic bird 

abundance within the California current system. 

• Southern California Kelp: Starting in the late 1970s, Tegner et al. (1996, 1997) 

show that kelp forests have suffered great damage. Tegner et al. (1997) show a 

two-thirds reduction in standing biomass since 1957 in southern California kelp 

forests.15

• Global Climate Change: There is also some indication that the frequency of these 

climatic events may be increasing (McGowan, et al. 1998).16

 Temperature of the water is described as playing a prominent role in determining 

faunal/floral distributions (Horn and Allen 1978). Hydrographic patterns affect the dispersal 

of organisms (and pollutants). For example, because most nearshore fishes, invertebrates, and 

macroalgae have planktonic phases in their life histories, the spatial and temporal variability 

of their recruitment is linked to physical oceanographic processes, such as currents, eddies and 

upwelling (Roughgarden et al. 1988). 

 Marine scientists show that a trend in the general decline in the food supply and 

biomass of the SCB began before the current warm-water regime was identified by marine 

scientists; the general decline in the biomass started before 1977 (McGowan, et al. 1998). 

The water temperature of the SCB is getting warmer. We can expect increased storm activity 

and other climate-related impacts to intensify in the future (McGowan, et al. 1998).17 The 

 

15 According to Tegner et al. (1996, 1997) kelp forests suffered great damage during these events are now 

systematically smaller and depauperate, a trend that began in the late 1970s. Tegner et al. (1996) show that the 

abundance and stipe number (an index of individual size) of southern California populations of the kelp 

Macrocystis pyrifera have undergone a substantial decline, following the trend of increasing sea surface 

temperature. Comparison with historical stipe data from 1957, 1973, and 1974 indicates up to two-thirds 

reductions in standing biomass since 1957 in southern California kelp forests. 

16 Development of coastal habitat (wetlands and saltwater marshes) is a contributing factor influencing the 

general health of the marine environment, pollution, commercial fishing and climate change. Important coastal 

locations in the study area that are important for marshbirds, waterbirds, shorebirds and seabirds include the 

Santa Ynez River Estuary and San Antonio Creek Estuary (on VAFB), Devereux Slough, Goleta Lagoon, 

Carpinteria Marsh, Santa Clara River Estuary, and Mugu Lagoon. Coastal development in or near many of these 

habitats and the general destruction of southern California’s wetlands has significant impact on the health of 

various bird species (McGinnis, et al. In Press). 17 A number of sources support this position, including US EPA. 2000. Regional Impact Report. Food and Fiber: 

Fisheries and Aquatic Systems. Oceans; 

http://www.epa.gov/globalwarming/publications/reference/ipcc/chp8/america12.html#two; US EPA. 2000. 

Regional Impact Report. Coastal Ecosystems; 

http://www.epa.gov/globalwarming/publications/reference/ipcc/chp8/america13.html; US National Assessment. 

2000 (June). The Potential Consequences of Climate Variability and Change; B. Herbert. July 10, 2000. Cold 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

25

ecology of particular rigs may change with future regime shifts and ocean-climate variability. 

In addition, biogeographical patterns and the transitionary nature of the SB Channel influence 

the ecology of rigs (Holbrook, et al. 2000). 

The Relationship Between Regime Disturbance and the Decommissioning Debate 

 Offshore rigs are part of a dynamic ecological system. The reduction in biomass and 

significant decline in the abundance of a number of species of rock fish and other marine 

animals and habitats sets the current ecological stage or context for the debate over the utility 

of the rigs-to-reefs option. It is important to keep in mind that rigs are situated in particular 

biogeographic settings that may change over time. 

 In summary, each offshore rig is situated in a particular ecological setting of the SCB. 

The ecology of a particular rig is influenced by oceanographic patterns (such as eddies and 

currents), biogeographic and faunal regimes, transition areas of the Channel, climate-related 

factors, and regime disturbance. Each platform has its own unique fish assemblage.18 There 

are wide differences between platforms in the numbers or biomass of various species. With 

respect to some of the platforms, mussels from the platform pilings are dislodged and fall to 

the bottom, creating a sense bed. These mussel mounds appear to form a different habitat 

from the platform bottom. There may also be differences in fish communities inhabiting 

platforms and nearby natural reefs (Holbrook, et al. 2000). What is certain is that 

policymakers may need to make trans-scientific decisions that involve the intermingling of 

scientific information, values and interests. 

The Political Ecology of Decommissioning 

Scientific investigation does not take place in a political vacuum, but involves 

important perceptual, value-based and ethical issues (Shrader-Frechette and McCoy 1994). In 

a comprehensive analysis of the history of California coastal and ocean studies from 1945-

1973, Harry Scheiber (1995) describes several factors that influence the use of scientific 

knowledge to inform ocean policies: 

1) the dilemma of incomplete information (policy makers often act without a 

comprehensive understanding of a policy area); 

2) the frustration of political entanglement (most policy areas include a number of 

government and non government interest); 

3) the minefield effects of multi-level government (ocean and coastal policy making is 

an intergovernmental process that involves a number of different actors who may hold 

different interests and values); and 

4) the pitfalls of naive faith in science. 

 In California, the politics of integrating scientific information in the OCS decision 

making process takes place within the context of a highly charged and contentious 

intergovernmental process. This process is often resolved by litigation (Lester 1991). Given 

scientific uncertainty, “good” scientific information is that which supports one’s position in 

the decision-making situation. 

 

Facts of Global Warming. NY Times; P. Hanson. August 3, 2000. Deep Sea Offers Clues to Global Warming. 

Chicago Tribune; Global Warming and California. www.nextgeneration.org. 

18 Love, et al. (1999, 2001) has found that juvenile fishes, primarily rockfishes (genus Sebastes), dominate the 

midwater around platforms. These are primarily widow, bocaccio, olive, blue and yellowtail rockfishes. Adult 

and older juvenile rockfishes dominate platform bottoms. The larger fishes tend to closely associate with the 

pilings and cross beam. 
Final Study Report – McGinnis, Fernandez, Pomeroy 

26

 Moreover, Shrader-Frechette (a philosopher) and McCoy (an ecologist) received 

funding from the National Science Foundation to evaluate the role of ecological theory and 

information in environmental policy making. Their findings and analysis are supported by 

recommendations made by the National Academy of Sciences and the National Research 

Council. Their findings are also relevant to the politics of decommissioning policymaking 

(McGinnis 1998). 

 Shrader-Frechette and McCoy (1994) show the following: 1) Ecologists do not agree on 

what the basic principles or ecological laws (“community” and “stability”) are; 2) All 

scientific facts are laden with epistemic or cognitive values. Values can be divided into three 

types: bias values, contextual values, and methodological values; 3) Ecology cannot dictate 

ends or goals (but can act as a guide to good environmental policy); 4) Ecologists and 

laypersons do not share the same uncontroversial and unambiguous goals; 5) Ecology cannot 

tell us what is “natural”; 6) Ecological applications arise when and because scientists have a 

great deal of knowledge about the (qualitative and quantitative) natural history of a specific 

organism or place (which is not the case in this policy area). 

 Based on the work of Shrader-Frechette and McCoy (1994), ecological information 

cannot provide the foundation for a future decommissioning policy or program. People will 

act out of their perceptual and value-based understandings of the world (Stone 1985). 

Ecology information cannot provide policy makers with goals or values for policies, but can 

guide policy makers regarding the means to attain or the reasons to attain policy ends or goals 

(Shrader-Frechette and McCoy 1994). 

If there is scientific consensus, scientists agree that all the facts are not in (Holbrook, 

et al. 2000). There is no scientific consensus on the ecological importance of offshore oil and 

gas structures (NRC 1985, 1996). Moreover, evidence suggests that offshore oil structures do 

not serve the same ecological functions as natural reefs (Holbrook, et al. 2000). Scientists do 

not know whether offshore rigs “attract” or “produce” fish (Holbrook, et al. 2000). 

 Therefore, value-based conflict between scientist, policymakers and the general public 

is inevitable given the ecological and political issues and concerns associated with the rigs-toreefs debate in California (Green 1996; MMS 1998d; McGinnis 1998). Scientists cannot tell 

us what is natural (Shrader-Frechette and McCoy 1994). The future of the organic machines 

of the SCB will remain a political and scientific debate over the various meanings and 

discourses of “nature”, the role of science, and issues related to appropriate technology. 

 The next section describes the costs and benefits that are associated with three 

particular decommissioning options. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

27

SECTION THREE

COSTS AND BENEFITS OF OPTIONS FOR CALIFORNIA 

OCS OIL AND GAS PLATFORMS 

By Linda Fernandez and Sam Hitz 

This section contains an analysis of three different alternatives for decommissioning 

oil platforms through identification and comparison of costs and benefits of each alternative. 

Monetary values are quantified for the cost and benefit categories along with identifying the 

influential variables affecting costs and benefits across nonuniform oil platforms. The 

estimates for the individual categories considered as well as the range of net costs in this 

analysis offer more details compared to previous studies that merely list speculative point 

estimates of fewer categories (for potential platforms in the North Sea) (Griffin 1996). 

The three decommissioning alternatives are: 

(1) Leave platform in place. This option involves steps to insure oil extraction activity 

is shut down as well as preparation of the platform to support other uses. Platforms would be 

stripped of all equipment directly related to the extraction of oil. Wells would be plugged 

normally (in compliance with 30 CFR 250) and conductors severed and removed completely 

to 15ft. below the mud-line. All other parts of the platform would remain, including 

potentially much of the above surface structure. The most biologically productive part of the 

platform is the upper part and this is likely to be removed in the process of the other two 

options. The euphotic zone is apparently from water surface down to about 100 feet. Juveniles 

are there and as the population ages, the fish move to lower depths. 

(2) Complete Removal of offshore platform from the ocean. The material from the 

platform is removed from the ocean for multiple destinations (scrapping and reuse or onshore 

disposal). The timing of platform removal varies ranging from one at a time all at once or 

lagged over time for simultaneous removal of multiple platforms to account for economies of 

scale. Wells would be plugged and no other part of the platform itself would remain above 15 

ft. below the mud-line. 

(3) Partial removal of the oil platform with disposal of the material either offshore or 

onshore. The estimates of this option apply to material that is toppled in place, taken to 

another location that the original platform, or disposal of the removed portion onshore. 

Partial removal encompasses several potential possibilities (see Figure 1). All 

scenarios under this last heading require wells to be plugged and conductors severed and 

removed as well. They also involve the removal of the topsides. Then, the jacket might be 

truncated to some specified depth. That portion of the jacket removed could be reefed on site, 

transported and reefed at another location, or disposed of onshore. The second possibility is 

that the entire jacket structure of the platform might be toppled in place. And finally, the entire 

jacket could be transported to another location and reefed. 

The cost analysis undertaken is static in nature. All costs are assumed to occur at the 

moment that decommissioning commences and are assumed to be one time costs. There is no 

attempt made to account for the actual dynamic nature of costs. That is, we anticipate that for 

some categories costs might be incurred at different points during the course of the 

decommissioning project. Furthermore, were decommissioning to commence at some point in 

the distant future, the cost information provided would have to be inflated accordingly. 
Final Study Report – McGinnis, Fernandez, Pomeroy 

28

Table 3 contains the cost and benefit categories with estimates and variables to be 

considered in the estimates for each of the three options for decommissioning. 

The subsequent paragraphs contain text to accompany each of the categories of costs 

and benefits in order of appearance in Table 3.

Table 3. Costs Associated with Decommissioning Options. 

 OPTIONS 

COSTS Leave-in-place Complete Removal Partial Removal 

 Leave-in-place entails less engineer- Engineering and Planning Costs All partial removal options will entail 

 ing and planning. Costs are apt to represent 2% of total removal costs more expensive engineering and planEngineering and Planning amount to 1% of total removal costs. for platforms >30,000 tons and 4% ning than the leave-in-place scenario, 

 This produces a range of for those whose weight is less. This but probably less than for complete 

 $14,700-$699,200 gives a range of $58,800-$1,398,400 removal. Hence the cost range is 

 $14,700-$1,398,400 

Permitting and Regulatory undetermined $230,000-$380,000 $230,000 $760,000

Compliance 

Platform preparation costs are less Platform preparation costs are es- The same deck preparations that are

extensive and might amount to be- timated to be some 12% of total made for complete removal must also 

 tween 1⁄4 and 1⁄2 of those for complete removal costs scaled according to be made for any partial removal 

Platform Preparation removal. This produces a range of deck weight. Depending on size of scheme. Costs remain the same, 

 $75,000-$600,000 the platform this method produces $300,000-$1,200,000 

 a range of $300,000-$1,200,000

 Standard plugging and abandonment procedures would be employed in all options. 

Plugging and Abandonment No complications: $63,300/well; Major complications: $192,400/well. 

This results in a range of $633,000-$12,121,200 for all options.

 Most likely completed in conjunction with P&A process. Undertaken regardless 

Conductor Severing of disposition option. 400 ft. and less: $34,000; 

and Recovery 400-800 ft range: $59,400; 800 ft and deeper: $3,029,400. 

 These estimates give a range of $291,000-$3,029,400 for all options.

 Would involve a minimal use Depends on market conditions and Potentially some small savings might 

 of heavy lift equipment, whose extent of demand for heavy marine be achieved here relative to the 

cost drives this category. construction equipment as well as the complete removal case. However, 

 Total mobilization/demobiliza- size of heavy lift vessel that will be costs could easily be just as large.

Mobilization/Demobilization tion costs would probably required. These vessels will either be $500,000-$12,000,000 

amount to less than $500,000 deployed from Asia (100 days of 

 transit) or the Gulf (200 days of 

 transit). This yields a cost range 

 of $500,000-$12,000,000. 

 Platform and structural removal cost Costs depend on exact partial disposi-

 No costs incurred. Decks, jacket includes the cost of removing top- tion option. Complete removal 

and piles would be abandoned sides, cutting piles and removing where entire structure is reefed in 

in place. jackets. It depends most critically on another location would not change 

 the size of the structure and cones- the costs relative to complete removal 

Platform and Structural quently its depth. 200 ft. = with onshore disposal 3,960,000 - 

Removal $3,960,000; 400 ft. = $15,263,000; $48,675,000. A toppling in place

 700 ft. = $21,450,000; 1200 ft. = scenario would result in a range of 

 $48,675,000. Accordingly, the range $2,904,000-$8,632,000 depending 

 is $3,960,000-$48,675,000 on the depth of the structure. A trunca- 

 tion scenario would result in a range of 

 $2,376,000 - $14,850,000 

 Pipelines and cables must be Abandonment is most likely strategy. Pipelines and cables must be 

 dealt with in the same way Removing lines and cables could dealt with in the same way 

 they might for a complete esclate costs sharply. There are no they might for a complete 

Pipeline and Power Cable removal scenario. exact estimates of the cost of doing removal scenario. 

Decommissioning $400,000 - $550,000 so for platforms in greater than 700 $400,000 - $550,000 

 ft. of water. For a typical platform 

 the cost might be $400,000 - 

 $550,000 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

29

Table 3. Costs Associated with Decommissioning Options (continued)

 OPTIONS 

COSTS Leave-in-place Complete Removal Partial Removal 

 Minimal costs incurred. Cost estimates for materials Materials disposal cost depends upon 

 disposal include transportation partial removal scheme employed. 

 and assume that all steel is Toppling in place would entail costs of 

 scrapped and recycled. Estimates $1,262,500- $4,050,000. Truncating 

 are net of the revenue generated jackets to a navigable depth (100 ft.) and 

 by recycling. All other materials disposing of the jacket section on land 

Materials Disposal are assumed to be disposed of in would give a range of $1,668,750 - 

 appropriate landfills. Based on $6,000,000. A scheme that involved 

 the size of the platform the cost transporting part or all of the jacket and 

 range would be $1,925,000 - reefing it in another location would not 

 $23,450,000 change costs significantly relative to the 

 topple-in-place scenario. 

 Costs would be less than in a Total for platforms in <300 ft. of Costs could be less than in a complete 

 complete removal scheme, however water: $244,200-$521,400. Total removal scheme(for truncation options) 

Site Clearance and exact cost savings is difficult for platforms in >300 ft. water: but higher for reefing an entire 

Verification to quantify. $590,700 - $1,060,400 structure in another location.

 The overall range would vary from 

 the leave-in-place costs to perhaps 

 twice the complete removal costs. 

 Removal of mounds could cost up to 

 No costs incurred. $2.5 M/platform in 4H case. Likely Costs only incurred in move and reef 

 more in deeper water. Alternatively scenario, in which case they will be the 

Shell Mounds providing trawlers with navigational same as in the complete removal option 

 aids might entail one time cost of 

 $1.5M for those affected by 4H 

 mounds. Cost of buoying represents 

 a low end at $30,000 

 Costs might range from buoys on order 

 Visual presence minimizes need for No costs incurred of $30,000 to provision of more sophisNavigational Aids additional measures ticated navigational aids for effected 

 parties. Perhaps as much as $75,000/ 

 ship. Truncating to a minimum depth 

 of 100 ft. should reduce potential 

 liability. 

TOTAL COSTS $2,085,900 - $18,560,200+ $8,500,000 - $106,364,400+ $5,879,400 - $90,354,800+ 

 OPTIONS 

BENEFITS Leave-in-place Complete Removal Partial Removal 

 Shellfish harvest by Ecomar 

 removing biofouling consists of: No data tying area without rig to No data tying area without rig to 

Commercial Fishing Mussels: 50-100,000 lbs/rig/year, fish stock fish stock 

 Oysters: 100-1000 bushels/rig/year 

 Scallops: 1000-10,000 lbs/rig/year. 

Using average prices for 1999, 

 range of commercial value: 

 $16,150 - $460,000

 Diving and Fishing value from 

 recreational boat operations: 

Recreational Value $10,000/year at rigs where currents 

 and weather do not limit access as 

 well as presence of habitat 

TOTAL BENEFITS $26,150 - $470,000 

Engineering and Planning Costs 

The Engineering and Planning phase of decommissioning consists of several stages. 

The first stage is a review of all contractual obligations and decommissioning requirements 

from lease, operating, production, sales or regulatory agreements. The second stage is an 

engineering analysis aimed at developing a plan for every phase of the decommissioning 
Final Study Report – McGinnis, Fernandez, Pomeroy 

30

effort, from well plugging and abandonment to the removal and disposal of platform 

materials. The third stage involves the process of surveying the market for required equipment 

and vessels and beginning to contract for such equipment. The nature of the marine 

construction business necessitates that this be done well in advance of planned 

decommissioning, perhaps as early as three years proceeding. Finally, an assessment must also 

be made of which tasks can be handled in-house and which require outside operational 

assistance or responsibility. The process of hiring outside contractors might also include 

procuring the services of firms with large project management and engineering expertise to act 

as a general contractor of sorts. 

Costs under this heading represent the company manpower or consulting costs 

incurred to devise a detailed plan for all stages of the decommissioning process. The 

engineering and planning phase and the costs incurred during this stage will themselves 

depend on the technical procedures and the particular dismantling strategies to be employed 

which this process identifies. For instance, the extent of planning involved for the 

decommissioning of a platform with an integrated topside will be less than for a platform with 

a complex modular deck (See Topsides Removal Section below). The latter might necessitate 

planning fairly involved modifications to deck modules and prefabrication in preparation for 

individual lifts. Similarly, attempting to remove a deep water jacket by progressive transport is 

apt to require far more detailed planning than removing a small jacket in a single lift. 

However, while this phase will be different for each particular platform it is important 

to recognize aspects of the decommissioning process that are common across platforms. 

Certain aspects of the planning process need not be repeated for all platforms and 

consequently cost savings could be realized at this stage under some sort of a combined 

decommissioning effort. These savings would of course depend upon the number of platforms 

to be decommissioned and the extent of their similarities. 

The 4H engineering and planning cost figure ($1.6M) indicates the costs involved in 

planning for the complete removal of a series of relatively shallow water platforms (Clement, 

personal communication, 1999). This cost represents some 4% of the total removal costs of 

$38M (Clement, personal communication, 1999). Four percent seems comparable to the 

engineering and planning costs in the Gulf as a percentage of total expenditures. The absolute 

planning costs incurred for a large deep-water platform decommissioning effort would 

undoubtedly be greater than those for a small-shallow platform. However, as a percentage of 

total cost they are apt to be less. A previous analysis prepared by the MMS asserts that 2% 

might be more accurate representation for heavier platforms (greater than 30,000 tons) (MMS 

1999). Most OCS in the Pacific fall into four cohorts, small (5,000 ton range), medium 

(10,000 ton range), large (30,000 ton range) and ultra-large (70,000 ton range). This same 

MMS analysis suggests that $1000/ton represents a fair estimate for the total cost of removing 

a ton of steel platform (MMS 1999). 

The leave-in-place scenario would entail fairly minimal planning and engineering 

costs. These cost would be related to planning for plugging and abandoning wells, removing 

conductors, removing or abandoning pipelines and power cables and clearing the topsides or 

equipment (Culwell 1998). One percent or less of total removal costs might represent a fair 

indication of costs in this scenario. 

In the case of a partial removal these costs would be somewhat less than the complete 

removal scenario depending upon the nature and extent of removal (Culwell 1998). Toppling 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

31

in place might represent the partial removal scenario with the least planning and engineering, 

and consequently lowest costs. The engineering and planning costs for the topple-in-place 

option might be bounded on the lower end by the those costs incurred under the leave-in-place 

scenario. Both partial removal where part or the entire jacket is transported to another location 

(be it in the ocean or onshore) are apt to involve a level of planning that equals or potentially 

even exceeds complete removal. 

Example of cost calculation: 

Platform Hermosa (depth 603’, weight 28131 tons) 

Complete Removal: $1000/ton × 28,131 tons × 2%= $1,125,000 

Leave-in-place: $1000/ton × 28,131 tons × 1%= $280,000 

Partial Removal: < $1,125,000 

Cost Range based on weight 

Platforms Gina (weight 1470 tons) to Harmony (weight 69920 tons) Table 4 contains 

the corresponding details for each platform. 

Complete Removal: $58,800-$1,398,400 

Leave-in-place: $14,700-$699,200 

Partial Removal: $14,700-$1,398,400+ 

Costs and variables for Engineering and Planning are summarized in Table 3 and 

Figure 2. 

Table 4. Platform Specifications. 

Well and Conductor Specifications Projected Platform Removal Weights

Platform Water Depth Wells to Conductors Jacket Wt. Deck Wt. Total Wt. 

 (ft.) Plug (tons) (tons) (tons) 

Gina 95 12 12 434 815 1470 

Hogan 154 40 40 1263 2259 4110 

Edith 161 18 23 3454 4134 8298 

Houchin 163 36 36 1486 2591 4637 

Henry 173 23 24 1311 2500 4247 

A 188 52 55 2516 2601 6350 

B 190 57 57 2516 2601 6355 

Hillhouse 192 47 52 2000 2500 5538 

C 192 38 43 2516 2601 6270 

Gilda 205 63 64 3220 3792 9342 

Irene 242 24 24 3110 2500 7652 

Ellen 265 61 64 3200 5350 11634 

Habitat 290 20 20 3200 3514 8853 

Grace 318 26 35 3090 3800 9390 

Hidalgo 430 10 10 10950 8100 21421 

Hermosa 603 13 16 17000 7830 28131 

Harvest 675 19 21 16633 9024 30190 

Eureka 700 50 60 18500 5200 29192 

Gail 739 21 22 18300 7693 31320 

Hondo 842 29 29 12200 8450 27250 

Heritage 1075 27 49 32420 9826 60556 

Harmony 1198 26 51 42900 9839 69920 

Source: MMS, “Offshore Facility Decommissioning Costs, Pacific OCS Region,” March 31, 1999 
Final Study Report – McGinnis, Fernandez, Pomeroy 

32

Figure 1. Partial Removal Options 

Permitting and Regulatory Compliance Costs 

This category describes costs related to obtaining the necessary federal, state and local 

permits required to conduct decommissioning operations and satisfy the California 

Environmental Quality Act (CEQA) and National Environmental Policy Act (NEPA). 

