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California Offshore Partial Platform Removal And Decommissioning Study On The Pacific OCS

by Tomas DiFiore
The Laws Are Flawed, But The Model Outputs Are Robust - Are Oil Platforms Off California The Most Productive Marine Fish Habitats Globally? The heralded October Report seems to be more of a PR piece, and as such, is a typical component currently in the petroleum industry PR. It's timing conjuncts with continuing discussions of the 2010 Rigs to Reefs decision in the California Legislature and the approaching time for permitting decommissioning. AB 2305 “The California Marine Resources Legacy Act” passed in September 2010, notes that the 23 platforms in federal waters offshore of California, are not expected to be ready for decommissioning until sometime between 2015 and 2030.
800_don_t_frac_my_ocean.jpg
End Of Your Line
2014 Partial Platform Removal And Decommissioning Study On The Pacific OCS

There are 27 oil and gas platforms in the waters off California. The platforms are located between 1.2 and 10.5 miles from shore and at depths ranging from 11 to 363 m or in English that's 35 to 1,198 ft. All platforms have finite economic life spans and more than a few California platforms may be nearing an end. Once an industrial decision is made to cease oil and gas production at a platform, managers must decide what to do with the structure, a process known as decommissioning. The Bureau of Ocean Energy Management (BOEM) defines decommissioning as the process of ending operations and returning the lease or pipeline right-of-way to a condition that meets the requirements of the regulations.

There are strict federal requirements, but now since 2010, in California, with the controversial passage of AB 2503, “The California Marine Resources Legacy Act”, there is the option of partial removal to somewhere about 85 feet below sea level.

Understanding the effects of the different decommissioning options on the biology of fishes living in such altered habitats will be important information to consider on a global scale. There are at least 188 decommissioned platforms in the Gulf of Mexico which have remained in Gulf waters, continuing to function at some level as artificial reef habitat since 1947; however, the ecological impact assessment of these structures has been limited, and since the Macondo well blowout – now a mute point.

Federal law prior to 2010, required the platform operators to remove the structures entirely and to restore the seabed to its pre-drilling condition. Platform operators had to remove them completely after they reached the end of their useful lives. This new law, Assembly Bill 2503, authorizes the State to consider allowing platform operators the option of leaving most of the platform in place, (the bulk of the steel segments of the midwater sections to the seafloor,) as so-called "rigs-to-reefs" conversions.

Decommissioning of the more than 7500 oil and gas platforms around the world is an unavoidable ecological issue. Decommissioning is the process by which the fate of these structures is determined and typically results in one of four alternatives: complete removal, toppling, partial removal, or leave-in-place.

In the “rigs-to-reefs” approach, some portion of the platform is left in the water to continue functioning as an artificial reef. Yet unresolved concerns are the degree to which these types of structures enhance ecosystem function and services, and in particular secondary fish production, compared to natural reefs.

2014 Rigs-To-Reefs Partial Platform Removal And Decommissioning Study

“Biological Productivity Of Fish Associated With Offshore Oil And Gas Structures On The Pacific OCS”, is the full title of the 2014 study. The chapter heading for Chapter One became the lead headline across the nation on October 22, 2014 in a commentary by Jonah Goldberg; “Oil Platforms Off California Are The Most Productive Marine Fish Habitats Globally” a.k.a. 'Oil Platforms Off California, The Ecological Skyscrapers Of The Sea'

Are Oil Platforms Off California The Most Productive Marine Fish Habitats Globally?
Survey Data Gaps And Productivity Modeled Estimates Of New Fish Biomass:
An Order Of Magnitude Of Deception Beyond 1000 Percent More Fish

“Applying this model, it was found that oil and gas platforms off the coast of California have the highest secondary fish production of any marine habitat that has been studied.” The authors created the model, it should work!

Based on subsets of the mathematical differences between estimated observed biomass, predicted biomass, and estimated new recruitment of biomass, the recent study adds nothing to the discussion of artificial reefs and decommissioning of offshore platforms.

Data for the well publicized study was obtained from singular annual visual surveys conducted during daylight hours in the fall using the manned Delta research submersible from 1995 through 2009 and the Dual Deepworker in 2010 - 2011. A researcher aboard identified, counted and estimated the total lengths to the nearest 5 cm (2 inches) of all fishes....

“Since different subsets of platforms were surveyed each fall, we used data from the 16 platforms that had been surveyed for at least 5 years, some of which had been surveyed up to 15 years.” p22 of 70 (or document page 13)

“Fish abundance was measured visually and changes in biomass were estimated from those observations. If, during a year when a platform was sampled, the platform base habitat was not sampled - typically due to limited visibility, the mean of its available annual values were used. Additionally, there was limited data from successive years for many sites.” And where necessary, “the mid-water platform estimates of increases in fish biomass were used in place of shallow depth platform estimates which were lacking for several of the platforms.”

Love it, what kind of grade should they get for effort?

Abundance Of Offshore Rigs

On Friday, October 24, 2014, California and The Nation summed it up quite cogently. “The researchers could not determine if the thriving habitat was due to higher fish productivity or its attraction to passersby.”
http://www.allgov.com/usa/ca/news/california-and-the-nation/california-offshore-oil-rigs-are-the-worlds-best-fisheries-141024?news=854617

Upon translation, that poses an as yet unanswered questions:
Do artificial reefs serve as productive marine