Typically, companies might contract consultants to guide them through the complex and 

sometimes length permitting process required by numerous federal, state and local agencies 

and to provide the services that ensure compliance. The latter might include addressing 

marine mammal protection provisions or measures required by local Air Pollution Control 

Districts to offset emissions during decommissioning operations. Much of the information 

available on these costs is derived from Chevron’s experience with the 4H platform removal 

project (Clement, personal communication, 1999) with costs as follows: 

Environmental Consultants $200,000 

Marine Mammal Protection $200,000 

SLC Administrative Fees $450,000 

(State Lands Commission) 

APCD Offset Fees $450,000 

(Air Pollution Control District) 

Fishermen Preclusion Compensation $510,000 

The final category describes the cost ($15,000 average) to compensate 34 fishermen 

who were precluded from the fishing areas in which they commonly operated during the 

decommissioning process. The actual figure corresponds to navigational tracking aids to avoid 

the area. 

Reef in another 

location 

Plug wells 

Sever and remove 

Conductors 

Remove topsides 

Truncate jacket to 

navigable depth 

Sever piles 

Reef in place 

Reef in another 

location 

Topple jacket in

place 

Option 1 

Option 2 

Option 3 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

33

Clearly, some of these costs can be extrapolated to future decommissioning efforts and 

others cannot. For instance, in the case of OCS decommissioning, State Lands Commission 

fees would not be relevant as OCS platforms are not located in State waters. Furthermore, in 

light of the fact that state law now precludes Air Pollution Control Districts from levying 

offset fees it does not make sense to include this category. In the 4H case, fees for 

environmental consultants cost $200,000 per platform. This represents a relatively fixed cost 

that to some extent does not depend upon whether one platform or four are being 

decommissioned. It seems reasonable to assume that these costs might range between 

$50,000/platform and $200,000/platform depending upon how many were removed in 

conjunction. Marine mammal protection costs (covering the expense of NMFS observers and 

observation vessels) probably represent less of a fixed cost. Accordingly, $50,000/platform is 

a fair estimate. Finally, the compensation of fishermen will depend upon the scope of the 

decommissioning effort as well as the number of fishermen operating in the area, the type of 

fishery affected and the duration of preclusion. The per platform costs of compensating 

fishermen in the 4H cost may give a fair indication of this cost for future decommissioning 

projects (approx. $130,000). Taken together these costs sum to a range of $230,000 –

$380,000 for the complete removal of a platform. 

The leave-in-place option will avoid the majority of these costs, but may incur other 

costs related to leaving the bulk of the structure in place such as compensation for the 

permanent loss of what might have been fishing grounds. This amount might be distinct from 

the navigational hazard or net hazard posed by leaving a structure in place. This cost is apt to 

be negotiated and critically dependent upon the political atmosphere at the time of 

abandonment (MMS 1999). 

Any partial removal plan would undoubtedly lead to regulatory and compliance costs 

substantially higher than those incurred under a complete removal plan. This would especially 

be the case for any scheme involving transport of a portion (or the entirety) of a jacket to state 

waters for reefing. In this case permitting and related activities would have to be undertaken 

for at least two sites. Consequently, these costs could be several times as large as those 

incurred for complete removal (perhaps $430,000 – $760,000 or more). The expected range 

would then be bounded by the minimum potential complete removal costs ($230,000) on the 

low end and twice the maximum potential complete removal costs ($760,000). 

Costs and variables for Permitting and Regulatory Compliance are summarized in 

Table 3 and Figure 2. 

Figure 2. Factors Contributing to Range of Costs by Category*

Example Cost Category 

— Factors determining 

Low end factors high end factors 

* Based on Complete Removal Costs, 

† Size of arrows is not proportional to estimated costs 

†
Final Study Report – McGinnis, Fernandez, Pomeroy 

34

Figure 2. Factors Contributing to Range of Costs by Category (continued)

Engineering and Planning 

— Size of structure (gross tonnage) 

— Complexity of Topsides 

— Water depth

Small $58,800 - $1,398,400 large 

integrated deck complex, modular deck 

shallow deep 

Permitting and Regulatory Compliance 

— Number of platforms decommissioned during effort

 $230,000 - $380,000 

single platform multiple platforms 

 

Platform Preparation 

— Size of structure (gross tonnage) 

— Complexity of Topsides

Small $300,000 - $1,200,000 large 

integrated deck complex, modular deck 

 

Plugging and Abandonment 

— Degree of difficulty 

— Number of well slots

no difficulty encountered $633,000 - $12,121,200 difficulty encountered 

few well slots many well slots 

 

Conductor Severing and Removal 

— Depth

 $219,000 - $3,029,400 

shallow deep 

 

Based on Complete Removal Costs. Size of arrows is not proportional to estimated costs. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

35

Figure 2. Factors Contributing to Range of Costs by Category (continued) 

Mobilization and Demobilization 

— Market conditions in marine construction industry

— Size of structure (gross tonnage) 

— Location from which large equipment deployed 

— Number of platforms decommissioned during effort

low demand for HLVs $500,000 - $12,000,000 high demand for HLVs 

small large 

Asia GOM or North Sea 

single platform multiple platforms 

Platform and Structural Removal 

— Size of structure (gross tonnage) 

— Depth and type of diver support required 

— Market conditions in marine construction industry 

— Complexity of Topsides

Small $3,960,000 - $48,675,000 large 

shallow/air diving deep/saturation diving 

low demand for HLVs high demand for HLVs 

integrated deck complex, modular deck 

Pipeline and Power Cable Decommissioning 

— Depth 

— Extent and length of pipeline removed (removal costs not incorporated in analysis)

 $400,000 - $550,000 

shallow deep 

Materials Disposal 

— Size of structure (gross tonnage) 

— Distance to disposal facility

small $1,925,000 - $23,450,000 large 

disposal facility disposal facility distant 

 close 

Based on Complete Removal Costs. Size of arrows is not proportional to estimated costs. 
Final Study Report – McGinnis, Fernandez, Pomeroy 

36

Figure 2. Factors Contributing to Range of Costs by Category (continued)

Site Clearance and Verification 

— Depth and type of diver support required 

— Size of area to be cleared

shallow/air diving $244,200 - $1,060,400 deep/saturation diving 

small area large area 

 

Shell Mounds 

— Depends on selected disposition method

 $30,000 - $1,500,000 

mark with buoys total removal 

 

Navigational Aids 

— Depends on method of marking residual structure

 $30,000 - $??? 

mark with buoys underwrite GPS systems 

 

Based on Complete Removal Costs. Size of arrows is not proportional to estimated costs. 

Platform Preparation Costs 

Platform preparation describes costs incurred in connection with ceasing operations 

and preparing the platform for decommissioning. These steps might include cleaning the 

decks of hydrocarbon residual, degassing and cleaning tanks and lines, removing platform 

equipment, installing equipment needed for decommissioning, cutting pipelines and power 

cables, installing structural reinforcement required for lifting, etc. (Culwell 1998). The key 

factors driving the costs of this stage of decommissioning are apt to be size and complexity of 

the deck (Prasthofer 1998). 

In the Gulf of Mexico, platform shutdown and decommissioning costs were reported 

to be some 6% of the total cost of platform removal ($1000/ton) (MMS 1999). However, the 

MMS analysis correctly points out that for the purposes of extrapolation, the cost of platform 

preparation should be related only to the size of the deck (MMS 1999). Since approximately 

1⁄2 of the total platform weight is contributed by the deck in a shallow water platform, as most 

of those in the Gulf have been, this percentage should be doubled in any extrapolation. The 

weight of the deck as a proportion of the total platform weight decreases disproportionately as 

total platform weight increases (MMS 1999). MMS identifies the following categories for 

platform size: 

Small 12% of 2500 tons @ $1000/ton = $300,000 

Medium 12% of 4000 tons @ $1000/ton = $480,000 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

37

Large 12% of 7500 tons @ $1000/ton = $900,000 

Ultra-Large 12% of 1000 tons @ $1000/ton = $1,200,000 

yielding a range of $300,000 - $1,200,000 per platform for complete removal. 

For the leave-in-place scenario, platforms must still be cleaned and stripped of 

equipment related to the extraction of oil and gas. However, there is obviously no need to 

make preparations for further platform removal. It might then be reasonable to assume that the 

costs related to cleaning and clearing the decks might be 1⁄4 to 1⁄2 those incurred during 

complete removal (Prasthofer 1998). This would give a range of $75,000 - $600,000. 

Since all the partial removal scenarios involve the removal of the topsides, they would 

entail essentially the same deck preparations that would be required under a complete removal 

option. 

Costs and variables for Platform Preparation are summarized in Table 3 and Figure 2. 

Plugging and Abandonment Costs

Plugging and abandonment procedure is highly regulated and would be required under 

all decommissioning scenarios. Consequently, the costs incurred to meet the regulations 

governing plugging and abandonment would not be the distinguishing factor between 

decommissioning options (Byrd, personal communication, 1999). Hence, this category is only 

discussed briefly. The primary factor which can control plugging and abandonment costs is 

the degree of difficulty encountered, experienced as unforeseen time or operational delays. 

Well depth is a less important factor. Depending on the degree of difficulty encountered a well 

might take between 5 and 10 days to plug (Fields and Martin 1998). The number of wells to 

be plugged in Pacific OCS platforms ranges from 10 to 63 (MMS 1999). 

While the nature of the plugs and the depth of the wells will have an impact on the 

overall costs, those incurred during the 4H decommissioning project give an indication of the 

scale. Overall costs for well plugging and abandonment were $ 11,883,000 for Platform Hope 

with 46 well slots; Platform Heidi with 36 well slots; Platform Hazel with 24 well slots; and 

Platform Hilda with 29 well slots (Clement, personal communication, 1999). The resulting 

average cost per well $88,000 from the 4H project represents an average cost per well for 

minor complications. This is in line with the MMS analysis which suggests an average cost of 

$95,500 per well under the minor complications assumption and based on a contract with a 

service company to plug multiple wells (MMS 1999). MMS estimates a “no complications”

cost of $63,300 per well and a “major complications” cost of $192,400. Taken together this 

results in a range of $63,300 - $192,400 per well. Using this price range and Platform Gina 

with 10 well slots and Platform Gilda with 63 well slots (See Table 4) generates a cost range 

of $633,000-$12,121,200. 

Costs and variables for Plugging and Abandonment are summarized in Table 3 and 

Figure 2. 

Conductor Severing and Removal Costs

Conductor severing and removal would most likely take place as part of the plugging 

and abandonment process (Culwell 1998). As a cost common to all options, it does not 

significantly effect the overall decommissioning decision but it is discussed briefly 

nevertheless. Traditionally, mechanical casing conductors have been used with good success. 

However other options for conductor severing which could be used include abrasive water jet 
Final Study Report – McGinnis, Fernandez, Pomeroy 

38

cutting or explosives. Since the use of explosives is generally prohibited in open water, 

severing is done mechanically. After severing, conductors are pulled (generally in 40 ft.-long 

segments) and offloaded (Byrd, personal communication, 1999). While the cost of conductor 

removal for the 4H project was on the order of $14,000 per well this cost probably does not 

translate well to conductors in deeper water (Clement, personal communication, 1999). The 

length of the conductor is dependent upon the depth of the water column and the amount of 

material to be removed and disposed of varies accordingly (Culwell 1998). Conductors are 

generally severed 15 ft. below the mud line and extend up through the deck, perhaps 40-50 ft. 

above the water (Culwell 1998). Consequently the depth of the water column plus 65, 

multiplied by the number of well slots gives a fairly reliable indication of the length of 

conductor to be removed and disposed of (Byrd, personal communication, 1999). It is 

commonly estimated that the concrete grout used to bind together well casings weighs about 

60-100 pounds per foot of conductor (or alternatively occupies a volume of .5 ft3

) (Byrd, 

personal communication, 1999). Depth then is the driving variable for conductor removal 

cost. 

MMS estimates a price of $21,900/conductor removal in depths of 400 ft. and less, 

$34,400/conductor in depths of 400-800 ft. and $59,400/conductor for those in depths of 800-

1200 ft (MMS 1999). The number of conductors for platforms in the Pacific OCS varies from 

10 to 64. The shallow water platform with the fewest conductors (12) is Gina. The deep-water 

platform with the largest number of conductors is Harmony with 51 (See Table 4). These two 

platforms, at $219,000 (10 @ $21,900 each) and $3,029,400 (51 @ $59,400) also represent 

the cost extremes for conductor removal (MMS 1999). 

These costs do not include transportation or disposal of conductor material. The costs 

reflect costs associated with removal of marine growth offshore as the conductors are pulled. 

The concrete would have to be disposed of onshore. The cost of disposal could be easily 

estimated using landfill rates at the time based on this weight or volume. It is not anticipated 

to be difficult to locate a landfill capable of handling the concrete. 

Costs and variables for Conductor Severing and Removal are summarized in Table 3 

and Figure 2.

Mobilization/Demobilization Costs

The cost of assembling all the necessary equipment and transporting it to the 

decommissioning site can be considerable. This is especially the case for the U.S. West Coast, 

where there are currently no heavy lift vessels that have the capacity to handle platform 

decommissioning (Clement, personal communication, 1999). In the 4H case, a relatively 

simple decommissioning project relative to deepwater platform decommissioning, these costs 

approached $2.4 M (Clement, personal communication, 1999). For deepwater platforms that 

require the heaviest lift vessels available and large cargo barges, this figure would certainly be 

eclipsed (Clement, personal communication, 1999). The exact value of this figure will be 

sensitive to the state of the marine construction market during decommissioning and the other 

demands for this relatively scarce equipment. It will however principally depend upon the cost 

of mobilizing and demobilizing the heavy lift vessel that the decommissioning project 

requires (Culwell 1998). This cost will vary depending upon from where the heavy lift vessel 

must be deployed. The approximate time to deploy a heavy lift vessel from Asia would be 

fifty days, or a total mobilization/demobilization time of 100 days (MMS 1999). If a vessel 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

39

were to be deployed from the Gulf of Mexico or the North Sea area this figure might be closer 

to 200 days (MMS 1999). The day rate for a 500-ton capacity lift vessel is on the order of 

$25,000 (MMS 1999). The rate for the largest capacity dual-crane semi-submersible heavy-lift 

vessels can be upwards of $300,000/day (potentially as high as $500,000/day depending upon 

the demand for marine construction equipment) (MMS,1999). 

It is however important to recognize that if the decommissioning of these large 

platforms were undertaken in a serial fashion, the mobilization/demobilization costs on a per 

platform basis could be minimized through economies of scale. The cost range could be 

calculated as follows: 

Low end: 100 days @ $25,000/day ÷ # of platforms decommissioned 

High end: 200 days @ $300,000/day ÷ # of platforms decommissioned 

If decommissioning was done in groups of 5, this range might be between $500,000 

and $12,000,000 (Clement, personal communication, 1999). 

A leave-in-place scenario would greatly reduce the need for and consequently the need 

to mobilize heavy lift vehicles. In most instances the cost to mobilize equipment would 

probably be less than the lower end of the range calculated above. 

A partial removal scenario would not be apt to affect mobilization/demobilization 

costs. In most instances, heavy lift vessels would still be required (Culwell 1998). A scenario 

that saw the jacket structure truncated or simply toppled might not require a heavy lift vessel 

of the same capacity that complete removal would. However, under all partial removal 

scenarios, the topsides must be completely removed. This could be the factor that determined 

the capacity of lift vessel required. Furthermore, any scenario in which the jacket structure 

was transported to another location would call for a lift vessel of the same capacity that 

complete removal might otherwise dictate. Consequently, that a partial removal scheme would 

not substantially reduce mobilization/demobilization cost. 

It should be noted that this discussion does not attempt to project what types of new 

technology might be available to employ in the decommissioning process. There is simply not 

enough information at this point to make projections about the availability of new 

technologies and the cost of mobilizing and demobilizing such technology. 

Costs and variables for Mobilization and Demobilization are summarized in Table 3 

and Figure 2. 

Platform and Structural Removal Costs 

Topsides Removal

The diversity and range of complexity of topside facilities suggests that no one 

removal technique will be most appropriate or cost effective in all cases (Byrd, personal 

communication, 1999). This makes it difficult to generalize about the costs associated with 

this stage in the overall decommissioning process. However, the costs stemming from the 

removal and disposal of topside decks can be a substantial portion of the overall costs of 

decommissioning. They have been estimated to account for 30-40% of the total removal costs 

of the installation (Byrd, personal communication, 1999). A number of complexities as well 

as the method of removal employed drive costs. 
Final Study Report – McGinnis, Fernandez, Pomeroy 

40

As described in the Platform Preparation section, topsides must first be cleaned. This 

process involves draining all tanks and piping of operating fluids and removing all small or 

loose equipment from the decks. Regulated substances must be removed in accordance with 

all guidelines (Culwell 1998). For the leave-in-place disposition scenario, all further 

equipment directly related to the extraction of oil must be removed. Additional removal as 

required under the complete removal and partial removal scenarios can then proceed in one of 

four ways. 

Removal in one piece entails lifting off the entire topside at once after it is severed 

from the jacket. While this method has the advantage of requiring the least amount of offshore 

work, which can rapidly escalate costs, it requires the use of a large capacity lift crane. There 

are few cranes actually capable of lifting the loads that might be required if this method were 

employed for California platforms. A number of the topsides under consideration off the coast 

of California weigh in the 8,000 to 10,000-ton range. While the very largest semi-submersible 

dual-crane heavy-lift vessels have a combined lift capacity on the order of 14,000 tons, most 

current generation high capacity heavy lift vessels are 5,000-ton capacity and their expense 

can be considerable (potentially in the range of $300,000-$500,000/day) (Byrd, personal 

communication, 1999). Consequently, this method is only practical for the smallest of 

topsides. 

A second method that can be applied to those topsides whose construction is modular 

in nature is reverse installation removal (Prasthofer 1998). So-called modular topsides are 

assembled piecemeal from units as opposed to integrated deck structures where the facilities 

and hooked up and commissioned onshore and simply attached to the jacket or substructure 

offshore (Prasthofer 1998). These modular topsides can be removed in a fashion that parallels 

their installation, but in reverse sequence. While reverse installation requires more pre-lift 

planning than one-piece removal it makes the removal of large topsides feasible with the 

current generation of moderate capacity or heavy lift crane barges (Culwell 1998). It would be 

possible to extrapolate from cost records of installation, adjusted for inflation, to get a handle 

of what exactly this process might cost. Records indicate that between 6 and 17 main lifts 

were required to install the topsides of those platform decks that are modular in nature 

(Prasthofer 1998). The largest lift for any one module or support structures was 2,000 tons 

(Prasthofer 1998). 

A similar method of removal reduces the number of lifts and consequently time for 

which expensive heavy lift vessels are required by lifting combined modules. This method 

however can require more extensive preparation and stabilization for lifts (Culwell 1998). 

Finally, a last approach is to deconstruct topsides on the platform using cutting devices 

and make a number of smaller lifts. These lifts can be made from deck mounted cranes, 

eliminating the need for heavy lift vessels or cargo barges all together. However while this 

method alleviates the need for expensive heavy lift equipment, it is time and labor intensive 

(Culwell 1998). 

While individual circumstances will determine which method is most cost effective, 

the removal of topsides in most cases is likely to be by the reverse installation process 

(Prasthofer 1998). The basic driving costs which must be weighed in each case and in light of 

prevailing market conditions are heavy lift vessel commissioning, cargo barge hiring and 

manpower costs. Clearly single lift strategies (if technically feasible) might minimize the 

number of trips that a cargo barge would have to make between the platform and onshore 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

41

scrapping facility (Byrd, personal communication, 1999). However, it would necessitate the 

use of the very largest heavy lift vessels, potentially very expensive. Strategies that 

disassemble the topsides offshore to some degree (modular removal or small piece removal) 

reduce the need for heavy lift vessels but probably increase labor costs and might require 

multiple cargo barges making multiple trips to and from the scrapping facility (Prasthofer 

1998). 

Pile Cutting

While the open water use of explosives has been restricted, application below the mud 

line continues to be permitted and is seen as the most reliable method of severing piles 

(Culwell 1998). This reliability translates into lower costs. However the use of explosives 

requires that measures be taken to ensure that the impact on marine life is minimal. These 

costs are outlined in the Permitting and Regulatory Compliance section. In addition to method 

of cutting it is also important to consider factors such as piling access for cutting, diving 

requirements and water depths. 

Jacket Removal

Jacket removal is apt to be the costliest portion of the decommissioning process for 

larger Pacific OCS platforms (MMS 1999). In some cases, jacket removal can be 

accomplished as a single lift. This is not likely except for very small jackets. In most instances 

for larger platforms this will not be possible. Jackets can also be removed in sections 

potentially. However, deep-water structures present a serious hurdle, as their weights exceed 

the limits of current lift technology. Pacific OCS jackets range in weight from 400 tons to 

approximately 43,000 tons and are located in water depths that range from 95’ to 1198’(MMS 

1999). One proposed strategy (progressive transport) relies on rigging the structure between 

several barges, winching it off the sea floor and dragging it into shallower water where the 

exposed portion is removed and the process is repeated (Byrd, personal communication, 

1999). The costs associated with jacket removal will depend on the method of removal 

selected. This will determine the size of the heavy lift vessels and other equipment required as 

well as the quantity of offshore cutting required and labor. It is likely that gross tonnage will 

be the driving factor in the choice of method. 

Transport to the scrapping facility (Portland, Oregon) represents another significant 

portion of the total removal costs. Distance to the scrapping facility is influential due to the 

high cost of marine equipment 

The absence of jacket removal costs for the leave-in-place scenario represents a 

significant source of cost savings. For the partial removal scenarios the cost of jacket removal 

could vary tremendously. The topple-in-place scenario would probably be the cheapest partial 

removal option. Cutting and removing part of the jacket would undoubtedly constitute a larger 

expense. And finally, actually moving the entire jacket to a different location could be as 

expensive as complete removal, depending upon how far the structure is transported. 

Costs for Complete Removal

MMS estimates the costs of removing topsides, cutting piles and removing jacket 

structures based on estimates of the size and weights of the structures, the number of modules, 

the number of lifts needed and maximum weight of lifts needed (MMS 1999). The number of 

days required for completing various tasks is also estimated (MMS 1999) (See Table 5) and 

the removal costs are estimated for a typical platform at depths of 200, 400, 700 and 1,200 
Final Study Report – McGinnis, Fernandez, Pomeroy 

42

feet. Based on these factors the study calculates costs of $3,960,000, $15,263,000, $21, 

450,000 and $ 48,675,000 for platforms of increasing depth (MMS 1999). These cost 

estimates are primarily composed of the derrick barge costs and a per day estimate of related 

diver support, survey and other related vessels and equipment. A 10% contingency cost is also 

included to account for weather and other unforeseen factors. For 200 ft. platforms and less, a 

2,000 ton derrick barge ($150,000/day) is considered sufficient while for 400 ft. and greater 

platforms 5,000-ton barges are assumed ($310,000/day). The diver support and related 

equipment rate is estimated to be $30,000 per day for platforms in 200 ft. of water and 

$65,000 for platforms in 400 ft. of water or greater. These assumptions lead to the following 

costs: 

200 ft. water depth platform total cost of removal 

($ 150,000/day + $ 30,000/day + 10% contingency) × 20 days = $3,960,000 

400 ft. water depth platform total cost of removal 

($ 310,000/day + $ 65,000/day + 10% contingency) × 37 days = $15,263,000 

700 ft. water depth platform total cost of removal 

($ 310,000/day + $ 65,000/day + 10% contingency) × 52 days = $21,450,000 

1200 ft. water depth platform total cost of removal 

($ 310,000/day + $ 65,000/day + 10% contingency) × 118 days = $48,675,000 

Costs for Leave-in-place

A leave-in-place decommissioning strategy would incur no further ordinary costs 

beyond the platform preparation stage. Cleaned and stripped decks would remain in place as 

would piles and jackets. 

Costs for Partial Removal

Many partial removal scenarios would greatly reduce the costs associated with 

structural removal and they are considered here. A partial removal scenario where decks are 

removed, piles severed and the entire jacket structure is relocated and reefed in an alternate 

location would not change the costs of structural removal (Byrd, personal communication, 

1999). 

However a scenario where decks were removed, piles severed and the jacket was 

toppled in place would reduce maximum lift required (toppling could be done by simply 

winching the jacket structure onto its side (Byrd, personal communication, 1999). Working 

with the MMS assumptions, (See Table 4) this would mean that for platforms of all depths, a 

2000-ton capacity derrick barge would be sufficient. Furthermore, the days devoted to jacket 

removal (4, 12, 24 and 75 for increasing depth) would no longer be required. Related costs 

might remain at 50% of their previous values. This yields the following estimates for the 

toppling in place scenario: 

200 ft. water depth platform total cost of removal 

($ 150,000/day + $ 15,000/day + 10% contingency) × 16 days = $2,904,000 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

43

400 ft. water depth platform total cost of removal 

($ 150,000/day + $ 32,500/day + 10% contingency) × 25 days = $5,019,000 

700 ft. water depth platform total cost of removal 

($ 150,000/day + $ 32,500/day + 10% contingency) × 28 days = $5,621,000 

1200 ft. water depth platform total cost of removal 

($ 150,000/day + $ 32,500/day + 10% contingency) × 43 days = $8,632,000 

These cost give a fairly good indication of what deck removal and pile severing might 

cost. The actual process of toppling the jacket could be expected to add to these figures but 

not substantially. Thus, they are a fairly accurate indication of how much removal for the 

topple-in-place option might cost. 

Finally, it is also possible to build a scenario for partial removal in which the topsides 

are removed and the jacket is truncated to a depth thought to be safe for navigation 

(approximately 100 ft.). In this type of scenario the cost of cutting piles would be avoided as 

would much of the jacket removal work. Based on the MMS assumptions about the size of 

jacket sections to be removed and the number of days required for each section, truncation to a 

least 100 ft. requires 2, 3, 4 and 10 days for platforms of 200, 400, 700 and 1200 ft. depth 

respectively. Pile cutting and removal days are avoided all together. Number of days required 

for deck removal is unchanged (10, 16, 16, and 26 for increasing depth) as are the maximum 

lifts. The three deeper categories of platform still would require a 5,000 ton capacity derrick 

barges ($310,000/day) but would probably require a diminished level of support (again we 

assume 1⁄2 the level as for complete removal). The total number of removal days would then 

be 12, 19, 20, and 36 respectively. These assumptions yield the following cost estimates for 

the truncation scenario: 

200 ft. water depth platform total cost of removal 

($ 150,000/day + $ 30,000/day + 10% contingency) × 12 days = $2,376,000 

400 ft. water depth platform total cost of removal 

($ 310,000/day + $ 65,000/day + 10% contingency) × 19 days = $7,837,500 

700 ft. water depth platform total cost of removal 

($ 310,000/day + $ 65,000/day + 10% contingency) × 20 days = $8,250,000 

1200 ft. water depth platform total cost of removal 

($ 310,000/day + $ 65,000/day + 10% contingency) × 36 days = $14,850,000 

Clearly, then the cost savings represented by either of these latter two partial removal 

scenarios are substantial. 

Notes about Further Research and Reuse

Given the fact that each platform is unique, specific engineering and removal plans 

must be formulated before costs can be delineated thoroughly. The feasibility and cost 
Final Study Report – McGinnis, Fernandez, Pomeroy 

44

effectiveness of new technologies that might be employed in the removal process must also be 

investigated if a more accurate assessment of removal costs is to be conducted. Finally the 

technical potential to reuse refurbished deck components and equipment should be 

investigated thoroughly. Similarly, a potential market for the distribution and reuse of 

equipment between industry players and not simply within one company’s operation, must be 

explored further. 

Platform and Structural Removal costs and variables are summarized in Table 3 and 

Figure 2. 

Pipeline and Power Cable Decommissioning Costs 

At the present time there are 55 pipelines (315 miles) and 19 power cables serving 23 

facilities in federal waters offshore California (MMS 1999). Any decommissioning strategy 

deal with the offshore pipeline and power cable infrastructure associated with an oil platform. 

Whatever approach to pipeline and power cable removal or abandonment is adopted, it will be 

applied in all potential platform disposition options. In this respect, costs incurred for pipeline 

and power cable disposition are common to all platform-decommissioning options and do not 

effect this decision. Therefore, the discussion of this category is brief. 

Both Federal and California regulations allow decommissioned OCS pipelines to be 

abandoned in place so long as they do not constitute a hazard to navigation, commercial 

fishing or unduly interfere with other uses of the OCS. California State Lands Commission 

policy requires removal, when feasible, of pipeline segments in the surf zone to a depth of 15 

feet. Too date, with few exceptions, most power cables have also been abandoned in place. 

Any plan for power cable and pipeline decommissioning (be it removal or 

abandonment) begins with a survey and data collection phase. This process is aimed at 

identifying where pipelines or cables might pose a liability as well potentially as determining 

pipeline and cable burial locations and depth, water depth, nearby pipelines or structures and 

environmental information (Culwell and McCarthy 1998). In addition engineering information 

such as pipeline and power cable characteristics must be known. Under any scenario pipelines 

must be cleaned thoroughly. This involves “pigging” and flushing the lines with various 

substances aimed at removing all hydrocarbons (Culwell and McCarthy 1998). On a large 

scale, if complete removal were undertaken for instance, disposal of pipeline and power cable 

would constitute a potential hurdle. Reuse of pipeline steel is not feasible due to coatings 

(Culwell and McCarthy 1998). Any pipeline removed would have to be cut into short lengths 

and landfilled appropriately. Similarly, it is not likely that power cable could be reused. It too 

would have to be taken to a dumpsite. In an abandonment scenario, pipelines would be 

severed, capped and buried. Similarly, free ends of cut power cables would also be buried. 

Finally, post removal or abandonment site-clearance would be required. Costs associated with 

pre- and post-decommissioning surveys, engineering and planning, and transportation and 

disposal are included elsewhere. 

It is likely that many pipelines could be abandoned in place in the Pacific OCS (39 of 

55) however, some 16 would have to be removed (MMS 1999). The largest costs considered 

in this category are incurred during any such removal operations, and are driven by both fixed 

(mobilization/demobilization) and hourly rates for vessels and diver-related services. These 

costs are apt to increase with increasing depth and length of pipeline. 

The cost to decommission 2 pipelines in place, a typical number for a Pacific OCS 

platform would range from $400,000 - $550,000 (MMS 1999). “Decommissioning projects, 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

45

which necessitated partial or total removal of pipelines, could be as much as an order of 

magnitude higher depending upon length of pipeline and water depth. These estimates include 

economies of scale that might be achieved in decommissioning several closely-spaced lines in 

concert and average fixed costs over multiple projects.” (MMS 1999). MMS does not attempt 

to project the costs for decommissioning pipelines in place in water depths greater than 700 ft. 

or removing pipelines in water depths beyond 150 ft. due to the paucity of data. Pipeline 

abandonment and decommissioning is clearly an area where further study and experience will 

allow for more accurate forecasting of cost. 

Costs and variables for Pipeline and Power Cable Decommissioning are summarized 

in Table 3 and Figure 2. 

Materials Disposal Costs

There are three avenues for disposal of materials generated from decommissioning 

operations: reuse, scrapping and recycling and disposal in landfills. Opportunities for large 

scale or wholesale reuse of topsides or equipment are apt to be limited given recent stricter 

technical standards for equipment and the fact that many components were designed for a 

specific set of functional requirements (Byrd, personal communication, 1999). Scrapping 

remains perhaps the most viable option for the bulk of the steel removed while land-filling is 

the likely option for other material. Potentially harmful substances, while apt to occur in small 

quantity must be dealt with prudently and appropriately. 

No onshore facility in California is capable of landing or dealing with the large deepwater structures (Byrd, personal communication, 1999). The nearest facilities capable of 

landing and scrapping such structures are in the San Francisco Bay area (400 miles away) and 

Portland, OR (1000 miles away) (MMS 1999). The overwhelming bulk of the waste stream 

generated from decommissioning platforms is the steel from jackets. Schnitzer Steel 

Industries, Inc. in Portland processes some 500 tons of steel per hour. The total weight of 

California’s offshore platforms is 401,387 tons (MMS 1999). Schnitzer has quoted a price of 

$400/ton for scrapping the steel from offshore platforms. The steel must be cleaned of marine 

growth. This can be problematic as far as air emissions are concerned but marine growth can 

be disposed of in non-hazardous wet landfills. At most, marine growth might represent 5% by 

weight of the total gross tonnage of a platform. There has been some discussion of attempting 

to blast this growth off the jackets as they are removed from the water. This however would 

require permitting and its cost implications are not entirely clear. Scrapped steel could be sold 

at a conservatively estimated price of $75-100. In the past much of this scrapped steel has 

been sent to Japan. These figures are in line with the costs faced by Chevron during the 4Hdecommissioning project (MMS 1999). The net cost of scrapping steel in that instance was 

$333/ton. 

Other materials that are part of the waste stream but represent far smaller quantities 

include concrete and insulating materials and mud that could be disposed of in landfills in the 

Southern California area (Clement, personal communication, 1999). Most concrete is present 

as part of the conductors. This volume can be estimated as indicated in the discussion of 

conductor removal. Insulation and other materials might represent an even smaller proportion 

of the waste stream, perhaps 100 tons/platform (Byrd, personal communication, 1999). A 

more direct way to estimate these costs is to extrapolate based on the 4H costs 

($350,000/platform) (Clement, personal communication, 1999). The following calculations 
Final Study Report – McGinnis, Fernandez, Pomeroy 

46

build on the 1999 MMS study and assume that the cost of disposing of all non-steel waste will 

range from $300,000/platform for the smallest of platforms to $700,000 for the largest of 

platforms. The handling, transport and disposal of concrete would most likely dominate the 

cost of disposing of other materials (Byrd, personal communication, 1999). These estimates, 

combined with a cost of 325$/ton (after sale of scrap steel at $75/ton) yield the following cost 

estimates: 

Small 5,000 tons of steel × $325/ton + $300,000 (other materials) = $1,925,000 

Medium 10,000 tons of steel × $325/ton + $350,000 (other materials) = $3,600,000 

Large 30,000 tons of steel × $325/ton + $500,000 (other materials) = $10,250,000 

Ultra-Large 70,000 tons of steel × $325/ton + $700,000 (other materials) = $23,450,000 

Leave-in-Place

The leave-in-place scenario would incur few costs related to disposal of materials. 

Partial Removal Schemes 

A topple-in-place scenario would require only that deck material be scrapped. If the 

bulk of the deck material is in fact steel, the numbers just calculated can be adjusted. For most 

platforms categorized as small, the deck weight constitutes approximately half of the total 

tonnage (Byrd, personal communication, 1999). This relationship holds true for medium 

tonnage platforms as well. For large platforms, deck weight is more nearly 1/4 of the total 

platform weight. And, for ultra-large platforms, deck weight is closer to 1/7 of the total 

platform weight (Byrd, personal communication, 1999). This results in the following costs: 

Small 1⁄2 × $1,925,000 + $300,000 (other materials) = $1,262,500 

Medium 1⁄2 × $3,600,000 + $350,000 (other materials) = $2,150,000 

Large 1/4 × $10,250,000 + $500,000 (other materials) = $3,062,500 

Ultra-Large 1/7 × $ 23,450,000 + $700,000 (other materials) = $4,050,000 

A scheme that truncated jackets at approximately 100 feet below the surface would be 

apt to incur roughly the same non-steel related disposal costs as in the aforementioned 

scenarios (again, concrete from conductor removal is apt to dominate this category) (Byrd, 

personal communication, 1999). Steel-related disposal costs could be calculated based on the 

number of sections that would have to be removed to achieve truncation to 100 ft. and their 

summary weight (See Table 5 below). 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

47

Table 5. Platform Deck and Jacket Removal Times and Costs. 

 WATER DEPTH (ft.) 

 200 400 700 1200 

Derrick Barge Capacity (tons) 2000 4000-5000 4000-5000 4000-5000 

Jacket Weight (tons) 2500 11000 18500 43000 

Jacket Sections 

 Max Weight per Section (tons) 1250 3000 3000 3000 

 Number of Sections 2 4 6 15 

 Days per Section 2 3 4 5 

 Total Jacket Removal Days 4 12 24 75 

Deck Modules 

 Max Weight per Module (tons) 1000 2000 2000 1300 

 Number of Modules 5 8 8 13 

 Days per Module 2 2 2 2 

 Total Deck Removal Days 10 16 16 26 

Rig up/Rig down Days 4 7 10 15 

Pile Cut/Removal Days 4 7 10 15 

Total Days 20 37 52 118 

Coat per Day ($) 3,9600,000 15,263,000 21,450,000 48,675,000 

source: MMS, “Offshore Facility Decommissioning Costs, Pacific OCS Region”, March 31, 1999 

Finally, the cost of disposing of decks must also be included 

Small 1,250 tons of steel × $325/ton +$1,262,500 (deck and other) = $1,668,750 

Medium 3,000 tons of steel × $325/ton +$2,150,000 (deck and other) =$3,125,000 

Large 3,000 tons of steel × $325/ton +$3,062,500 (deck and other) =$4,037,500 

Ultra-Large 6,000 tons of steel × $325/ton +$4,050,000 (deck and other) =$6,000,000 

Finally, a partial removal scheme that involved transporting part or all of the jacket 

and reefing it in another location would not result in disposal cost significantly different than 

the aforementioned topple-in-place scenario. 

Costs and variables for Materials Disposal are summarized in Table 3 and Figure 2. 

Site Clearance and Verification Costs 

The scope of site clearance work will be determined by the disposition option selected. 

Also the potential future uses of a site will determine the extent to which debris clearance 

might be required. If for instance a platform is located in an environment unsuitable for 

trawling or any other use that require site conditioning, debris clearance (beyond the removal 

of hazardous material) could be less of an issue (McCarthy 1998). 

Typically, site clearance might begin with a pre-decommissioning survey of the area 

surrounding the platform using side-scan sonar (McCarthy 1998). Debris extraction, which 

relies on the use of ROVs and divers, would follow platform disposition (McCarthy 1998). 

This process might be part of a leave-in-place or partial removal scenario as well but it seems 

logical that, complete removal might motivate a more thorough debris removal (as would the 

move and reef option under partial removal). The actual cost of removing debris depends 

strongly on depth, size of area to be cleared and verified, quantity and type of debris, and 

weather conditions. Greater depths require different methods of removal, namely saturation 

diving. Trawling with heavy nets or using remotely operated vehicles (ROVs) working in 

conjunction with divers can be effective in shallow waters; deep water might necessitate 
Final Study Report – McGinnis, Fernandez, Pomeroy 

48

larger ROVs and even manned submersibles (McCarthy 1998). This would escalate costs 

considerably. Regulatory requirements also require test trawls. 

MMS estimates costs of clearance and verification for complete removal (MMS 1999). 

It is assumed that air diving is used for platforms in less than 300 ft. of water and saturation 

diving is used in platforms in greater than 300 ft. of water. 

Pre-Demolition Side Scan Sonar Survey (3 day) $55,000 

Post-Demolition Side Scan Sonar Survey (3 day) $55,000 

ROV deployment (7-14 days @ $11,000/day) $77,000-$154,000 

Air Diving (7-14 days @ $10,000/day) $70,000-$140,000 

Saturation Diving (7-14 days @ $45,000/day) $315,000-$630,000 

Test Trawl (7-14 days @ $5,000/day) $35,000-$70,000 

Total for platforms in < 300ft. of water $244,200-$521,400 (includes 

 10% contingency) 

Total for platforms in > 300ft. of water $590,700-$1,060,400 (includes 

 15% contingency) 

These costs are in line with the 4H case, where pre-abandonment surveying expenses 

amounted to $50,000 for the four platforms (Clement, personal communication, 1999). 

Trawling costs totaled approximately $238,400 for all four platforms (Clement, personal 

communication, 1999). The debris removal costs incurred in the 4H decommissioning process 

were on the order of $1.5M (Clement, personal communication, 1999). 

It is difficult to speculate reliably about how these costs might change in a leave-inplace scenario or any of the partial removal scenarios. A leave-in-place scenario would 

probably result in some cost savings. First, the extent to which site clearance and verification 

is required is apt to be less stringent. Furthermore, because less work is required to simply 

clean and prepare the decks for abandonment, there is apt to be less debris added to the sea 

floor during decommissioning than in all other options. While the former reasoning applies 

equally well to a platform toppled in place or one whose trunk is left in place, there is apt to 

be more debris added to the sea floor during the decommissioning process (McCarthy 1998). 

Consequently, there is some reason to believe that costs are apt to be higher than the leave-inplace scenario but still less than those incurred under complete removal. Finally, any scenario 

that reefs platform material in another location might incur the additional costs of surveying 

and clearing that new location. This could potentially double site clearance and verification 

costs (McCarthy 1998). 

Costs and variables for Site Clearance and Verification are summarized in Table 3 and 

Figure 2. 

Costs of Shell Mounds 

Complete removal of shell mounds, if ultimately required, could be a significant cost 

category. Chevron has estimated that, if required to remove the mounds left from the 4H 

decommissioning, costs could reach $10 M or $2.5 M per mound (Clement, personal 

communication, 1999). Clearly these costs might escalate in deeper water. Alternatives to 

actually removing shell mounds have been explored. In addition to buoying, these alternatives 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

49

include providing fishermen with specially equipped trawling nets with roller aimed at 

preventing snags. Also a draft agreement of the South Coast Trawlers Association 

Navigational Aid Program proposes compensating fishermen for constraining fishing grounds 

with differential GPS units (Carr, personal communication, 1999). This particular agreement, 

part of the 4H decommissioning, would involve an investment of approximately $1.5M to buy 

units for some twenty vessels (Carr, personal communication, 1999). Handling shell mounds 

and the threat they pose to trawling vessels requires further research, as do the ecological 

consequences of disturbing the shell mounds (Carr, personal communication, 1999). 

A leave-in-place or partial removal scenario (with the exception of reefing the entire 

platform in another location) is not apt to require the removal of shell mounds. In all such 

instances, there is apt to be debris that constitutes a more significant threat to trawling or 

navigation than do shell mounds. 

Costs and variables for Shell Mound decommissioning are summarized in Table 3 and 

Figure 2. 

Costs of Navigational Aids 

In all instances where some portion of the platform remains in the ocean, provisions 

must be taken to ensure safe navigation and trawling. For a leave-in-place scenario, where a 

substantial remainder of the above surface platform will continue to serve as a visual marker, 

few additional measures might be required. However, fishermen might still demand 

compensation for the continued loss of fishing grounds. While it is hard to extrapolate about 

the likely magnitude of such compensation, we know that in the 4H case the proposed 

compensation (in the form of differential GPS navigation systems) for exclusion due to the 

shell mound was on the order of $1.5 M ($75,000/fishing boat) (Clement, personal 

communication, 1999). These costs could substantially be higher depending upon the location 

and number of fishermen affected. For various partial-removal and reefing alternatives, other 

measures have been discussed. Buoys, costing $30,000 per mound on average have been used 

at least as a temporary measure to mark the shell mounds remaining from the 4Hdecommissioning project (Clement, personal communication, 1999). Buoys might be 

employed to mark any reefed material or the stump of a truncated platform. Alternatively or in 

addition, some more sophisticated navigational aid such as differential GPS units could be 

supplied to those vessels operating near an effected area. As with the 4H shell mounds, this 

might cost $75,000/vessel (Clement, personal communication, 1999). 

Costs and variables for Navigational Aids are summarized in Table 3 and Figure 2. 

Onshore Facility Removal Costs 

All three decommissioning options will bear the same onshore facility removal costs. 

Therefore, this is not a category of costs that requires details of estimation since it will not be 

a determinant in which decommissioning option is chosen. 

Preface to Biology Benefits 

The area that the platform occupies can support other activities due to biological 

resources that translate to benefits in terms of commercial fishing and recreational use. 

Currents in excess of seven knots, wave actions exceeding 15 feet and seasonal storms dictate 

utilization of materials and approaches that are inherently risky. Thus, any derivation of 

benefits for commercial and recreational fishing and aquaculture must be qualified with the 
Final Study Report – McGinnis, Fernandez, Pomeroy 

50

fact that access to the resource near a platform may be limited and therefore seen as an 

unachievable benefit. 

The following description of what evidence there is of biological growth and 

derivation of an economic value of this biological growth should be viewed in the context of 

what might occur near the platform delineated by the jacket and above water structure. No 

generalizations can be made in terms of the distribution, recruitment, and survival of biota for 

all platforms due to the variation across platforms in the multiple variables influencing the 

presence of biological growth such as currents, geochemical process, food chain dynamics, 

and nutrients (Chelton et al. 1992). There is no evidence at this time to make a case for 

attributing any potential value to pipelines that lead from the platforms to shore. Therefore 

under the different alternatives of full removal, partial removal or leave-in-place, there’s not a 

measure that takes into account any biological activity on these pipelines. Another key 

distinction to make based on evidence of two series of biological monitoring studies (Simpson 

1977 and de Wit 1999) is that the biological growth of shellmounds can only be counted with 

the option of leaving the platform in place. Observations made during the 4H study suggest 

that the removal of the upper portions of the platform legs and cross members and the 

elimination of deposits of live mussels to the shell mound has been a factor in this general 

reduction in shell-mound associated epibiota (de Wit 1999). The fish assemblage on the 

mound is related to that of the platform (Love et al. 1999). Average shell mound fish 

abundance with the platforms is 100 individuals per 100 square meter or 1 per square meter at 

seven platforms studied (Love et al. 1999). There is evidence that the act of removing the 

platform as well as what the platform offered the shellmound influences the overall decline in 

biological growth. In addition to physically disturbing the surface and subsurface shell layers 

during decommissioning operations, removal of the platforms has effectively eliminated the 

source of shell talus (de Wit 1999). Without the mound being re-supplied with live bivalves 

from the platform legs, support members, and drill pipes, the organic input has been reduced 

and the epibiota has been substantially altered (de Wit 1999). 

Commercial Fishing Benefits

Under the leave-in-place scenario, current commercial fishing value derived from the 

platforms may continue. Ecomar of Goleta, California, contracts with a number of oil and gas 

operators offshore of the California coast to remove what is considered biofouling by oil and 

gas operators from their platforms. The substantial buildup of sea life attached to the 

underwater support for the platforms causes enough wave and current drag to present a 

potential hazard in terms of structure instability (Dougall 1996). To alleviate this problem, 

operators pay Ecomar for divers to remove the growth. One man’s biofouling is another’s 

gourmet dinner (Dougall 1996) and Ecomar has established a business of selling the shellfish 

it harvests and seeds at the platforms. The species that it harvests are mussels, scallops, and 

oysters from the platform legs during the cleaning. The divers also harvest clams from bags 

that they seed by hanging infant clams suspended on the platform over a few months. The 

reason for the growth of species near the platform is that the offshore location tends to 

moderate swings in water temperature and water currents make the system essentially selfcleaning, providing new, oxygenated water and removing wastes from fish and feeding. The 

ranges in weight of shellfish biomass harvested are provided for Ecomar in Table 3 on a per 

platform basis. For mussels, 50-100,000 pounds harvested per year is multiplied by the 

average 1999 price of $3.00 pound for the wholesale market yielding $150-$300,000. For 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

51

oysters, 500-5,000 bushels harvested per year is multiplied by the average 1999 price of $20 

per bushel yielding $10,000-$100,000. For scallops, 1,000 to 10,000 pounds harvested per 

year is multiplied by the average 1999 price of $6 per pound yielding $6,000-$60,000. 

In order to predict any value of potential spillovers of fish from platforms as refugia to 

support recreational or commercial activities some distance away, it is necessary to obtain 

data that has not adequately been gathered indicating the range of movement (migration) of 

the species. The investment in tagging the fish underwater in order to deal with constraints on 

rockfish physiology (swimbladders). It is clear that the dispersal of larvae for the Piccachio is 

distant (from Mexico to Pt. Conception). Platform Gina is shallow, therefore, recreational 

access is possible. But, Platform Irene is deep and surrounded by strong current so recreational 

and/or commercial access would be from a distance. With tagging data it might be possible to 

link the data available from California Dept. of Fish and Game on catch per patch (square 

area) per time period and location of the platform in order to establish a value of the platform 

in generating fish stock benefits for the commercial fishing industry as well as for recreational 

fishing. 

The partial removal scenario and complete removal scenario cannot be assigned 

commercial fishing values. Foregone fish catches due to the presence of the platform are not 

quantified in detail due to the fact that the presence of the rig over the years has not led to 

compensation already of the fishing industry. There’s no guarantee that the area now occupied 

by the rig would necessarily have been used for trawling. 

Recreational Value 

It is possible to quantify some value for recreational activities associated with the 

platforms by using available information from entities such as the Liberty dive boat out of 

Channel Islands Harbor scheduling dive recreational trips to the platform Grace. The value is 

derived through the travel cost method. By adding up the costs for traveling in the boat and 

participating in diving (equipment costs, other amenities), the travel cost method indicates 

what people pay to recreate at the platforms. $60 per person multiplied by 50 people 

multiplied by 3 trips per year per platform plus the monetary value of miles traveled ($1,000) 

equals $10,000 per year. Clearly, the ability to derive this value is site-specific due to a 

variety of conditions that might limit access to the platforms even though there might be 

fishing and diving amenities. Table 3 indicates the recreational benefits value. 

There is evidence from Simpson (1977) of the presence of 20 varieties of avian species 

and 4 species of marine mammals including sea lions and gray whales at the 4H platforms. 

The recreational value for observing such species could be derived from quantifying the travel 

cost for boat trips in the Channel (using Island Packers out of Ventura as a reference). 

Habitat Value 

The most productive part of the platform is the euphotic zone that is delineated from 

the water surface down to about 100 feet. Since this portion is likely to be removed for either 

the complete removal or partial removal option, the habitat value is a benefit for the leave-inplace option. Some factors that determine whether the platforms serve as ideal conditions for 

reef habitat are whether the material of the platform has stability, durability, and function in 

terms of supporting material for fisheries. 

Simpson (1977) indicates twenty to fifty more fish were found under the platforms 

than on adjacent sedimentary bottom and five times more fish were present under the platform 
Final Study Report – McGinnis, Fernandez, Pomeroy 

52

than at natural hard bottom habitats. Love et al. (1999, 2001) have conducted the most 

extensive analysis of the platforms in terms of investigating specific mechanisms (e.g. 

enhanced juvenile recruitment, increased survivorship of adults) that lead to biological 

function of the platforms. Results from their three year study (1995-1997) show that platform 

fish assemblages were less diverse and more variable in space and time than natural reef fish 

assemblages (Love et al. 1999). Fish abundance and species richness were negatively 

correlated with platform depth. The most abundant species at the platforms are rockfish. 

Schroeder has modified a measure developed by Bond et al. (1999) that is an index of habitat 

value. The index sums the square root transformation of the product of each species’ density, 

mean size (total length) and fidelity (Schroeder 1999). Each of those are empirically 

measured with density quantified on the basis of number of fish per hectare and fidelity 

measured by the number of times a species is observed in all surveys divided by the total 

number of surveys. The index is used to produce a measure of biological production and 

might serve as the basis for estimating an economic value. On average, platform habitat values 

were 42% lower than natural reef habitat values. The four northern platforms located in the 

Santa Maria Basin had lower values than the south eastern platforms in the Santa Barbara 

Channel. The platform values were more variable than natural reef values due to 

oceanographic processes reinforcing the notion that Love et al. project of not generalizing but 

looking at each site separately. It is difficult generalize about the value of biological resources 

for the area and leads to a limitation in quantifying exact economic measures of benefits. 

More details about the fisheries value based on observations from Love, Schroeder, et al. 

suggest that the habitat value does incorporate some trend analysis in terms of seasonal 

changes in the presence of fish at the platforms through the variable, fidelity. By accounting 

for how many times the fish were spotted over the number of observations, it is possible to 

detect the frequency trend. Otherwise, by listing a range of values to indicate the low and high 

value corresponding to the scarcity and abundance of the species over time, it is also 

indicative of a trend. Based on the ranking the top 10 fish, it might be possible to narrow the 

comparison between natural reefs and platforms to indicating that rockfish are more abundant 

on platforms and surfperch and others more abundant on natural reefs. The habitat values are 

listed by species and by platform. The following equation from Schroeder et al. is used to 

quantify economic value with the habitat value multiplied by the monetary value of the 

species listed as present. 

The following equation offers a method to use a habitat value for each species that 

could be relevant for deriving a possible monetary value. 

HV % = (HV/∑HV) * 100 

Where HV is the habitat value contributed by each species and the sum of HV is the 

habitat value of the entire site. From Schroeder et al. (1999), the sum of values for nine 

platforms is 16,600. Since this represents both a percentage and size of the fisheries biomass, 

if might be useful to multiply this total for all of the platforms by a monetary value of the 

various fish. Assuming an average price of $5.00 for the variety of species, the habitat value 

for nine platforms is $83,000. From the table we can disaggregate to value each platform 

separately using the same average price. In this manner, we do not distinguish between what is 

commercially valued or what is nonmarketed for recreational and existence value. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

53

The costs of establishing and maintaining artificial reefs are common to all 

decommissioning options, according to David Parker of California Department of Fish and 

Game since the criteria for material for artificial reefs is that the material have the potential for 

maximizing complex, diverse biological growth that fosters production as well as attraction of 

flora and fauna (Parker, personal communication, 1999). The ideal material is quarry rock for 

stable substrate to have rugosity and to provide microhabitat hiding holes for production of 

flora and fauna not just attraction. Submersible and scuba surveys of platform structure reveal 

that fishes aggregate in crevices and corners at the bottom of platforms (Schroeder 1999). 

Parker asserts that it is likely for any platform that is proposed for potential reefing would still 

require material to be added to it (rock added within and around the legs and pilings to build 

the substrate for enhancing the complex, biological growth). Hence, there would be additional 

costs for making the rig into a reef besides just locating the rig somewhere (in place, toppled, 

cut and brought to shallow water). Granted, with a platform left in place, especially in a 

shallow position, there may be less purchase of quarry rock required due to the presence of 

shell mounds. The interaction between the mounds and the platform detritus fosters 

biological growth. However, since it has been noted that without the rigs and the constant 

supply of new material to the mounds, there is little growth (habitat for flora and fauna to 

thrive). Parker believes that the lost of the most productive euphotic zone with any change in 

the current platform orientation means there’s even more need to add more amendment 

material to have any potential for a reef. An example of the cost of quarry rock for reef 

activity is: 

$300,000 for 10,000 tons of quarry rock from Santa Catalina Quarry delivered onsite 

(mid 1990s) 

Figure 2 indicates the factors (variables of importance) contributing to the estimated 

range for each cost category. 

For example, the cost category for Engineering and Planning can yield costs increasing 

in structure size and weight, water depth and complexity of topsides. Permitting and 

Regulatory Compliance costs increase in the number of platforms decommissioned. The cost 

of Platform Preparation increases in the size of the structure and the complexity of topsides. 

Plugging and Abandonment costs increase in the degree of difficulty as well as the number of 

well slots. Costs of Conductor Severing and Removal increase by the variable of water depth. 

Mobilization and Demobilization costs are a function of market conditions in the marine 

construction industry and can increase with the size of the structure, distance between 

platform and location of equipment deployment, and the number of platforms 

decommissioned. There may be economies of scale from decommissioning several platforms 

in proximity with the same equipment. Costs of Platform and Structural Removal increase in 

the size and weight of the structure, water depth and labor support required as well as the 

complexity of topsides. Market conditions in the marine construction industry will influence 

the costs (the fewer number of operators, the higher the price of service, common of oligopoly 

and monopoly markets). Pipeline and Power Cable Decommissioning costs increase in water 

depth and the extent and length of the pipeline to be removed. Costs of Materials Disposal 

increase in the size of the structure and the distance from platform to disposal facility. Site 

Clearance and Verification costs increase in the water depth and type of labor support required 
Final Study Report – McGinnis, Fernandez, Pomeroy 

54

as well as the size of the area to be cleared. Costs of Shell Mound Decommissioning are a 

function of the method chosen. Navigational Aid costs also depend on the method of marking 

residual structures. 

Figures 3-7 indicate the cost categories that are most influential for each 

decommissioning option. Figure 3 graphs the leave-in-place scenario. Clearly, Plugging and 

Abandonment Costs could dominate all other cost categories with the largest range and 

highest upper bound. Figure 4 graphs the complete removal scenario. The costs of Platform 

and Structural Removal have the largest range and could surpass the next largest range of 

costs, Materials Disposal. Figure 5 graphs the reefing onsite partial removal scenario. 

Platform and Structural Removal costs could be as much as the range for complete removal 

and this category can far exceed other costs of Mobilization and Demobilization as well as 

Plugging and Abandonment. Figure 6 graphs the truncation partial removal scenario. The 

range for Platform and Structural Removal costs is largest followed by costs Mobilization and 

Demobilization and Plugging and Abandonment. Figure 7 graphs the topple-in-place partial 

removal scenario. This scenario is parallel to the truncation alternative with a decrease in the 

upper bound of the range for costs of Platform and Structural Removal. 

Figure 3. Cost Ranges by Category for Leave-in-place Scenario. 

$0

$2,000,000

$4,000,000

$6,000,000

$8,000,000

$10,000,000

$12,000,000

$14,000,000

Engineering and Planning

Permitting and Regulatory Compliance

Platform Preparation

Plugging and Abandonment

Conductor Severing and Recovery

Mobilization/Demobilization

Platform and Structural Removal

Pipeline and Power Cable Decommiss...

Materials Disposal

Site Clearance and Verification

Shell Mounds

Navigational Aids

none none unknown none none 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

55

Figure 4. Cost Ranges by Category for Complete Removal Scenario.

Figure 5. Cost Ranges by Category for Reefing Offsite Scenario

$0

$10,000,000

$20,000,000

$30,000,000

$40,000,000

$50,000,000

$60,000,000

Engineering and Planning

Permitting and Regulatory Compliance

Platform Preparation

Plugging and Abandonment

Conductor Severing and Recovery

Mobilization/Demobilization

Platform and Structural Removal

Pipeline and Power Cable Decommiss...

Materials Disposal

Site Clearance and Verification

Shell Mounds

Navigational Aidsnone 

$0

$10,000,000

$20,000,000

$30,000,000

$40,000,000

$50,000,000

$60,000,000

Engineering and Planning

Permitting and Regulatory Compliance

Platform Preparation

Plugging and Abandonment

Conductor Severing and Recovery

Mobilization/Demobilization

Platform and Structural Removal

Pipeline and Power Cable Decommiss...

Materials Disposal

Site Clearance and Verification

Shell Mounds

Navigational Aids

unknown unknown 
Final Study Report – McGinnis, Fernandez, Pomeroy 

56

Figure 6. Cost Ranges by Category for Truncation Scenario 

Figure 7. Range of Costs by Category for Topple-in-place Scenario 

$0

$2,000,000

$4,000,000

$6,000,000

$8,000,000

$10,000,000

$12,000,000

$14,000,000

$16,000,000

Engineering and Planning

Permitting and Regulatory Compliance

Platform Preparation

Plugging and Abandonment

Conductor Severing and Recovery

Mobilization/Demobilization

Platform and Structural Removal

Pipeline and Power Cable Decommiss...

Materials Disposal

Site Clearance and Verification

Shell Mounds

Navigational Aids

$0

$2,000,000

$4,000,000

$6,000,000

$8,000,000

$10,000,000

$12,000,000

$14,000,000

Engineering and Planning

Permitting and Regulatory Compliance

Platform Preparation

Plugging and Abandonment

Conductor Severing and Recovery

Mobilization/Demobilization

Platform and Structural Removal

Pipeline and Power Cable Decommiss...

Materials Disposal

Site Clearance and Verification

Shell Mounds

Navigational Aids

unknown none unknown 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

57

Comparing Alternatives 

The range of values for the three alternatives implies they can be compared relatively, 

where low and high bounds of the ranges may lead to a ranking. The range for Partial 

Removal has an upper bound that makes accounting for two sites (original platform site and 

site where rig is transported to) less attractive than the Complete Removal and Leave-in-place 

alternatives. The overlap of ranges for Complete Removal versus Leave-in-place means it is 

more likely that each platform should be considered individually in order to derive more 

specific estimates of costs and benefits to weigh alternatives. However, the ability to consider 

economies of scale from grouping platforms together for complete removal is possible by 

accounting for spreading the costs from the engineering and planning, mobilization and 

demobilization and platform and structural removal across several platforms. 

Since the study is an objective information document, the result should not be one 

alternative ranked above all others. Instead, the results identify the factors involved in 

decommissioning, especially for platforms standing in varied water depths that often exceed 

the depth of platforms that have been decommissioned in other geographic areas such as the 

Gulf of Mexico. Table 3 depicts the costs associated with the three decommissioning options 

described in this section. 

One category of interest that is not quantified here is liability. The oil producer retains 

all liability for the platform and wells under various decommissioning options. 

Liability for accidents during lease clearance and abandonment is a cost to contend 

with in terms of personal injury, property damage, and environmental damages for the 

complete removal alternative. Liability for any recreational or fishing accident taking place at 

a platform is a cost to contend with for the leave-in-place and partial removal alternatives. 

The potential costs of liability with the leave-in-place or partial removal alternatives 

call into question the logic of pending legislation (Senate Bill No. 1, Alpert) within the State 

of California that suggests platform operators can and will yield cost savings from leaving the 

platform in place for fisheries mitigation projects. The platform can still cost the operators 

long after ceasing oil production with threats of top-heavy platforms from biofouling growth 

supporting fisheries habitat leading to possible toppling and/or personal injury or property 

damage from accidents around the platform. The operators should hold financial resources to 

cover these potential costs. 
Final Study Report – McGinnis, Fernandez, Pomeroy 

58

SECTION FOUR 

CALIFORNIA’S ARTIFICIAL REEF PROGRAM AND 

THE RIG-TO-REEF DEBATE 

By Caroline Pomeroy 

 In the Gulf of Mexico OCS region, the connection between artificial reefs and rigs-toreefs has long been evident. In the Gulf States, artificial reef programs were created pursuant 

to, rather than prior to the emergence of questions about offshore rig decommissioning policy 

(See Section 5). In California, however, the interest in - and the development of - artificial 

reefs in state waters occurred nearly two decades prior to the first offshore platform 

decommissioning efforts, and even longer before the onset of the current rig-to-reef debate 

within the state. Table 6 depicts a chronology of the California Artificial Reef Program 

(CARP) and Rig-to-Reef Debate. 

Table 6. California Artificial Reef Program and Rig-to-Reef Chronology

1958-1964 Early investigative period. 

1958-1960 Ocean Fish Habitat Development Project study of two artificial reefs built by CDFG from 

donated materials and offshore oil drilling platforms to investigate the effectiveness of various 

reef materials for increasing sportfishing success. 

1958-1961 CDFG and Western Oil and Gas Association (WOGA) three-year agreement for CDFG to 

study effects on marine life of man-made structures and of depositing washed drill cuttings on 

ocean floor. 

1960-1965 Study of three experimental, multi-component man-made reefs and one "production" model 

reef in Santa Monica Bay to determine optimum material for artificial reefs and effects on 

fishing. 

1965-1980 CARP slow-down. 

1974 Platform Harry, 1 mile off Pt. Conception, decommissioned; reefing proposed, but tabled. 

1980-1986 Southern CA Edison builds an artificial reef to mitigate kelp forest loss. Major program of 

CARP reef construction and research begins with CDFG's kelp restoration group and Sport 

Fish Restoration Act funds redirected to CARP. 

1984 National Fisheries Enhancement Act passes. 

 Breaux amendment to Sport Fish Restoration Act allocates funds to artificial reef programs. 

1985 California SB 70 passes institutionalizing CARP and providing one-time $.5 million funding. 

1988 Platforms Helen, Herman decommissioned; reefing proposed, but tabled. 

1992 Last new artificial reef constructed by CDFG. 

 4H Platforms (Hazel, Heidi, Hilda, Hope) proposed for decommissioning; CDFG determines 

 materials not suitable for reefing. 

1994 MMS/SLC Decommissioning Workshop: "Abandonment and Removal of Offshore Oil and 

Gas Facilities: Education and Information Transfer". 

Use of decommissioned platforms as artificial reefs within Sycamore Canyon MRPA 

Ecological Reserve proposed, then withdrawn. 

1996 Decommissioning of four Chevron platforms begins; liability issues prevent reefing. 

1997 Interagency Decommissioning Working Group (IDWG) formed by MMS and SLC. 

 MMS/SLC Decommissioning Workshop: "Decommissioning and Removal of Oil and Gas 

 Facilities Offshore California: Recent Experiences and Future Deepwater Challenges". 

1998 Senator McPherson (R – Santa Cruz) introduces Rig-to-Reef bill (SB 2173); bill dies in the 

Senate. 

 National Oceans Conference, Monterey, CA. 

 California Artificial Reef Enhancement (CARE) organization established. 

 AB 1241: Marine Life Management Act passes (Fishery management reform, Nearshore 

 Fishery Management Act). 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

59

Table 6. California Artificial Reef Program and Rig-to-Reef Chronology (continued)

 Artificial Reef Conference (UCLA): "The Politics and Long Term Management of Essential 

 Fish Habitats, with Particular Reference to Artificial Reefs and Offshore Structures". 

1999 Senator Alpert (D - San Diego) introduces Rig-to-Reef bill (AB 241); bill held over to second 

year. 

 UC Select Committee on Decommissioning formed. 

 MMS/SLC Decommissioning Workshop: "Rigs-to-Reefs". 

 Sea Cliff Pier (offshore facility, Southern CA) decommissioned. 

 AB 993: Marine Life Protection Act passes (Marine managed areas reform). 

2000 CARP administers 35 artificial reefs. 

 West Coast Groundfish Fishery declared a disaster. 

 Clinton issues executive order calling for nationwide system of marine protected areas. 

 Belmont Island (offshore facility, Orange County, CA) decommissioned. 

 AB 241 placed on inactive file by request. 

2001 Senator Alpert (D - San Diego) reintroduces Rig-to-Reef bill (SB 1). 

 In this section, we provide 1) a brief history of the California Artificial Reef Program 

(CARP), 2) brief discussion of rig to reef proposals and related activities leading up to the 

current legislative debate, and 3) an analysis of the recent rig-to-reef policy debate in 

California. 

California's Artificial Reef Program

 California's Artificial Reef Program (CARP) has a lengthy history, dating back to 

1958, when concerns about declining ocean resource productivity and increasing demands, 

especially for sportfishing opportunities, prompted the California Department of Fish and 

Game to explore artificial reefs as a mechanism for addressing those concerns and needs. 

Over the ensuing decades, the Department oversaw research, development and monitoring of 

artificial reefs, albeit in fits and spurts as funding and political support fluctuated. It was not 

until 1985, however, the year after the passage of the National Fishing Enhancement Act, that 

the program was acknowledged by the Legislature and incorporated into the California Fish 

and Game Code (Sections 6420 - 6425). Most recently, the program's continuation has been 

called into question, as the Department's Strategic Plan does not provide explicitly for the 

program. Recent efforts to establish a state rig-to-reef program, however, might increase the 

program's profile, and the resources available to it. In the following paragraphs, we provide a 

brief history of the California Artificial Reef Program, focusing on four periods: 1) the early 

investigative period (1958-65), 2) a subsequent slow-down period (1965-80), 3) renewed 

activity (1980-1992), and 4) a recent slowdown period, but one that has seen the more serious 

introduction of rig-to-reef proposals (1992-present). 

The early investigative period: 1958-1965

 The predecessor of the present day CARP was created by the California Department of 

Fish and Game (CDFG) in 1958 as the Ocean Fish Habitat Development (OFHD) Project 

(Turner, et al. 1969). The program was initiated in response to the observation that although 

there were anecdotal reports of greatly increased sportfish yield where state and private 

agencies had placed old automobile bodies and other materials on the sea floor "barren of 

sportfish", there had been no scientific evaluation of the reefs (Carlisle, et al. 1964:6). The 

goal of the program was to conduct research on the possibility of increasing marine resource 
Final Study Report – McGinnis, Fernandez, Pomeroy 

60

production both to mitigate negative environmental impacts of growing coastal and marine 

resource use and to enhance recreational (especially) and commercial (to a lesser degree) 

fisheries (Turner, et al. 1969). The OFHD Project was designed to determine 1) the 

practicality of artificial reefs in southern California waters, 2) the best materials to use, and 3) 

the return to the fisherman (Turner et al. 1969:196). The CDFG full-time biologists and a few 

other part-time personnel were involved in this project. More generally, they were responsible 

for several tasks including planning, permitting, siting, constructing , augmenting, and 

monitoring artificial reefs. [A Marine Habitat Advisory Council, comprised of representatives 

of the petroleum industry, California Wildlife Federation, the Ocean Fish Protective 

Association, and relevant state agencies provided oversight for the part of the study that dealt 

with offshore oil drilling (Carlisle, et al. 1964:5).] 

 With financial support from the Dingell-Johnson Federal Aid in Sport Fish Restoration 

Act (SFRA) of 1950 and other sources, CDFG biologists conducted a series of studies over 

the next several years to address the need for scientific evaluation of artificial reefs in southern 

California waters. The first study, initiated in May 1958, entailed the construction of 

experimental reefs to determine the effectiveness of various reef materials for increasing 

sportfishing success. In July 1958, CDFG entered into a 3-year agreement with the Western 

Oil and Gas Association to study the effects of man-made structures and washed drill cutting 

deposits on marine life. As a result, the CDFG study entailed the monitoring both of the newly 

created artificial reefs and of selected offshore oil drilling installations (Platforms Monterey, 

Hilda, Hazel, and Rincon Islands) (Carlisle, et al. 1964). The researchers concluded that 

quarry rock was the best material for constructing artificial reefs (Carlisle, et al. 1964:73). 

With regard to offshore oil installations, they concluded that the changes in habitat brought 

about by establishing offshore oil-drilling installations were generally beneficial to the flora 

and fauna, and that depositing washed drill cuttings on the bottom at these sites was "neither 

deleterious nor beneficial to the marine life in the area" (Carlisle, et al. 1964: 73). 

 This early success led to a second set of artificial reef studies from 1960 through 1965. 

These entailed the study of three experimental, multi-component man-made reefs and one 

"production" model reef in Santa Monica Bay to further explore and determine the most 

appropriate material for artificial reefs, and to begin to address the "attraction versus 

production" question that is at the crux of many artificial reef debates. Funding support 

included SFRA funds, along with $18,000 from California's Wildlife Conservation Board, and 

$6,000 from the Los Angeles County Fish and Game Commission (Turner, et al. 1969:7). The 

researchers confirmed their previous conclusion that quarry rock is preferred material. In 

addition, they found that an ideal configuration for an artificial reef would include its being 

moderately large, with many holes and crevices, on barren substrate over large area (200,000 

ft2

), at 10 to 80 ft in depth (Turner, et al. 1969:199). They also stressed that it is critical to use 

adequate biological and physical data, and to have government supervision of artificial reef 

efforts because "other groups, no matter how well intended, are all too prone to consider only 

their own special interests" (Turner, et al. 1969:199). 

Program dormancy: 1965-1980 

 These results notwithstanding, however, program funds dropped off soon after the 

study was completed, and the program entered a 15-year period of relative quiet. Funds from 

traditional sources such as the Wildlife Conservation Board, which had helped pay for the 

construction of many artificial reefs in the early years, diminished. Staff duties were reduced 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

61

to maintaining permits and accepting materials donated for reef construction and 

augmentation (Parker personal communication). It is important, however, to note certain 

events that occurred in the broader context during this time, and how they may have related to 

the state's artificial reef program. These events included the 1969 oil platform blow-out in the 

Santa Barbara Channel, the passage of the National Environmental Policy Act in 1970, the 

Coastal Zone Management Act in 1972, and both California’s Coastal Act and the (federal) 

Fishery Conservation and Management Act in 1976. Nationwide, and arguably statewide, 

attention was re-directed toward more pressing concerns about the risks of offshore oil 

development and competition between foreign and domestic fishing fleets. 

Program Renewal: 1980-1992 

 The state's artificial reef program took another turn in 1980. As part of its mitigation 

for negative impacts of power plant discharges on nearby kelp forests, Southern California 

Edison engaged in a 6-year (1980-1986) cooperative project with CDFG for the construction 

of Pendleton Artificial Reef (in northern San Diego County) and studies to evaluate the reef's 

potential for enhancing marine resources (Lewis and McKee 1989:3). The resulting influx of 

funds and interest prompted the redirection of Sport Fish Restoration Act funds, along with 

CDFG's existing Kelp Restoration group, to the CARP. Staff was increased from three to five 

biologists, and their duties were expanded to include site selection, permitting and surveys. 

Artificial reef construction became one aspect of CDFG's Nearshore Sportfish Habitat 

Enhancement Program for restoring or enhancing sportfish habitat along the southern 

California coastline (Lewis and McKee 1989:1). The program's objective was (and still is) to 

maintain sportfishing success in the face of the cumulative effects of increasing fishing 

pressure as well as negative impacts on the nearshore ecosystem (Lewis and McKee 1989:1). 

 Although it was clear that the reefs attracted fish, there were concerns that this result 

could lead to increased local fishing pressure and resultant negative effects on populations. 

Next the program turned to an emphasis on designs that would promote production (by 

augmenting shelter and forage), as well as attraction (Lewis and McKee 1989:4). Japanese 

researchers found that high relief, open structures served best to attract fish, and better enable 

fishery exploitation (Lewis and McKee 1989:4). CDFG then sought to combine this strategy 

with one that also provided shelter and forage to increase production, with the goal of 

increasing “fish carrying capacity of selected areas" (Lewis and McKee 1989:4). 

 Five years into the renewed artificial reef program, and one year after the passage of 

the National Fisheries Enhancement Act of 1984, the California Legislature passed SB 70, 

providing legislative recognition of and support for the program (some 27 years following its 

initiation by CDFG). SB 70 added Sections 6420 through 6425 to the Fish and Game Code, 

which 1) declared the need for and potential value of an artificial reef program to enhance 

southern California marine fishes (Sec. 6420), 2) defined pertinent terms (Sec. 6421), 3) 

specified CDFG as CARP administrator and outlined the program's activities (Sec. 6422-

6423), and 4) specified current and future funding sources (Sec. 6424-6425). Of particular 

note, the legislation included a one-time appropriation of $0.5 million to augment other 

resources (including Southern California Edison, Sport Fish Restoration Act, and Wildlife 

Conservation Board funds) that supported the CARP. Soon afterward, the program received 

an increased budget, and was able to support five positions, with one group working on site 

selection and another working on surveys. In 1991, however, the program was cut back to 

three positions, and both reef construction and research were curtailed. 
Final Study Report – McGinnis, Fernandez, Pomeroy 

62

Ebb and flow: 1992 - present

Since 1992, CDFG has sponsored the construction of only one new reef, but has 

continued its permitting activities for reefs proposed by non-governmental groups, and its 

reception of augmentation materials. Most of these efforts occur near major ports, and follow 

from nearby demolition projects as a cost-saving measure (Parker personal communication). 

In recent years, sport fishing and diver interest in artificial reefs in southern California has 

grown considerably. Numerous groups have initiated reef building and augmentation projects, 

which CDFG then oversees through the permitting process and beyond. Among the most 

recent of these is the San Diego Oceans Foundation-sponsored Project Yukon, which involved 

the sinking of a decommissioned Canadian military vessel in Fall 1999. At present, CARP 

manages 35 artificial reefs (each consisting of several modules) in state waters. 

 With the recent implementation of CDFG’s Strategic Plan, resources that would have 

been directed to the CARP have been reallocated to other, more pressing needs. As a result, 

“there’s no real artificial reef program” at present. A skeleton team of CDFG biologists 

attends to permits and materials made available for augmentation, but there is no monitoring. 

(One CDFG biologist noted that such monitoring could be resumed by incorporating it with 

ongoing programs to monitor natural reefs.) Moreover, program staff say they have taken care 

not to let the state program become a waste-dumping programs; “We'll take materials and/or 

construct a reef only if it suits our needs and criteria of stability, longevity, substrate value”

(Parker, personal communication) 

 Fluctuations in the state program aside, there is a formal procedure for establishing an 

artificial reef in California waters. The applicant must obtain both federal (U.S. Army Corps 

of Engineers) and state (California Coastal Commission) permits, and a lease from the State 

Lands Commission. The applicant is responsible for completing an extensive environmental 

impact review which usually involves multiple agencies (e.g., Corps of Engineers, California 

Department of Fish and Game, U.S. Environmental Protection Agency, U.S. Coast Guard). 

The Corps of Engineers has oversight over navigational concerns while the California 

Department of Fish and Game is responsible for making sure the proposed reef complies with 

the Fish and Game Code. If the reef is proposed for state waters, it must comply with 

California Environmental Quality Act criteria, with U.S. Environmental Protection Agency 

having some authority as well. If it is proposed for federal waters, NEPA would be the 

primary guide for environmental impact assessment. Once these steps are completed, and 

other permits are in place, the proposal is submitted to the California Coastal Commission, 

which checks it for consistency with the California Coastal Act. Once the CCC grants a 

coastal development permit, it is the responsibility of the underlying property owner/project 

applicant to operate and maintain the reef. (If the reef is to be sited in federal waters, an SLC 

permit is not required, but the Coastal Commission must issue a consistency finding before 

the Army Corp of Engineers will issue a permit. Where artificial reef proposals are initiated 

by an entity other than CDFG, the Department serves as a commenting agency (Bedford 

personal communication; Ewing personal communication). 

Initial rig-to-reef efforts in California 

 The rig-to-reef option is not new to California and its artificial reef program. Proposals 

to convert platforms slated for decommissioning have been put forward intermittently since 

the 1970s. The first documented rig-to-reef proposal was entertained when Platform Harry, 

located one mile off Point Conception, was decommissioned. Although it was suggested that 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

63

some of the platform's materials be reefed, the proposal was tabled amid controversy over 

proposed relocation of parts to reefing sites (IDWG 1999a). Fourteen years later, reefing of 

decommissioned rigs was again considered, this time for Platforms Helen and Herman. As in 

1974, however, controversy over leaving parts of the platform in place resulted in complete 

removal and clean-up of the site. The rig-to-reef concept was revived in 1992, when Chevron 

moved toward decommissioning its 4H platforms (Hazel, Heidi, Hilda, Hope). However, 

CDFG determined that the rig materials were not suitable for reefing. Nonetheless, in 1994, a 

proposal was made to use portions of these structures for the construction of test reefs in the 

newly created Sycamore Canyon MRPA Ecological Reserve, but this proposal failed amid 

controversy and delays, to the dismay of southern California sport fishing and other recreation 

interests. Most recently, Exxon-Mobil's Belmont Island was proposed for reefing in 1999, but 

the SLC did not approve the plan following receipt of evidence that the area was not suitable 

for an artificial reef, as well as the recurrent problems of liability and site selection (IDWG 

2000). However concrete rip-rap surrounding the structure will be made available to CDFG 

for the enhancement of the Bolsa Chica artificial reef (IDWG 2000). 

 Chevron's 1992 proposed decommissionings served as a catalyst for more directed 

attention toward decommissioning issues and options, including rigs-to-reefs, for California’s 

offshore platforms. The Minerals Management Service and the California State Lands 

Commission (SLC) have jointly sponsored public workshops: "Abandonment and Removal of 

Offshore Oil and Gas Facilities: Education and Information Transfer" in 1994, 

"Decommissioning and Removal of Oil and Gas Facilities Offshore California: Recent 

Experiences and Future Deepwater Challenges" in 1997, and a Rigs-to-reefs Workshop in 

1999. Pursuant to the 1997 meeting, the MMS and the SLC convened an Interagency 

Decommissioning Working Group (IDWG) to facilitate communication among the relevant 

local, state and federal agencies. The group meets three to four times a year, and serves as a 

clearinghouse of information for its member agencies. In 1999, the IDWG released a draft 

Action Plan. The Action Plan was prepared to “guide agency efforts in addressing the 

technical, environmental, disposition, and site clearance issues associated with 

decommissioning operations” (IDWG 1999b:1). The Plan does not address or resolve policy 

issues, but identifies information needs relative to the selected policy issues the group can 

address (IDWG 1999b:1). (Existing law already allocates much authority to individual 

agencies.) The Plan identified five categories of issues: technical, environmental, disposition, 

site clearance and policy, with numerous separate issues falling within each of these 

categories. Over the next three years, the IDWG is to collect, synthesize and disseminate 

relevant information, and coordinate issue-specific forums to facilitate communication among 

parties interested in decommissioning. 

 In addition to these agency-sponsored efforts, there have been meetings and other 

events sponsored by the University of California, Los Angeles and other non-governmental 

groups to consider, and in some cases actively promote, rigs-to-reefs for California. In 

December 1998, UCLA convened a meeting “to discuss the issue of whether a “Rigs-toReefs” program was of potential value for the southern California area.” (Hamner 1999). 

Various interests in the rig-to-reef debate participated in the meeting, and included 

representatives of the American Sportfishing Association, the San Diego Oceans Foundation, 

the Professional Association of Diving Instructors, Proteus SeaFarms International, the 

California Sea Grant Extension Program, a commercial fisherman, the Center for Marine 
Final Study Report – McGinnis, Fernandez, Pomeroy 

64

Conservation , the Environmental Defense Center and the United Anglers of Southern 

California/American Sportfishing Association Conservation Coordinating Committee. In 

Spring 1999, the Southern California Academy of Sciences’ Annual Meeting included a 

Symposium on Artificial Reefs, which included scientific and interest group presentations on 

the rigs as potential reef sites/materials. 

 Throughout, attention has focused upon a number of scientific, technical and 

institutional issues. These include: 1) whether rigs actually enhance, or simply attract reef 

fishes; 2) the net ecological benefits or costs of removal and of reefing; 3) the practicality of 

removal and of reefing, especially involving rigs in very deep waters; 4) concerns for 

navigational safety; 5) interference with other ocean uses; 6) funding to support maintenance 

and monitoring as well as initial reefing; and 7) liability, among others. Recent rig-to-reef 

policy proposals manifest in legislation first introduced in 1998, then re-introduced in 1999 

and 2000, have sought to address many of these issues. And this is where the state’s artificial 

reef program and the rig-to-reef concept have become intertwined. 

California’s rig-to-reef policy debate 

 We can use Kingdon's (1984) model of the policy process to consider the current 

debate over rigs-to-reefs in California. As the current California Legislative session comes to 

a close, the most recent rig-to-reef program proposal, in the form of Senate Bill 241 (Alpert), 

has been placed on inactive status. That action, effectively tabling the notion for another 

several months, is the outcome (to this point) of convergent - and divergent - events in the 

problem, policy and political streams identified by Kingdon (1995). In the following pages, 

we illuminate this situation. 

The Problem Stream 

 According to Kingdon(1995), problems needing attention are brought to the attention 

of policy makers with the aid of systematic indicators, focusing events, and feedback from the 

operation of current programs. We would argue that there are two problems that have been 

brought to the attention of policy makers that are germane to the rig-to-reef debate. The first 

follows from the recognition that many of the oil and gas platforms offshore California are 

nearing the end of their productive life as sources of oil and gas. The problem lies in the 

debate that has arisen around the disposition of the rigs, specifically whether they should be 

removed or left in place to serve as artificial reefs. On the one hand, original leases require the 

complete removal of the rigs. On the other hand, there are three factors - not fully anticipated 

when the rigs were installed - that suggest potential problems or drawbacks to rig removal. 

These are: 1) the high cost of platform removal, 2) the risk of releasing presently concealed 

contaminants (e.g., encased in shell mounds that have accumulated around rig legs) into the 

marine environment, and 3) the rigs' value to some resource users and perhaps to the marine 

environment as habitat for several commercially and recreationally important species and 

other marine life. Although the first of these is a problem of the lessees, and therefore less a 

public policy issue, the latter two fall clearly within the public interest. Yet while the idea of a 

rig-to-reef program might appeal to some sectors of the public, the first dampens that interest. 

Moreover, the relatively long time (5 to 20 years) before decommissioning is to begin detracts 

from its salience when so many other issues are more compelling. This became evident in 

1998 when the first rig-to-reef bill (SB 2173, McPherson) was introduced into, then abruptly 

withdrawn from, the California Legislature. According to legislative staff members, the 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

65

Senator did not anticipate the extent to which the bill appeared to be exclusively directed 

toward certain special interests, nor the extent to which the environmental community and 

other groups would oppose it. 

 The second problem complements, and provides a broader and more compelling case 

for considering rigs-to-reefs. The rigs serve as habitat for a diversity of marine species, 

including juvenile and adult rockfishes (Sebastes spp.). Declines in many of these species, and 

critical concerns for the health of their stocks were, in part, the basis for the January 2000 

declaration of the "Federal Groundfish Disaster" (US Department of Commerce Press 

Release). The disaster declaration was a focusing event that brought the problem of declining 

rockfish stocks in the southern California Bight and throughout much of the U.S. west coast 

into sharp relief for policy makers and the broader public. 

 These two problems have converged to help bring rig-to-reef policy proposals to the 

fore, although it is the latter that has made a compelling case for the continued and expanded 

consideration of a California rig-to-reef program. Indeed, SB 241, through several iterations, 

was reshaped to address these two interdependent issues. (See below.) 

The Policy Stream 

 The policy stream is the setting in which policy proposals are generated by a process 

"like natural selection in biology," through which they "float, combine and recombine with 

one another" (Kingdon 1995). Ultimately, the survival of a policy proposal is contingent upon 

its technical feasibility, its value acceptability and the extent to which it is expected to not be 

overcome by budget or political constraints over the longer term (Kingdon 1995). 

 Rig-to-reef policy proposals for California have moved through such a policy stream. 

Moreover, the rig-to-reef proposals have combined and recombined with other proposals, 

namely those directed toward restoring and enhancing southern California fish stocks and 

opportunities for their use, especially by (consumptive and non-consumptive) recreationalists. 

 The first bill to propose rigs-to-reefs for California was SB 2173, introduced by 

Senator Bruce McPherson in February 1998. Entitled "Artificial Reefs", it was cast as a 

proposal to extend the state's artificial reef program to the Outer Continental Shelf off the 

California coast. As introduced, the bill cited declines in southern California's marine species 

and their adverse effects on the state's recreational and commercial fishing industries as the 

basis for expansion of the state's artificial reef program, both within state waters and into 

federal waters. Moreover, it declared artificial reefs' ability to duplicate natural conditions and 

induce production. 

 Neither of these arguments, however, proved convincing. They were struck from an 

early version of the bill, the arguments were recast, and new provisions were added. The 

amended bill cited instead the "diverse values " of southern California's marine resources, and 

highlighted the value of commercial and especially sport fishing to the state economy. It 

declared the need to prevent overfishing, facilitate resource protection, and foster growth in 

coastal and marine tourism. Artificial reefs were recast as a mechanism for facilitating 

protection, enhancing diversity, increasing production, and improving fishing opportunities. 

 SB 2173 addressed the technical feasibility of a rig-to-reef policy (without naming it as 

such) in several ways. It highlighted the state artificial reef program's 40-year history of 

construction, research and management as an indication of its capability to effectively carry 

out the proposed expanded activities. The bill also cited the National Fishing Enhancement 

Act of 1984, which provided for the establishment of artificial reefs in OCS waters. It also 
Final Study Report – McGinnis, Fernandez, Pomeroy 

66

provided for the development of artificial reef program elements to address other technical 

aspects, including the determination of design criteria for increasing biomass of marine flora 

and fauna, the specification of siting and placement requirements, and the development of 

mechanisms for program planning, coordination, management and evaluation; monitoring and 

enforcement; environmental impact assessment and compliance, and damage assessment. 

 The McPherson proposal appealed to certain values in the broader political arena, 

namely the value of living marine resources to the people of California, and the value of 

sustainable fisheries - especially recreational fisheries. It asserted the value of artificial reefs 

as duplicating natural conditions, and their potential for facilitating habitat protection, 

enhancing diversity, increasing production and improving fishing opportunities. Moreover, it 

precluded the transfer of liability from offshore platform owners and operators to the state, a 

critical issue of public concern. 

 Provision also was made to limit the likelihood that the proposed policy would be 

overcome by budget or political constraints over the longer term. Key provisions to address 

this concern included the removal of language from the California Fish and Game Code that 

appropriated $500,000 to the artificial reef program in 1985 [Fish and Game Code 6425 (a)]; 

and the creation of an Artificial Reef Program Account within the Fish and Game Preservation 

Fund (FGPF) and a Marine Preservation Endowment Fund. The one-time $500,000 legislative 

appropriation for the artificial reef program was made in 1985, but its persistence in the codes 

could be used as a constraint on subsequent program funding; striking it from the codes 

diminishes this likelihood. The importance of doing so lies in the uncertainty of costs of an 

expanded artificial reef program, especially one that extends into federal waters offshore 

California. The establishment of a dedicated account for the artificial reef program addressed 

not only funding needs of a rig-to-reef program, but also long-standing funding problems for 

the state's artificial reef program. The establishment of dedicated accounts within the FGPF is 

a recurrent issue in California; monies generated by specific resource uses otherwise go to the 

General Fund, from which they are then allocated to those issues or resource uses that are 

politically salient or popular, to the neglect of other, less visible, yet important programs. 

In addition to the development of a dedicated artificial reef program account, the bill 

created a supplementary fund, the Marine Preservation Endowment Fund (MPEF). The fund 

was to be administered by the California Endowment for the Preservation of Marine 

Resources (whose members were to be appointed by leaders in the Legislature), which would 

receive and disburse cost savings from offshore platform and facility conversion to artificial 

reefs. The bill specified that an owner/operator would be required to contribute 10% of cost 

savings from converting an offshore platform to an artificial reef to both the MPEF and the 

ARP Account. Touching on the critical issue of liability, the bill provided for 50% of any cost 

savings to be apportioned among these funds, should CDFG assume full liability, control and 

management for such an artificial reef. 

 All of these provisions notwithstanding, SB 2173 died only four months into the 1998 

legislative session. (The bill text was replaced by an entirely different measure, on 

employment application fees.) The policy proposal, however, did not die. It was revived and 

re-introduced by Senator Dede Alpert at the beginning of the next legislative session in 

January 1999. It made little progress in the legislative process initially, and was tabled in April 

1999. In December 1999, however, it was revived again by its author, and reintroduced with 

significant amendments in January 2000. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

67

 SB 241, entitled "Decommissioned oil platforms and production facilities: California 

Endowment for Marine Preservation", was very similar to its predecessor in some respects, 

but also reflected greater attention to issues of technical feasibility, value acceptability and 

resistance to budget and political constraints over the long term. The issue of technical 

feasibility was addressed with declarations that rigs-to-reefs had already been considered 

within the state, paving the way for its institutionalization; and that artificial reef management 

would best be done by the California Department of Fish and Game (CDFG) with the 

assistance of other institutions. This declaration and associated provisions reduced the 

potential burden on CDFG, and called attention to the relevance of other sources of technical 

support. In doing so, it also suggested that these other institutions might partake of the 

benefits (e.g., Fund monies to support artificial reef research, monitoring and management) 

should the policy proposal be enacted. In an effort to bolster this notion, as well as the 

viability of the bill itself, Senator Alpert requested assistance from the state university system 

in convening a "Blue Ribbon Panel" to identify the scientific questions to be resolved, 

evaluate existing data on potential ecological and environmental consequences of 

decommissioning alternatives, and identify uncertainties regarding such assessments. 

 SB 241 also differed notably from SB 2173 in its attention to other agencies (e.g., the 

State Lands Commission, the California Coastal Commission, the Bay Conservation and 

Development Commission) and laws (e.g., the California Environmental Quality Act, the 

federal Clean Water Act), and the value of interagency coordination on artificial reef siting 

and management. Concerns for technical feasibility were further addressed by the funding 

mechanism, under which cost savings to be contributed to the program fund (see below) 

would increase as a function of water depth, thereby providing greater funds to match (or 

parallel) greater costs of platform removal from or maintenance as an artificial reef in deeper 

waters. 

 Another aspect of technical feasibility pertains to the converted rigs' potential for 

serving the goals of the state's artificial reef program, especially that of biomass production 

rather than simply attraction. The attraction versus production debate has been a critical issue 

in the debate over artificial reefs in general, and has been a focus of the state program's 

research - and its permitting criteria - since the 1960s. There are two dimensions to this issue: 

determining what materials are conducive to production (and perhaps protection) rather than 

attraction, and insuring that such reefs do not increase target species' vulnerability to 

overfishing by concentrating fishing effort in key habitats. SB 241 sought to address the first 

concern by noting that the rigs are already serving as artificial reefs, and by requiring that new 

artificial reefs be constructed of materials allowed by the NFEA (under the assumption that 

these are materials determined to afford production) - which include offshore oil platform 

materials. Moreover, by requiring that CDFG designate rigs converted to reefs as marine 

reserves (i.e., no-take marine protected areas, with a surrounding buffer), SB 241 addressed 

both of the foregoing concerns. This latter requirement implicitly linked the proposed rig-toreef program to the state's marine managed area system, suggesting the possibility of 

additional technical (and political) support for the proposal. 

 SB 241's marine reserve requirement also constituted an appeal to emerging values 

among the California public, as did several other provisions in the bill. By requiring that rigto-reef sites become marine reserves, SB 241 broadened its appeal beyond that of SB 2173, 

which had been directed toward the more narrow interests of recreational fishing and tourism 
Final Study Report – McGinnis, Fernandez, Pomeroy 

68

in southern California. While such a provision may have alienated a subset of recreational 

fishermen in southern California, it expanded its realm of likely supporters to broader interests 

within southern California and statewide. As a marine reserve, a rig-to-reef would contribute 

to coastwide efforts to protect and restore the marine environment and fisheries. SB 241 

highlighted the cost savings to be realized by rig-to-reef conversion, and asserted that those 

savings should be shared with the citizens the state, not just recreational users in southern 

California. 

 The bill's provision of funding mechanism based on these cost savings is one element 

of the proposal directed toward insuring its long term fiscal viability. As noted above, the bill 

required that a portion of the cost savings, to be calculated based on the platform's depth, be 

split between a newly created Artificial Reef Endowment Fund (AREF) and CDFG. Unlike 

SB 2173, the bill failed to specify that formula, perhaps raising questions as to whether the 

resulting funds would be sufficient to cover program costs. (SB 241's program element are the 

same as those articulated in SB 2173.) Like SB 2173, however, it also would have struck the 

1985 allocation from the Fish and Game Code, thereby helping to guard against the program's 

vulnerability to budgetary and political constraints in the future. SB 241's explicit recognition 

and encouragement of continued interagency coordination on artificial reef and rig-to-reef 

matters (noted above) also served this purpose. 

The Political Stream 

 The political stream, broadly construed, refers to the political climate into which a 

policy proposal is introduced. The political stream is influenced by swings in national, state 

and local mood, elections, party control of the legislative and executive branches, the 

composition of key committees, the degree of interest and commitment of congressional 

leaders, and interest group pressure campaigns. To uncover some of these influences, it is 

helpful to look at the different sets of actors engaged in the policy process, the positions they 

have taken and the roles they have played as the policy situation has played out. 

Sportfishing and other recreational interests 

 California hosts extensive sportfishing and other marine recreational activities 

statewide, but especially in southern California (i.e., south of Pt. Conception) (McWilliams 

and Goldman 1994). Sportfishing takes place from beaches and piers on the mainland, and 

from private and commercial passenger fishing vessels (CPFVs)]. Other, non-consumptive 

recreational activities include diving, pleasure boating and nature tourism. 

 These interests have been active in southern California resource enhancement and 

management for decades. They are acknowledged for their contributions to the state’s 

artificial reef programs since the 1950s, and have continued to donate time , materials and 

other resources to support the state’s artificial reef program (e.g., Carlisle et al. 1964, Turner 

et al. 1969; McKee and Lewis 1989). 

 Most recently, many of them have become strong advocates of a rig-to-reef policy for 

California. Their interests and arguments for a state rig-to-reef program are noted in 

transcripts of the December 1998 UCLA-sponsored conference on rigs-to-reefs. For example, 

Bill Shedd of the American Sportfishing Association noted the sportfishing community’s 

concerns that “the 4H Rigs were decommissioned prematurely and that a tremendous 

opportunity to benefit natural marine resources was lost...With so little hard bottom in 

Southern California we can’t afford to waste valuable habitat, as with the 4H Rigs removal.”

Vishwanie Maharaj of the American Sportfishing Association highlighted declines in 
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69

Southern California saltwater anglers from 1994 to 1997 as a loss of potentially valuable 

economic inputs that could be realized with the enhancement of fishing opportunities through 

a rig-to-reef program. Similarly, Kristin Valette, of the Professional Association of Diving 

Instructors, noted the potential for increased recreational activity, and economic benefits of 

associated tourism for southern California communities. 

 As rig-to-reef policy proposals, SB 2173 and its successor, SB 241, have received 

growing support of this interest group, starting with United Anglers and the Channel Islands 

Council of Divers in 1998, and expanding to include the Sportfishing Association of 

California, the Recreational Fishing Alliance, the San Diego Oceans Foundation, San 

Francisco Reef Divers, among others, as SB 241 moved through the legislature in 1999 and 

2000. 

The Offshore Oil Industry 

 Like sportfishing and recreational interests just noted, the oil industry has a keen 

interest in the development of a rig-to-reef policy in California, both as a cost-savings 

mechanism and as an opportunity for promoting its image as an environmental steward or 

benefactor. As noted above, the industry has a long history of working with CDFG in its 

artificial reef monitoring studies. Moreover, it has long sought reefing as a decommissioning 

options for some of its platforms. At present, the most visible industry actor is Chevron, 

which played a large role in drafting SB 2173 and later officially supported SB 241. 

 Moreover, Chevron has provided seed funding to two non-profit organizations, 

California Artificial Reef Enhancement (CARE) and the Coalition for Enhanced Marine 

Resources (CEMR). The purpose of CARE, whose board of directors includes the various rigto-reef proponents noted above, is to facilitate and disseminate information on artificial reefs 

and their role in the marine ecosystem. As noted in CARE's literature, the organization will 

"work in tandem with the Blue Ribbon Committee (coordinated by the University of 

California) and the general public, to systematically address scientific questions on artificial 

reefs." The purpose of CEMR is to advocate for the development of a state rig-to-reef 

program. 

Commercial Fisheries 

 Commercial fishermen, in general, have been strongly opposed to the rig-to-reef 

option. In the mid-1990s, Richards and colleagues interviewed southern California 

commercial fishermen to ascertain their views on and preferences for various 

decommissioning options (Richards et al. 1998). Although there were some differences of 

opinion among gear types, fishermen from all gear types strongly favored full removal of 

platforms and associated debris over all other options. The option of moving the platform 

jacket to an existing artificial reef site was considered a possible option by most fishermen. A 

preferred alternative (over the latter, not the former) was non-removal with multiple use. 

Richards notes, “Non-removable, in fact, was preferred by nearly all of the fishermen 

interviewed, if one or two platforms were carefully selected to serve as weather stations.” 

 Southern California’s commercial fishermen have long resisted rigs-to-reefs. Trawlers, 

in particular, have been strongly opposed to rigs-to-reefs. They cite assurances made to them 

by the offshore oil industry and the agencies involved that once production ceased, offshore 

platforms and all associated materials would be completely removed, and their traditional 

fishing grounds would be restored. Although they argue that they have experienced negative 
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70

socio-economic impacts as a result of offshore oil and gas activity, Senator Alpert questions 

the veracity of such claims, following CDFG analysis of the fishery that "failed to demonstrate 

a clear negative impact of oil platforms in the general catch areas reported on commercial 

trawl logs" (Senate Natural Resources and Wildlife Committee 2000). Although the Southern 

California Trawlers Association has been perhaps the most vocal on this topic, other 

commercial fishing interests have also expressed their opposition to such a policy. 

 There have been two exceptions to this stance. The first is the position of Santa 

Barbara and Ventura Country lobster fishermen, who favored the reefing of Rincon Island, 

and have noted the value of selected offshore pipelines as abalone habitat. On the other hand, 

these fishermen raise a broader issue regarding permit obligations and compliance: "In most 

[fishermen's] minds, they're concerned that there's not going to be some kind of double 

standard there where we have to take care of our permits, and we have to be accountable for 

our impacts on the habitat and that there's somehow a lot more flexibility for the oil 

companies" (IDWG 1999a). 

 The second, and more generalized exception is found in mariculture interests, who 

view the rigs as potential sites of operation. At the 1998 UCLA Rigs-To-Reefs Conference, 

Thomas McCormick of Proteus SeaFarms cited several benefits of offshore platforms to 

offshore aquaculture, as they can provide secure mooring for cage systems, house centralized 

feeding systems, serve as a navigational aid, provide shelter for maintenance workers, and 

house watchmen and hatchery operations. 

Environmental and Resource Conservation Interests 

“Environmental” interests have long been involved in the debate over offshore oil and 

gas development, and continue their efforts in the context of decommissioning. But their 

positions on the decommissioning and rig-to-reef issue vary. The Center for Marine 

Conservation, a national organization with a strong presence in California, has taken a “wait 

and see” stance on rigs-to-reefs. In his UCLA Conference presentation, CMC’s Warner 

Chabot suggested 1) there was “no need to rush” into legislation until fundamental legal, 

technical and scientific questions regarding rigs-to-reefs could be addressed and policy 

options could be developed, 2) the need for “some agreement of...further knowledge on some 

of the basic scientific questions [e.g., production versus attraction]” and 3) seeking political 

consensus rather than risk further polarization on the issue. (He cited the social capital 

required and reinforced by the recent passage of AB 1241, the Marine Life Management Act, 

and the potential risk to that capital of pursuing rig-to-reef legislation.) A more staunch 

opponent of rig-to-reef proposals is the Santa Barbara-based Environmental Defense Center 

(EDC). EDC, an environmental law firm known for its "environmentalist" stance against rigto-reefs, supports a “cautious, deliberative approach.” It's key concerns focus on long-term 

environmental impacts of leaving the rigs in place, liability and financial issues. Several other 

environmental/conservation organizations (e.g., Sierra Club, Vote the Coast, Surfrider 

Foundation, California Coastkeeper) have weighed in on the issue as well, primarily in 

opposition to SB 241. A notable exception was the Sea Shepard Conservation Society, which 

enlisted itself among the bill’s supporters. 

Federal agencies 

 In addition to the Minerals Management Service, the U.S. Army Corps of Engineers 

and the National Marine Fisheries Service (NMFS) have participated in the rig-to-reef policy 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

71

debate. The Corps' jurisdiction over projects within state waters is comprehensive, but extends 

also to seabed construction in federal waters (pursuant to the NFEA), and pertains to both 

navigation and water quality issues. NMFS' interest in the rig-to-reef debate stems from its 

general responsibilities for the conservation and management of living marine resources, 

together with its specific interest in groundfish resource management and essential fish 

habitat. As of 1999, the agency's Southwest Regional Office did not hold a position on the 

issue, but "is more inclined to support original agreements between industry and the public 

regarding removal once operations become unproductive" (IDWG 1999a). 

State Natural Resource Agencies 

 Three key state agencies play a role in the rig-to-reef debate: the Department of Fish 

and Game (CDFG), the State Lands Commission (SLC), and the Coastal Commission (CCC). 

These agencies come to the rig-to-reef debate after decades of artificial reef and offshore oil 

platform experience. CDFG, whose artificial reef program stands to be enhanced (though 

perhaps also burdened) by the programs proposed in SB 241, nonetheless has been firm in its 

concerns about program costs, liability and the appropriateness of rig materials for reefing. In 

its 1999 white paper on the issue, as well as its co-sponsorship of the IDWG and associated 

workshops, the SLC demonstrates its interest in the rig-to-reef option, but also highlights 

critical permitting, scientific, technical and institutional issues that must be resolved for such a 

program to move forward successfully. The CCC has been more reserved on the matter. 

According to a December 1999 memo from CCC Executive Director Pete Douglas to the 

SLC, it is the opinion of the CCC that "the jury is still out" on many of the scientific questions 

associated with artificial reefs in general and rigs-to-reefs in particular, such as "whether these 

structures constitute good habitat with diverse and robust habitat values and function to 

actually increase the regional abundance of fish populations or where they are primarily fishattractive devices" (IDWG 1999a). The CCC anticipates receiving "substantial new 

information about the nature of artificial offshore structures and their habitat values" through 

its involvement in the Southern California Edison artificial reef project, which will be useful 

to the further consideration of rig-to-reef policy for the state. He also noted that any proposal 

to partially demolish an offshore oil platform or other structure and leave it in place would 

require regulatory review and approval pursuant to the Coastal Act. 

Cities and Counties

Several south central and southern California counties have a stake in the rig-to-reef 

debate as Responsible Parties under CEQA and NEPA because of the onshore components of 

offshore production facilities and the potential impacts of their decommissioning. Yet their 

positions diverge from one another. Whereas the Cities of San Diego and Newport Beach 

supported SB 241, Santa Barbara County opposed it, in keeping with a history of concern 

about offshore oil and gas development. At the 1999 Rigs-To-Reefs Workshop, the county 

representative noted the county's interest in "substantial scientific evidence of public and 

environmental benefit and the absence of any potential future environmental impacts" (IDWG 

1999a). 

The Window of Opportunity 

 A "window of opportunity" opened in late 1999, allowing for the re-introduction and 

serious consideration of a rigs-to-reefs policy proposal for California. Within the problem 

stream, private concerns about the costs of removing offshore oil platforms and recreational 
Final Study Report – McGinnis, Fernandez, Pomeroy 

72

user groups' interests in enhanced recreational opportunities were augmented by public 

concerns about precipitous resource declines of some southern California marine fishes, made 

especially cogent by the state push for a nearshore fishery management plan and the 

subsequent declaration of a western groundfish disaster. In the politics stream, these concerns 

led to growing interest in marine resource restoration by "natural" means (e.g., marine 

reserves) and by artificial means (e.g., artificial reefs) at the local, state and federal levels. 

Within the state, decommissioning discussions picked up, with new coalitions formed and old 

ones revived between the offshore oil industry and recreational interests on the one hand, and 

environmental and commercial fishing interests on the other hand. Meanwhile, the state's once 

vibrant artificial reef program had been reduced, for lack of funding and political support, to a 

bare minimum of activity. 

 Although the original rigs-to-reefs policy proposal as articulated in SB 2173 did not 

succeed, it did present a solution, albeit and imperfect and incomplete one, for the ecological 

and economic problems not fully identified or reckoned with at the time of its introduction. 

The growth in public concern for the marine environment between the time of its introduction 

in early 1998 and it's re-introduction in 1999 (and 2000) led to the clear identification of the 

problems a rig-to-reef program could help to address. During that time, the proposal was reshaped to address some of its deficiencies, and over its two year course through the legislature 

as SB 241, it underwent further refinement to address critical issues including program 

funding, scientific merit and liability. Moreover, it was reshaped to mesh with state and 

federal fishery (and other marine) management resource management, especially recent policy 

changes and new concepts pertaining to marine resource restoration, marine reserves, and 

essential fish habitat. 

 Yet the rig-to-reef policy proposal embodied in SB 241 has fallen short in meeting 

these and other myriad concerns. Uncertainties regarding liability issues, start-up and ongoing 

funding, and the scientific merits of such a policy, together with strong opposition from 

certain interests proved insurmountable. The increased attention to problems in the marine 

environment and rigs-to-reefs as a policy solution, and the active debate of liability, funding 

and ecological impact concerns, however, have likely prompted policy entrepreneurs to seek 

solutions to those issues, and incorporate them into a revised policy proposal, ready for the 

next window of opportunity. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

73

SECTION FIVE 

SETTING THE RIGS-TO-REEFS POLICY AGENDA: 

THE CASE OF THE GULF EXPERIENCE 

By Michael Vincent McGinnis and Carla Navarro 

 This section describes how and why the idea of the rigs-to-reefs policy evolved in the 

distinct political, intergovernmental, regional and ecological context of the Gulf. The 

political, problem and policy streams met to form a policy window of opportunity. Various 

policy entrepreneurs from the MMS, oil and fishery industries, and others advocated the idea 

of a rigs-to-reefs alternative to complete removal of Gulf OCS oil rigs (Reggio 1987a, b; 

Reggio and Kasprzak 1991; Murray 1994). Reggio, from the Gulf Region of the MMS, and 

Kasprzak, from the Louisiana State University, (1991: 15) explain: 

[T]here are ever increasing demands on marine fish and restrictions on fishing. 

Through state and industry leadership, we have an unprecedented opportunity 

in the Gulf of Mexico to create artificial reefs with oil and gas structures, 

which will concentrate marine life and enhance fishing. 

In contrast to the scientific and political debates in California over the future of OCS 

oil rigs described in Section Three, the perceived problem was not whether the oil rig 

produced or attracted fish. The attraction versus production debate was not resolved before 

the passage of the National Fisheries Enhancement Act (NFEA). This question remains an 

important concern of state artificial reef managers (Murray 1994). In an analysis of state 

artificial reef programs, Murray (1994: 960) argues, “The National Artificial Reef Plan of 

1985 suggested that states should play a major role in the development of guidelines for 

artificial reefs. However, most coastal states have not established clear artificial reef 

development plans that consider social, economic, environmental and biological factors 

associated with their artificial reef programs.”

In general, the development of the rigs to artificial reef programs in the Gulf serves the 

need of the recreational and commercial fishing industries. The significant development of oil 

on the Texas-Louisiana OCS created a web of artificial “habitats” for marine species that are 

harvested by the commercial and recreational fishing industries. Given the perceived “lack of 

natural habitat” in the Gulf OCS, removal of offshore rigs would have associated economic 

impacts (and potential ecological impacts) to these fishery industries. Removal of a rig would 

mean the removal of a “fishing hole”, such as the removal of the “best Snapper Fishery in 

World” offshore Alabama (a state with very little natural reef fish habitat). The Gulf’s 

commercial and recreational fishery industries are the largest in the US. 

Gulf offshore oil production is analogous to the creation of the “organic machine”. 

The long history of large-scale OCS oil and gas activity in the Gulf has led to “overadaptation” to these rigs as fishery enhancement structures. 

Why was complete removal of offshore rigs a “perceived problem”? There are many 

reasons, some of which are introduced below: 

• Field studies show the lack of “natural” habitat for fish in the Gulf region. Field 

studies also show the link between offshore rigs and marine life, including 

commercially and recreationally valuable fisheries and oysters. 

• Social scientists show the link (in terms of recreation days and levels of use) 

between offshore rigs and sports fishing. State, regional and local economies 
Final Study Report – McGinnis, Fernandez, Pomeroy 

74

benefit from offshore oil and gas activity, and artificial reef building (in Florida, 

Alabama, Louisiana, Mississippi, and Texas). 

• In the Gulf, commercial and recreational fishery groups have been receptive to the 

oil industry (Freudenberg and Gramling 1994; Gramling 1996). Special interests 

in the Gulf sought out a Federal OCS policy that could provide guidance, 

coordinate local, state, and federals efforts as well as streamline the permitting 

process for the rigs-to-reefs alternative. 

• Gulf state governments had artificial reef programs in place, many of which were 

operated by local and regional administrators on a part-time basis or as volunteers. 

There was no major state-based funding or private source to develop and 

implement artificial reef programs. Alabama established the first program in the 

Gulf of Mexico in 1954. Alabama’s program started with the sinking of 250 car 

bodies and now includes several thousand individual artificial reefs in state waters 

(Harrison 2000). 

• A number of policy entrepreneurs and advocates campaigned for the rigs-to-reefs 

alternative, basing their preferences on available scientific information, and fishery 

values associated with offshore structures. 

 The passage of the National Fisheries Enhancement Act (NFEA) was followed by the 

creation of formal state artificial reef programs in Louisiana (1986), Texas (1989), Florida 

(1990), and Mississippi (1999). 

The Problem Stream: The Perceived Lack of “Natural” Habitat 

The reliance of commercial and recreational fishers on OCS oil and gas structures 

contributed to a perceived problem --- complete removal of structures would have significant 

economic impacts on the fishery industries. Policy entrepreneurs defined the problem based 

on the perceived lack of natural fishery habitat in the Gulf, and the link between the 

development of offshore oil and commercial and recreational fishing. As Villere Reggio, Jr. 

(1987: 2) from the MMS, Gulf of Mexico Region, writes, “Since the inception of the federal 

offshore leasing program in 1954, the Gulf of Mexico OCS Region has led the nation in 

offshore energy production and has retained its pre-eminence in offshore fishery production.” 

The ecology of the Gulf, the history of Gulf OCS oil development, the relationship between 

offshore oil development and fishing (such as commercial hook-and-line fishing) and scuba 

diving were also factors associated with the problem stream. 

The Ecology of the Gulf 

The Gulf of Mexico is a semi-enclosed oceanic basin that is bound by the North 

American continent and Cuba. It stretches nearly 900 km from north to south and 

approximately 1595 km from east to west with a total surface area of 564,200 km2 (Darnell 

and Defenbaugh 1990). Driven by offshore winds, warm tropical and subtropical Caribbean 

waters enter through the Yucatan Channel (176 km wide) into the eastern portion of the Gulf 

(Darnell and Defenbaugh 1990). Larvae, juveniles, spores, pelagic fishes and plant materials 

are transported into the eastern Gulf, and become part of the Gulf stream (Rezak, et al. 1990). 

The Gulf basin was created by sea floor spreading and seismic faulting in preCretaceous time (240-170 million years ago) during the Permian and early Jurassic period 

(Darnell and Defenbaugh 1990). The continued accumulation of sedimentary layers since the 

beginning of the Tertiary period created a continental slope (0 to 200 m) that now makes up 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

75

nearly 35% of the bottom habitat, with 25% being very deep water (>3000 m) and reaching a 

maximum depth of 3850 meters (Darnell and Defenbaugh 1990). 

The northern shelf and slope offshore Texas and Louisiana receive extensive 

accumulations of sediment from stream, estuarine, and river discharges. River-borne 

sediments composed of silt, sand, clay and anthropogenic pollutants create a soft bottom 

habitat that stretches from the coastline to the middle and outer shelf off most of Louisiana 

and Texas (Darnell and Defenbaugh 1990). In some areas, the sediment is over 17 km thick, 

creating an unconsolidated and unstable benthos that tends to slump into the deep Gulf waters 

(Darnall and Defenbaugh 1990). 

Biological production is generally high near river outfall areas that deliver nutrients 

directly into coastal waters. The Mississippi River accounts for nearly 64% of the freshwater 

input into the Northern Gulf, bringing a high annual volume (4.1 x 10^8 metric tons) of 

sediments, nutrients and anthropogenic pollutants to the delta and the surrounding continental 

shelf (Darnell and Defenbaugh 1990). The Texas-Louisiana shelf experiences annual hypoxic 

episodes during the summer months (June to August) when river-borne nutrients cause 

phytoplankton blooms and subsequent biological decomposition starves surrounding bottom 

waters of essential dissolved oxygen. More importantly for offshore development, the delta 

supplies silt and mud to the broad, flat shelf area where many offshore structures are located. 

Although occasional small shoals and rocky ridges occur throughout the Gulf OCS, 

the broad and vast area is relatively barren with little habitat diversity. Only one-third of the 

natural reef habitat estimates are located offshore Texas and Louisiana where more than 95% 

of the platforms stand. The nearest natural hard-bottom habitat is located approximately 92 

km offshore Louisiana (Sonnier, et al. 1976). 

The History of Oil Development 

Texas and Louisiana initiated offshore oil and gas development in the Gulf region19 in 

lease sales in 1920 and 1922, respectively (Howe 1985; Wermund 1985). These leases were 

developed two decades later. On August 14, 1945, the Louisiana Minerals Board held its 

second lease sale (Howe 1985). Kerr-McGee acquired 43,000 acres in shallow water, nearly 

43 miles south of Morgan City, Louisiana. In 1947, Kerr-McGee drilled the first 

commercially successful offshore well in 18 feet of water, and approximately eleven miles 

from shore (Howe 1985). 

Gulf OCS oil and gas activity intensified in the 1940s and 1950s (Blalock 1985; Howe 

1985; Miller 1985; Wermund 1985). From 1942 to 1999, more than 5700 platforms were 

installed in the Gulf OCS compared to 24 in the Pacific OCS. By 200020, the Gulf of Mexico 

OCS (eastern, central, and western regions) had a total of 7,595 active leases covering 

7,612,048 producing acres (MMS 2000). Today, well drilling is occurring in over 8,000 feet 

of water (Villere, personal correspondence, 2001). 

Table 7 identifies the installation and removal of production platforms on the OCS. 

 

19 For a complete review of the history and politics of offshore oil development in the Gulf of Mexico, see W.R. 

Freudenberg and R. Grambling, Oil in Troubled Waters (State University of New York Press. Albany, New 

York, 1994) and R. Grambling, Oil on the Edge: Offshore Development, Conflict and Gridlock (State University 

of New York Press. Albany, New York, 1996). 

20 Number of leases and acreage as of July 31, 2000 
Final Study Report – McGinnis, Fernandez, Pomeroy 

76

Table 7. Installation and Removal of Production Platforms on the Federal Outer Continental Shelf 

 GULF OF MEXICO PACIFIC 

 YEAR Installed Removed Installed Removed 

1942-1960 459 0 0 0 

 1961 108 0 0 0 

 1962 123 0 0 0 

 1963 89 0 0 0 

 1964 127 0 0 0 

 1965 129 0 0 0 

 1966 118 0 0 0 

 1967 133 0 1 0 

 1968 109 0 3 0 

 1969 112 0 1 0 

 1970 117 0 0 0 

 1971 102 0 0 0 

 1972 132 0 0 0 

 1973 95 1 0 0 

 1974 56 5 0 0 

 1975 102 36 0 0 

 1976 115 30 1 0 

 1977 114 17 1 0 

 1978 166 26 0 0 

 1979 162 35 2 0 

 1980 175 36 3 0 

 1981 168 24 3 0 

 1982 195 15 0 0 

 1983 179 38 1 0 

 1984 226 53 1 0 

 1985 212 55 3 0 

 1986 115 34 1 0 

 1987 116 23 1 0 

 1988 169 99 0 0 

 1989 197 94 2 0 

 1990 177 108 0 0 

 1991 156 117 0 0 

 1992 92 105 0 0 

 1993 126 171 0 0 

 1994 179 124 0 1 

 1995 138 117 0 0 

 1996 159 121 0 0 

 1997 155 176 0 0 

 1998 142 75 0 0 

 1999 0 0 

Totals 5,744 1,735 24 1 

Sources: Gramling 1996, Minerals Management Service, 2000. 

The 400021 platforms of the Gulf supply 25% of the nation’s natural gas and 13% of 

its oil production (MMS 2000). Nearly 4,000 offshore production platforms and 22,000 miles 

of oil and gas pipelines exist (MMS 2000). Ranging in size and structure, the average depth 

 

21 Number of platforms as of July 31, 2000. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

77

of these platforms is 100 to 300 feet in state and federal waters. Roughly 95% of the existing 

oil and gas platforms exist off the coasts of Texas and Louisiana. 

The Political Ecology of Gulf Oil Development 

Most of the oil and gas structures are set in the soft, sandy bottom of the Gulf where 

there exists very little hard substrate for natural reefs (Sonnier, et al. 1976). In addition to 

natural reefs, studies have shown that offshore structures attract bacteria, algae, invertebrate 

and fish species. Filter feeding organisms proliferate in the pelagic environment, providing 

food and shelter for economically valuable and commercially and recreationally sought fish 

species (Sonnier, et al. 1976; Gallaway and Lewbel 1982; Gallaway, et al. 1988). 

The platforms of the Texas-Louisiana OCS have created a web of artificial habitats for 

some marine life. There is some indication that platform development increases the amount 

of habitat available for marine species that depend on hard bottom substrates (Continental 

Shelf Associates 1982; Gallaway and Lewbel 1982; Sonnier, et al. 1976). Underwater 

platforms structures serve as a point of concentration for many biofouling organisms. Marine 

studies describe the biofouling community associated with platforms as rich and diverse 

(Sonnier, et al. 1976; Gallaway and Lewbel 1982; Gallaway, et al. 1988). Microorganisms, 

algae and invertebrates drifting through the pelagic environment attach and grow on the 

underwater structures. Filter feeders such as anemones and bivalves tend to proliferate, 

feeding on the plankton carried by currents through the water column. The shells of 

invertebrates are covered by colonial species such as hydroids, bryozoans, and tunicates who 

exploit the habitat and/or food provided. The colonial species provide additional habitat for 

small and motile, cryptic organisms such as ophioroids and caprellid and gammarind 

amphipods who feed on the abundant food supply (Gallaway, et al. 1988; Gallaway and 

Lewbel 1982). Other colonial invertebrates found on offshore rigs include hydroids, 

bryozoans, ascidians, and sponges (Gallaway, et al. 1988; Gallaway and Lewbel 1982). 

Although the overall biomass is similar for nearshore and offshore platform structures, 

the composition of the biofouling community differs (Gallaway and Lewbel 1982). Nearshore 

platforms are typically dominated by one to several barnacle species including Balanus 

reticulates, B. eburneus, and B. improvisus (Gallaway and Lewbel 1982). Offshore platforms 

are similar but are dominated by pelecyods such as Ostrea equestris, Crassotrea virginica, 

and Hyotissa thomasi instead of barnacles (Lewbel, et al. 1997). 

Organisms typically found on platforms are restricted to a depth range that may be 

inconsistent with their “natural” range. Habituation on a natural reef exposes the organism to 

predation and competition by other species that may not be present on a platform. Fishers 

remain the primary predator for the marine species that are found on or near offshore 

platforms. 

The increased biological activity associated with platforms attracts a wide variety of 

fish species along a vertical zone in the water column (Continental Shelf Associates 1982; 

Gallaway and Lewbel 1982; Gallaway, et al. 1988; LGL and SAIC 1988; Sonnier, et al. 

1976). Following the installation of a new platform, fish colonization can occur in as little as 

15 months (Lukens 1983) in search of food and/or shelter (Gallaway and Lewbel 1982). 

Dressen (1989) estimates that nearly 20-50% more fish occur beneath or adjacent to platforms 

compared to nearby soft bottom areas in the Gulf. Fish assemblages vary from a few hundred 

individuals to a few thousand, depending on platform, size, location and season (Continental 

Shelf Associates 1982). 
Final Study Report – McGinnis, Fernandez, Pomeroy 

78

Based on the associated bio-fouling community and fish indicator species Gallaway 

and Lewbel (1982) classify platforms in the Gulf into three separate biological zones. These 

classifications are coastal (shoreline to 98 feet), offshore (98 to 197 feet) and blue-water 

(>197 feet). These authors also found that the location and assemblages of the associated 

communities are influenced by environmental factors such as turbidity, seasonal temperature 

changes, amount of primary productivity and degree and of exposure to Caribbean water 

(Gallaway and Lewbel 1982). 

 Stanley and Wilson (1990) surveyed catch records from recreational and charter boat 

anglers in the northern Gulf and found that the fish species and number caught varied with 

season, platform size and structural complexity, and water depth. 

The Perceived Problem 

 More than one-quarter of the remaining platforms in the Gulf are over 25 years old, 

and may be removed within the next ten years (MMS 2000). This means that nearly one 

thousand structures may be removed in the next ten years. 

Offshore oil and gas activity over the past fifty years has contributed to the 

development of commercial and recreational fishing. For this reason, a number of 

government and non-government organizations began to “campaign for changes in public 

attitudes and existing laws to facilitate use of petroleum platforms as artificial reefs for fish 

concentration” (Harville 1983: 5). The oil and gas industry was also anxious to cooperate 

with responsible reef developers willing and able to accept future responsibility and liability 

for rigs-to-reefs projects (DuBose 1985; Reggio 1987). A strong coalition of fishery and oil 

interest groups had emerged during a long history of oil development in the Gulf OCS region 

(Freudenberg and Gramling 1994; Gramling 1996).22 In addition, many coastal inhabitants of 

the Gulf regularly fish coastal and marine waters for recreation, sport, commerce, and 

subsistence. 

Table 8 is a list of fish species associated with Gulf OCS platforms. 

Table 8. Identified Fish Species Associated with Platforms in the Gulf of Mexico OCS 

 Common Name Scientific Name Common Name Scientific Name 

Atlantic bonito Sarda sarda Atlantic croaker Micropogonias undulates

Atlantic cutlassfish Trichiurus lepturus Atlantic spadefish Chaetodipterus faber

Bearded brotula Brotula barbata Black drum Pogonias cromis

Blackfin tuna Thunnus atlanticus Bluefish Pomatomus saltatrix

Blue marlin Makaira nigricans Blue runner Caranx cyrsos

Cobia Rachycentron canadum Crevalle jack Caranx hippos

Cubbyu Equestus umbrosus Dolphin Coryphaena hippurus

Florida pompano Trachinotus carolinus Flounder Paralichthys sp. 

Gafftopsail catfish Bagre marinus Great barracuda Sphyraena barracuda

Greater amberjack Seriola dumerili Grey triggerfish Balistes capriscus

Grouper Family Serranidae Grunts Hamulon sp. 

Hake Urophycis sp. Hardhead catfish Arius felis 

 

22 Notice the dramatic difference between OCS oil and gas activity in the Gulf and the Pacific found in Table 7. 

This is one reason why the history and political relationships that exist between fishery and oil interests is very 

different in California, see Molotch and Freudenberg (1996).
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

79

Table 8. Identified Fish Species Associated with Platforms in the Gulf of Mexico OCS (continued) 

 Common Name Scientific Name Common Name Scientific Name 

Kingfish Menticirrhus sp. King mackerel Scomberomorus cavalla

Ladyfish Elops saurus Leopard toadfish Opsanus pardus

Little tunny Euthynnus alletteratus Lookdown Selene vomer

Other jacks Caranx sp. Other seatrout Cynoscion sp.

Other snapper Family Lutjanidae Pinfish Lagodon rhomboids

Porgy Calamus sp. Puffer Family Teradontidae 

Rainbow runner Elagatis bipinnulata Rays Family Dasyatidae 

Red drum Sciaenops ocellatus Red snapper Lutjanus campechanus

Scamp Mycteroperca phenax Sharks Order Selachii 

Sheepshead Archosargus porbatocephalus Shrimp eel Ophichtus sp.

Silver/sand seatrout Cynoscion sp. Skipjack tuna Euthynnus pelamis

Spanish mackerel Scomberomorus macatulatus Spotted seatrout Cynoscion nebulosus

Squirrelfish Holocentrus sp. Tarpon Megalops atlanticus

Tripletail Lobotes surinamensis Wahoo Acanthocybium solanderi

White spotted soapfish Rypticus maculates Yellowfin tuna Thunnus albacares

Sources: Dugas et al. 1979, Stanley and Wilson 1990, and LGL Ecological Research Associates, Inc. and SAIC 

1988. 

The southeastern recreational fisheries are the largest in the nation. Between 1955 and 

1980, participation in saltwater recreational fishing increased 2.7 times and related 

expenditures grew sevenfold. In 1998, 5.8 million anglers took 53 million trips and caught 

284 million fish, nationwide (NMFS 1998). The increased interest in sport fishing is 

attributed to advances in technological design of recreational motorboats, outboard motors, 

navigational equipment and gear (NMFS 1999). Recreational fishermen operate from private 

boats, charter boats, head boats and shore using fish traps, hooks and lines, longlines, spears, 

trammel nets, bang sticks and barrier nets (NMFS 1999). 

 As the number of platforms dominated the Texas-Louisiana shelf, commercial and 

recreational harvest efforts became more concentrated around the structures. Studies 

document the levels of fishing activity near or around rigs. During the 1960s, Gulf 

newspapers and magazines featured the “fabulous” sites associated with rig structures (Reggio 

and Kasprzak 1991). Gunter (1963) describes the area between Pascagoula, Mississippi and 

Port Arthur, Texas as the “Fertile Fisheries Crescent” claiming it contains the most productive 

waters on earth. Oil platforms became a principal fishing destination for many local 

recreational fishermen (Ditton and Graefe 1978; Dugas, et al. 1979). In Louisiana, over 70% 

of all recreational angling trips occur near the platforms in Federal waters (Reggio 1987). 

 Ditton and Graefe (1978) showed that 87% of registered sport-fishing boats from 

Galveston, Texas target the platforms for fishing. One half of the 66,924 offshore fishing 

trips by resident boat owners in Galveston and eight adjacent counties, were primarily to the 

platforms (Ditton and Graefe 1978). A MMS (1980) survey of offshore platform personnel on 

300 platform structures offshore Texas and Louisiana shows that employees also fish off the 

structures. Stanley and Wilson (1989) found that the average distance traveled by recreational 

users was at least 62 km to the platform, and the distance increased from east to west and from 

anglers to divers. 

 Commercial fisheries harvest in the Gulf of Mexico lead the nation. Table 9 depicts 

the commercial fishery landings in the Gulf between 1955 and 1998. 
Final Study Report – McGinnis, Fernandez, Pomeroy 

80

Table 9. Commercial Landings Summary from 1955-1998. 

 Region Metric Tons Dockside Revenues 

 Gulf of Mexico 34,651,841.80 $18,075,538,997 

 Louisiana 22,890,187.10 $7,004,094,328 

 Texas 2,727,795.30 $5,302,623,472 

Source: National Marine Fisheries Service. 

From 1950 to 1998, commercial landings totaled more than 34 million metric tons and 

generated more than $18 billion in dockside revenues. Louisiana accounted for nearly 65 

percent (22 million metric tons) of the landings and 38 percent ($22 million) of the revenues. 

Texas holds the second largest fishery, contributing 2.7 million metric tons of commercial 

landings and generating $5 million in dockside revenues. 

Overall, the recreational fishing industry has grown significantly since the first 

platform was placed in Louisiana waters in 1947 (Howe 1985). Fishers have benefited from 

the increased biological activity associated with offshore rigs. As the number of removals 

increased from one year to the next, fishers became alarmed by the loss of habitat and 

reduction in fishing opportunities (Kasprzak, personal communication, 2000). The reduction 

in available habitat from the removal of platforms has unknown consequences to fish 

populations. At the very least, a huge amount of biomass is lost and fishes disperse to other 

places. As regular users of offshore platform structures, the sport fishing clubs, local artificial 

reef committees and dive clubs actively advocated the benefits of converting obsolete rigs into 

artificial reefs for fishery enhancement. 

The Political Stream 

The Gulf of Mexico contains approximately two-thirds of the world’s offshore oil and 

gas structures, and 95% of the production platforms in waters off the coast of the US (Reggio 

and Kasprzak 1991: 11). This level of development has been followed by significant levels of 

use by commercial and recreational fishers of these offshore oil rigs. In particular, fishing off 

Louisiana and Texas, where a majority of Gulf OCS oil production occurs, has contributed to 

rigs-to-reefs policy development. 

A coalition of oil and fishery interest groups, federal and state resource agency 

personnel, and other individuals, such as Congressional representatives, favored a rigs to 

artificial reef alternative to complete removal of Gulf OCS oil and gas facilities. For example, 

in 1979, the Sport Fishing Institute initiated action by urging a resolution to the Secretary of 

Commerce and the Secretary of the Interior to develop policies, procedures and guidelines to 

convert platforms to artificial reefs. The Sports Fishing Institute also pointed out the 

importance of existing artificial reefs in the Gulf to fisheries. 

Before the Act: Early Artificial Reef Program Development 

Existing artificial reef programs in the Gulf are carried out by local governments, 

private parties and individuals. In 1954, Alabama initiated the first artificial reef program in 

the Gulf. Natural reefs are virtually nonexistent in Alabama waters. As a result of artificial 

reef building, the state is now referred to as the “Red Snapper Capital of the World”, because 

Alabama waters provide the highest catch of red snapper in the Gulf (Harrison 2000). 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

81

 Since the late 1940s, the Texas Parks and Wildlife Department has also been involved 

in artificial reef activities, such as the development of oyster reefs in Texas bays since 1947 

(Joyce 1981; Osburn and Culbertson 1993). Some of the materials used during the 1940s and 

1950s were not durable enough to withstand the shifting currents and eventually dissolved or 

moved to an unknown location. Used cars and vessels have also been used (Joyce 1981; 

Osburn and Culbertson 1993). 

In Louisiana, small artificial reef sites were created by local fishermen in an effort to 

increase their personal fish catch (Kasprzak, personal communication, 2000). Early artificial 

reef development in this state was not part of a state artificial reef program. Unwanted 

materials such as old automobiles, large appliances, and concrete rubble were dumped in 

secret locations in estuaries and coastal waters to create personal fishing areas (Kasprzak, 

personal communication, 2000). 

Since 1978, several divisions with the Florida Department of Natural Resources have 

been involved with artificial reef activities to enhance fishery habitat (Joyce 1981). In 1980, 

the State of Florida set the precedent and made an important step toward the development of a 

rigs-to-reefs alternative. Through the cooperative effort between the Southeastern Fisheries 

Association, the Gulf and South Atlantic Fisheries Development Foundation, Exxon 

Corporation and the State of Florida, an oil production template was removed and transported 

from Louisiana waters to Florida offshore waters for use at an artificial reef site (Joyce 1981; 

Wilson and Van Sickle 1987). The oil industry has also contributed offshore structures to 

fishery enhancement projects. In 1980, a joint effort between Exxon and Florida’s 

Department of Natural Resources permitted the towing of a 2,200 ton submerged production 

system from Louisiana waters to a pre-selected site in Florida (Wilson and Van Sickle 1987). 

The structure was placed without an underwater survey of the site before placement (Mathews 

1985). 

Two years after the Exxon project, Tenneco Oil donated a production platform 

removed from offshore Louisiana. The structure was towed 275 miles and placed offshore 

Pensacola, Florida (Frishman 1982; Bohnsack and Sutherland 1985). The following year, the 

Alabama Department of Conservation and Natural Resources permitted Marathon Oil 

Company to tow a 1,650 ton oil platform 220 miles from Louisiana waters to southeast 

Mobile, Alabama (Wilson and Van Sickle 1987).23 

By the end of 2000, many materials such as used automobiles, refrigerators, derelict 

ships, concrete rubble and other structures (such as military tanks and oil structures) have 

been used to construct over 150 permitted artificial reefs off Florida, Alabama, Mississippi, 

and Texas (Reggio personal communication, 2000). Three-fourths of all the existing, 

dedicated, or permitted reefs sites in the Gulf are off the west coast of Florida and the Florida 

Keys (Reggio and Kasprzak 1991). Advocacy of artificial reef building has a long history in 

the Gulf. In 1979, the American Fisheries Society and Sport Fishing Institute supported 

artificial reef building in the Gulf (Harville 1983). 

Federal Resource Agencies

Federal involvement in artificial reefs began in 1966 with a research project at the U.S. 

Bureau of Sport Fisheries and Wildlife’s Sandy Hook Laboratory in New Jersey (Lukens and 

 

23 On October 2, 1985, two more Tenneco structures were towed 920 miles from Louisiana to 1.5 miles off Dade 

County, Florida (Wilson and Van Sickle, 1987). 
Final Study Report – McGinnis, Fernandez, Pomeroy 

82

GSMFC 1993). The seven-year study included an evaluation of the use of artificial reefs as a 

fishery enhancement tools (Lukens and GSMFC 1993). Existing artificial reefs were 

evaluated for their efficacy, building materials were tested through the construction of new 

reefs, and biomass impacts associated with reef sites were assessed (Lukens and GSMFC 

1993). Ten reef sites were built along the Atlantic coast but the most successful reef sites 

were offshore South Carolina and Florida waters (Lukens and GSMFC 1993). 

Since the late 1970s, the National Marine Fisheries Service (NMFS) has supported 

artificial reef research through technical and financial assistance to states, counties, and 

private interests (Harville 1983). NMFS has participated in artificial reef planning, design, 

permitting, construction, monitoring and evaluation (Lukens and GSMFC 1993). 

 The MMS also supports converting obsolete oil and gas structures to artificial reefs. 

MMS sponsored “Information Transfer Meetings” in 1982, 1984, 1985, 1986, and 1987 which 

included sessions on present and potential fishery uses of oil and gas structures. Reflecting on 

these public forums and information transfer meetings, Reggio and Kasprzak (1991: 10-11) 

write: 

Public forums organized and sponsored by the MMS in a series of annual 

information transfer meetings during the 1980s elicited additional information 

on the present and potential fishery uses of oil and gas structures. Federal and 

state conservation officials, private conservation groups, fishing organizations, 

oil and gas companies, university researchers, and others encouraged the 

conversion and use of oil and gas structures as artificial reefs. 

Workshops included a review of data available and information on Gulf fisheries, and 

explored the economic, social, political, biological and technical benefits of a rigs-to-reefs 

alternative. 

In August 1983, Secretary of Interior, James Watt created the Recreation, 

Environmental Enhancement and Fishing in the Sea (REEFS) task force to “pave the way for 

aggressive movement towards a national Rigs-to-reefs program which will enhance fishery 

resources and improve recreational and sport fishing opportunities within America’s offshore 

marine environments.” (DuBose 1985). The primary agenda of the REEF task force was to 

assess the use of obsolete platforms as artificial reefs as a means to enhance local fisheries and 

to develop policy that set national standards for artificial reef building. 

The Policy Stream 

Most ideas never find the light of day. Ideas that survive to shape public policy in a 

dynamic intergovernmental process must meet several criteria, including their scientific merit, 

their fit with dominant values, and the political support or opposition that ideas may 

experience. 

The Role of the Scientific Community

As the number of platforms increased in the Gulf, the number of scientific studies on 

the economic benefits of offshore platforms also increased. Since the 1950s, a number of 

field studies have described the invertebrate species, fish species and the impact of potential 

pollutants on waters and biota associated with offshore rigs. Gunter (1963) described the biofouling community on the legs of an oil platform in the northern Gulf. Nearly two decades 

later, the Offshore Ecological Investigation (1972 to 1974) by the Gulf Universities Research 

Consortium (GURC) investigated the sedimentology, hydrography, microbiology, plankton, 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

83

benthos, bio-fouling communities, trace metals, and hydrocarbons associated with platforms 

sited in Louisiana bays and inner shelf. Shinn (1974) described the composition and vertical 

zonation of fishes around Louisiana platforms. Sonnier, et al. (1976) compared natural reef 

fish assemblages to fish fauna associated with offshore platforms in the Gulf of Mexico. 

Interest spread to government agencies, particularly the MMS, who funded a number 

of large-scale, multi-year scientific projects. Table 10 summarizes the major government 

related research projects associated with offshore petroleum development from 1960 to 1990. 

Table 10. Major Broad-scale and Interdisciplinary Investigations of the U.S. Gulf of Mexico Conducted Since 

1960 by State and Federal Government Agencies. 

 Dates Sponsor, location, and nature of study 

1961-1965 National Marine Fisheries Service (NMFS). Rio Grande to Mobile Bay. Monthly transects across 

shelf. Hydrography, plankton, and trawl fishery survey. 

1965-1967 State of Florida. Hourglass Cruises. Monthly transects across Florida shelf off Tampa and 

Charlotte Harbor. Hydrography, plankton, trawl, dredge, trap, and handline survey. 

1970-1976 Texas A&M Univ. Defenbaugh dissertation. Gulfwide except west Florida and Yucatan. Trawl 

survey of benthic invertebrate fauna of U.S. and Mexican continental shelves. 

1972-1974 Gulf Universities Research Consortium (GURC). Offshore Ecology Investigation. Louisiana bays 

and inner shelf. Sedimentology, hydrography, microbiology, plankton, benthic flora and fauna, 

bio-fouling communities, trace metals, and hydrocarbons. 

1974-1979 BLM. Mississippi-Alabama-Florida (MAFLA) Baseline Study. Continental shelf off Mississippi, 

Alabama, and Florida. Sedimentary, geological mapping, hydrography and physical 

oceanography, plankton, neuston, benthos, demersal fishes, and trace metals and hydrocarbons 

(in water, sediments and biota). 

1975-1980 BLM. South Texas Outer Continental Shelf Baseline Study. Transects off south Texas (Rio 

Grande to Matagorda Bay). Sedimentology, geologic mapping, hydrography, plankton, 

neuston, benthos, demersal fishes, histopathology, and trace metals and hydrocarbons (in water, 

sediments and biota). 

1975-1985 BLM/MMS.* Topographic Features Program. Study of submarine banks off Texas, Louisiana, 

and Florida (Florida Middle Grounds). Geologic mapping and hydrographic and biological 

surveys. 

1977-1980 NMFS, EPA. Buccaneer Gas and Oil Field Program. Inner shelf off Galveston, Texas. 

Sedimentology, hydrography and circulation, benthos, bio-fouling communities, artificial reef 

study, and toxicology. 

1978-1981 BLM. Central Gulf Outer Continental Shelf Platform Study. Continental shelf off Louisiana. 

Sedimentology, microbiology, benthos, trace metals and hydrocarbons (in water, sediments, 

and biota), histopathology, and platforms as artificial reefs. 

1980-1987 BLM/MMS. Southwest Florida Shelf Marine Ecosystems Study. Continental shelf off south-west 

Florida from Fort Myers to 25th parallel (below the Everglades). Sedimentology, geologic 

mapping, hydrography, biological survey, benthos, biological processes, and productivity. 

1981-1985 U.S. Department of Energy (DOE). Strategic Petroleum Reserve Studies. Nearshore shelf off 

Cameron. Louisiana, and Freeport, Texas. Hydrography, plankton, benthos, demersal fishes, 

sediment chemistry. 

1981-present BLM/MMS. Northern Gulf Continental Slope Study. Outer Continental Shelf and upper slope, 

Gulfwide. Biological surveys, and benthos and chemosynthetic communities studies. 

1983-present MMS. Mississippi-Alabama Shelf Marine Ecosystems Study. Continental shelf from Mississippi 

River Delta to DeSota Canyon. Geologic mapping, and hydrographic and biological surveys. 

*The Minerals Management Service (MMS) was formed by merger of units from the Bureau of Land 

Management (BLM) and the U.S. Geological Survey (USGS) in 1981-1982. 

Source: Darnell and Defenbaugh 1990. 

For example, MMS sponsored a $4.4 million study in cooperation with Texas A&M 

University and the oil industry to assess the environmental impacts on the benthos 

surrounding oil platforms. The study, known as the Gulf of Mexico Offshore Monitoring 

Experiment (GOOMEX), was intended to provide detailed information on the biological, 
Final Study Report – McGinnis, Fernandez, Pomeroy 

84

geological, and chemical impacts of discharged effluents on the surrounding marine biota. 

Indeed, MMS remains the primary source of funding for marine science research in both the 

Pacific and Gulf OCS region. 

The Move to the Federal Level: Congressional Activity 

 The heightened awareness of converting rigs-to-reefs for fisheries enhancement among 

commercial and recreational user groups and the need to coordinate state and local efforts 

initiated hearings before the Congressional Subcommittee on Fisheries and Wildlife 

Conservation and the Environment on September 11, 1981. Members of Congress from 

Louisiana (John Breaux), New Jersey (William Hughes and Edwin Forsythe) and Rhode 

Island (Claudine Schneider) introduced two bills, H.R. 1041 and H.R. 1897, to: (1) develop 

marine artificial reefs in U.S. waters and, (2) provide funds to develop, maintain, and monitor 

offshore artificial reef sites. 

 The two bills, H.R. 1041 and H.R. 1897, designated the NMFS the primary 

responsibility to fund, develop, and monitor Gulf state artificial reef activities. The two bills 

stipulated that any construction of a “fishery conservation zone” (3 to 200 nautical miles) 

could only be constructed by the NMFS. Despite the fact that both of these bills were 

defeated, the bills demonstrate the idea for the need of federal backing for an artificial reef 

plan. One important policy entrepreneur Congressman John Breaux expressed his support for 

the development of a comprehensive artificial reef program for the Gulf as follow: 

We are missing a golden opportunity. There is, for example an oil and gas 

industry out there that has thousands of rigs that are going to have to be 

dismantled and towed in and broken up at a great deal of expense. It would be 

cheaper to be able to cut those and use them as artificial reefs. I think a 

coordinated policy could be greatly beneficial to both the fishing industry and 

the people who own those structures. If we need to change, or draft new 

legislation that would allow them to do that, I believe we should. 

Two years later, on July 18, 1983 Congressman John Breaux of Louisiana along with 

17 other members of Congress introduced H.R. 3474 in an effort to establish a national 

artificial reef policy. Testimony from federal, state and local agencies as well as user groups 

and environmental organizations supported the establishment of a comprehensive federal 

artificial reef program that included the rigs-to-reefs option. Some portions of the bill were 

amended and it was reintroduced as H.R. 5474. The amendments were approved and passed 

on April 12, 1984. 

The political stream included Congressional representatives, federal and state resource 

agency personnel, members of the oil and fishery industries who supported the idea of the 

rigs-to-reefs alternative to complete removal of offshore oil structures in the Gulf. Various 

studies of the marine ecology and socio-economic uses associated with commercial and sports 

fishing also supported the idea of the rigs-to-reefs alternative. MMS personnel (such as 

Villere Reggio) and other resource managers and scientists played a major role in promoting 

the use of rigs as artificial reefs to enhance fisheries. These individuals acted as policy 

entrepreneurs, pushing and advocating their particular proposals and ideas in the 

intergovernmental policymaking process. 

For the Gulf region, the idea of “rigs-to-reefs” is less an invention and more a mutation 

of an old idea. The rigs-to-reefs idea represents the coupling of an already familiar activity of 

building artificial reefs in the Gulf. The use of familiar ideas (such as artificial reef building) 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

85

by policy entrepreneurs and experts is described by Kingdon (1995: 201) as the “act of 

recombination”. The rigs-to-reef policy idea represents a recombination of an old solution 

(the reliance on artificial reefs to enhance fisheries) to a perceived new problem (the lack of 

natural habitat and potential economic impacts associated with complete removal of OCS oil 

and gas structures). 

The Window of Opportunity: Passage of the National Fisheries Enhancement 

Act of 1984 

The National Fishing Enhancement Act (NFEA) of 1984 (Title II of Public Law 98-

623) was passed by Congress and signed into law by President Reagan on November 8, 1984. 

The NFEA defines an artificial reef as “a structure which is constructed or placed...for the 

purpose of enhancing fishery resources and commercial and recreational opportunities.” The 

NFEA states the following: 

Properly designed, constructed, and located artificial reefs...can enhance the 

habitat and diversity of fishery resources; enhance recreational and commercial 

fishing opportunities; increase the production of fishery products in the United 

States; increase the energy efficiency of recreational and commercial fisheries; 

and contribute to the United States coastal economies. 

The NFEA consolidated several decades of localized and state laws to maximize the potential 

benefits of artificial reefs as fishery enhancement mechanisms. State governments are 

responsible for carrying out the general goals of the NFEA in federal and state waters by 

funding, promoting, and maintaining artificial reefs. The NFEA provides a foundation for the 

establishment of a national artificial reef program based on the following goals: 

• To enhance fishery resources; 

• To facilitate access for recreation and commercial fishing; 

• To lessen conflicts between users of marine resources; 

• To minimize environmental risks; 

• To follow principles of international law; 

• To prevent unreasonable obstruction to navigation; and 

• To promote consistency with the National Artificial Reef Plan. 

 The NFEA directed the NMFS to develop the National Artificial Reef Plan within one 

year. The Plan was published one year later through the combined efforts of fishermen, 

divers, scientists, state and federal resource agencies (Stone 1985; Harrison 2000). The Plan 

serves three purposes: 

1. To provide guidance to individuals, organizations, and government agencies on 

technical aspects of artificial reef planning, design, siting, construction, and 

management for effective artificial reef development; 

2. To serve as a reference for federal and state resource agencies involved in artificial 

reef permitting; and 

3. To ensure that the national standards and objectives established by the NFEA are 

met. 

The Plan serves as one guide to develop state artificial reef programs. It includes 

information on design criteria, permit compliance, management methods, and ideas for 
Final Study Report – McGinnis, Fernandez, Pomeroy 

86

increasing artificial reef development. In addition, the Plan emphasizes the need for research 

and monitoring of artificial reef activity. 

Federal Guidance and Assistance 

Since the NMFS developed and published the Plan, they have continued to support 

regional, state, and local artificial reef development activities. The NMFS provides technical 

consultation, resources, and contributes to various regional artificial reef management 

committees established by interstate marine fisheries commissions. 

 The U.S. Fish and Wildlife Service administers the Federal Aid in Sport Fish 

Restoration Program (16 U.S.C. Sec 777), which provides funding for important recreational 

fisheries work. Coastal states in Region 4 (North Carolina, South Carolina, Georgia, Florida, 

Alabama, Mississippi, and Louisiana) and Region 2 (Texas) of the Service can apply for funds 

from the Federal Aid for sport fish restoration and boating projects. Money for this program 

is collected from taxes placed on fishing tackle and motorboat fuel. In 1984, the Wallop 

Breaux amendment to the Sport Fish Restoration Act allocated funds for use in artificial reef 

programs. 

MMS amended its guidelines on the “Disposal of Oil Platforms” to reflect the goals of 

the NFEA. MMS’s new policy statement encourages the “reuse of obsolete offshore 

petroleum structures as artificial reefs in US waters” so long as the structures do not “pose an 

unreasonable impediment to future mineral development”. MMS also provides information to 

state programs, such a geophysical data, offshore area/lease block maps, bathymetric maps, 

pipeline and platform location maps, numerous technical reports and environmental impact 

statements, and visuals (maps that illustrate bottom sediment types, oceanographic currents, 

shrimp trawling areas, etc.) (MMS 2000). 

The Permits and Evaluation Branch of the Corps of Engineers (COE) regulates 

planning and development activities in OCS under the jurisdiction of the Rivers and Harbors 

Act of 1899, the National Environmental Protection Act of 1969, the Clean Water Act of 

1972, and the Marine Protection Research and Sanctuaries Act of 1972. It is the lead federal 

agency that permits and monitors artificial reef development under NFEA. All state natural 

resource agencies must obtain a COE permit before any construction of an artificial reef site. 

The COE reviews the permit, inspects the materials and then issues the appropriate permit or 

makes recommendations to improve the permit application. 

State Artificial Reef Programs24

In the Gulf, the primary purpose of the rigs-to-reefs policy is to enhance fisheries 

(Murray 1994). Since the implementation of the Plan of 1985, most state marine fisheries 

agencies have assumed the lead in developing artificial reefs through state developed 

programs. State natural resources agencies currently direct or coordinate with local agencies 

in obtaining permits, maintaining liability, financing, constructing, researching and 

monitoring marine artificial reefs. Many coastal states have adopted state-specific plans based 

on the guidance of NFEA. 

Louisiana was the first among the Gulf states to create a formal artificial reef program. 

Passed in 1986, the Louisiana Fishing Enhancement Act (Act 100) is the most comprehensive 

 

24 This section is not intended to provide a comprehensive review of Gulf State artificial reef programs but rather 

a characterization of the historical development of the rigs-to-reefs alternative. In addition to the state programs 

that are described in this section, Alabama and Mississippi have artificial reef programs. 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

87

reefing policy and program in the Gulf (Murray 1994). The Act provides for: 1) establishment 

of the artificial reef program, 2) creation of the Louisiana Artificial Reef Council, 3) 

establishment of a Louisiana Artificial Reef Development Fund, 4) development of a reef 

plan, 5) establishment of the state as the permittee for artificial reefs developed under the plan, 

and 6) relief from liability (Wilson and Van Sickle 1987). The Louisiana Act sets up a means 

to transfer the ownership and liability of the platforms from the oil and gas companies to the 

State when the platform ceases its production. The Plan established an Artificial Reef Trust 

Fund for funding costs associated with each artificial reef project (Kasprzak, personal 

communication, 2000). When oil and gas companies donate platform structures, they are 

asked to donate half of the cost savings for participation directly into the trust fund. As of 

2000, the Artificial Reef Trust Fund has accrued $13 million and uses the 5% interest to fund 

the artificial reef program (Kasprzak, personal communication, 2000). 

Since 1987, the Louisiana Artificial Reef Program has created 25 artificial reef sites 

that utilize 85 obsolete platform jackets and/or parts. Map 3 shows the artificial reef sites 

offshore Louisiana. 

Map 3. Location of artificial reefs in Louisiana waters. 

 

Source: Gulf States Marine Fisheries Commission 

Approximately 7-10 platforms are donated per year as platforms become available 

(Kasprzak, personal communication, 2000). Most of the reef development spans between 30 

to 70 miles offshore and extends down a minimum of 50 feet from the surface to satisfy Coast 

Guard navigational guidelines. 

To fulfill its monitoring requirement, hydroacoustic surveys are taken yearly to 

monitor fish populations at standing rigs versus toppled rigs (Kasprzak, personal 

communication, 2000). Results from these surveys have shown that standing rigs provide 

more vertical profile and a higher biomass results when compared to toppled rigs that provide 

less habitat area (Kasprzak, personal communication, 2000). Side scan sonars are used to 

make sure reef sites remain in place and do not pose any dangers to health or property 

(Kasprzak, personal communication, 2000). 
Final Study Report – McGinnis, Fernandez, Pomeroy 

88

The Texas legislature passed the Artificial Reef Act of 1989, which directed the Parks 

and Wildlife Department to promote, develop, maintain, monitor and enhance the offshore 

artificial reef potential (Osburn and Culbertson 1993). The following year, the Department 

introduced the Texas Artificial Plan that was adopted by the Parks and Wildlife Commission. 

To maximize accessibility for commercial and recreational fishermen as well as divers, 

reef sites are located across a wide range of depths and distances from shore. The Texas 

Program currently maintains 33 developed artificial reef sites, located 6 to 87 miles offshore 

in 36 to 288 foot depths (Osburn and Culbertson 1993). Construction materials used to 

develop reef sites range in size, structure, and durability. These “materials of opportunity” are 

donated to the program for use in artificial reef sites and include: 45 oil and gas structures, 12 

Liberty ships, 5 barges as well as a tugboat, concrete culverts, fly ash blocks, reef balls, quarry 

rocks, and a welded pipe. Map 4 shows the artificial reef sites located offshore Texas. 

Map 4. Location of artificial reefs in Texas waters. 

Source: Gulf States Marine Fisheries Commission 

Twelve of the sites are nearshore to allow accessibility to small boat owners. Efforts 

to create reefs close to shore include the Star Reef, a cluster of six oil rigs that were placed in 

the shape of a star approximately 33 nautical miles from Freeport (Texas Parks and Wildlife 

1999). For a complete listing of Texas artificial reefs, see 

http://www.tpwd.state.tx.us/fish/reef/artreef.htm. 

The Texas Artificial Reef Program includes the use of a citizen-based Artificial Reef 

Advisory Committee. The committee is comprised of at least one representative from major 

user or stakeholders from: (1) salt water sports fishing organization, (2) offshore oil and gas 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

89

company, (3) Texas tourist industry, (4) General Land Office, (5) Texas Shrimp Association, 

(6) Texas diving club, (7) Attorney General’s office, (8) Texas A&M University, (9) 

environmental group, (10) Texas antiquities committee. The committee meets regularly to 

discuss and resolve conflicts as well as provide guidance for the placement of future artificial 

reef sites to maximize user benefits. Oil companies are required to pay a fee equal to the 

company’s removal and cleanup costs. 

 Florida established its Artificial Reef Program in 1982 through the joint collaborative 

effort between the Department of Environmental Resources Management and Florida Fish and 

Wildlife Conservation. However, it is different from the Louisiana and Texas state programs 

in that artificial reef sites are typically the result of coordinated efforts of county or city 

agencies and private individuals. The Florida Artificial Reef Plan provides guidance and 

direction for reef planning, and development activities, yet allows each county to develop its 

own artificial reef program according to each region’s fishery needs. Each of the 35 

participating counties serve as the primary permit holders and project managers utilizing 

volunteer groups to serve on reef advisory boards, conduct site assessments, complete 

documentation necessary for permitting, obtain donations of suitable materials and 

periodically monitor the reefs. 

 The Florida State Reef Program drafted a State Reef Monitoring Plan that provides 

basic guidance and data for the biological, physical, oceanographic and socio-economic 

evaluations of artificial reefs. Map 5 shows the location of artificial reefs off Florida while 

Map 6 shows the location of artificial reefs in the entire Gulf. 

Map 5. Location of artificial reefs in Florida waters. 
Final Study Report – McGinnis, Fernandez, Pomeroy 

90

Map 6. Location of artificial reefs in the Gulf of Mexico. 

Discussion: Unresolved Issues and Concerns 

 Despite the NFEA, there remain a number of issues and concerns associated with the 

use of rigs as artificial reefs. In an analysis of interviews with state artificial reef managers, 

Murray (1994) describes the current status of artificial reef programs in relation to 

administration, budget, siting, promotion, education, evaluation, future trends and major 

concerns. The major issues and concerns that state artificial reef managers raise are as follows 

(Murray 1994): 

(1) The Liability Issue. Since the publication of the National Artificial Reef Plan, which 

recommended that the US Army Corps of Engineers develop specific permit standards and 

conditions, the issue of liability remains vague and unclear. The Corps has developed a policy 

requiring the permit holder of an artificial reef to prove adequate liability coverage. States 

with reefing programs have assumed the role of the permittee. This has necessitated a close 

review of the role of the states and localities in implementing the NFEA (Murray 1994). As 

Murray (1994: 965) writes in an analysis of the interviews with state artificial reef managers: 

Because most private fishing associations cannot afford the insurance 

premium, many states have assumed the role of the permittee. Although many 

state managers welcomed this as a way of gaining control of artificial reef 

activities, it has necessitated a closer inspection of each state’s liability. The 

level of concern varied widely, but the general consensus was the clarification 

is needed from the state’s attorney general’s office. Most reef managers felt 

that even this would be vague and subject to interpretation until a case comes 

before a court. 

Clarification of this issue would improve operational procedures and potentially reduce 

uncertainty about exposure on the part of state artificial reef managers (Murray 1994: 968). 

(2) Scientific Uncertainty: Production versus Aggregation. State artificial reef managers 

remain concerned about the production versus aggregation question. It remains unclear if rigs 

attract or produce fishes. As Murray (1994: 966) writes, “One troublesome issue is related to 

the inability of artificial reefs to assist fishery production at all stages of the life cycle.” 

Source: Gulf States Marine Fisheries Commission 

Source: Gulf States Marine Fisheries Commission 
The Politics, Economics, and Ecology of Decommissioning Offshore Oil and Gas Structures 

91

Artificial reef managers are concerned that too much emphasis has been placed on adult 

fishery enhancement activity and not enough on restoring essential coastal processes, such as 

estuarine habitats and wetland ecosystems (the “nurseries of the sea”). 

(3) Limited Funding. State artificial reef program funding remains a major concern of 

administrators and managers. In 1988, the average reported annual budget for reef programs 

was $139,000, with a range of 0$ to $400,000 (Murray 1994: 962). Most funds are generated 

from either state appropriations or Wallop-Breaux funds, which refer to the 1984 WallopBreaux Amendment to the Federal Aid in Sport Fish Restoration Act (16 U.S.C. sec. 777 

(1988)). 

 Oil companies that “donate” structures are asked to contribute half of the disposal 

savings realized to the Fund. In a description of this process, Reggio and Kasprzak (1991: 15) 

write: 

Negotiations to obtain platforms and to determine the amount of donation are 

done on a case-by-case basis between the oil and gas operator and the state. 

The size, location, distance from shore, water depth, resale value, and 

proximity of the platform to the permitted reef site all affect the cost of 

converting a rig into a reef; thus, it is not always cost-effective for operators to 

participate. 

State artificial reef programs maintain an average staff size of 1 full-time employee. In 

addition, monitoring of existing artificial reefs and regulatory compliance issues remain 

important concerns of state artificial reef managers in the Gulf. State artificial reef programs 

have not received adequate funding (Murray 1994: 967). 

Conclusion 

 This section described the political, problem and policy streams that met to form a 

policy window of opportunity for the rigs-to-reefs alternative in the Gulf region. In the case of 

the Gulf, an advocacy coalition that combined the interests of the oil industry, recreation and 

commercial fishing, scientists, and resource managers supported the use of offshore rigs as 

artificial reefs. The development of oil and gas in the Gulf OCS led to an increase in 

commercial and sports fishing activity. Scientific reports and workshops spoke to the benefit 

of artificial reefs in the Gulf. States and local artificial reef programs had been established 

before the passage of the NFEA. In passing the NFEA, the federal government granted 

discretionary authority to states to create their respective rigs to artificial reef program. Many 

of these programs were based on existing artificial reef programs. 

 Despite the passage of the NFEA, there remain a number of management issues and 

concerns that have not been clearly addressed by federal and state resource policymakers who 

are interested in artificial reef development and building. 
Final Study Report – McGinnis, Fernandez, Pomeroy 

92

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The Department of the Interior Mission 

As the Nation's principal conservation agency, the Department of the Interior has responsibility for most 

of our nationally owned public lands and natural resources. This includes fostering sound use of our 

land and water resources; protecting our fish, wildlife, and biological diversity; preserving the 

environmental and cultural values of our national parks and historical places; and providing for the 

enjoyment of life through outdoor recreation. The Department assesses our energy and mineral 

resources and works to ensure that their development is in the best interests of all our people by 

encouraging stewardship and citizen participation in their care. The Department also has a major 

responsibility for American Indian reservation communities and for people who live in island territories 

under U.S. administration. 

The Minerals Management Service Mission 

As a bureau of the Department of the Interior, the Minerals Management Service's (MMS) primary 

responsibilities are to manage the mineral resources located on the Nation's Outer Continental Shelf 

(OCS), collect revenue from the Federal OCS and onshore Federal and Indian lands, and distribute 

those revenues. 

Moreover, in working to meet its responsibilities, the Offshore Minerals Management Program

administers the OCS competitive leasing program and oversees the safe and environmentally sound 

exploration and production of our Nation's offshore natural gas, oil and other mineral resources. The 

MMS Royalty Management Program meets its responsibilities by ensuring the efficient, timely and 

accurate collection and disbursement of revenue from mineral leasing and production due to Indian 

tribes and allottees, States and the U.S. Treasury. 

The MMS strives to fulfill its responsibilities through the general guiding principles of: (1) being 

responsive to the public's concerns and interests by maintaining a dialogue with all potentially affected 

parties and (2) carrying out its programs with an emphasis on working to enhance the quality of life for 

all Americans by lending MMS assistance and expertise to economic development and environmental 

protection.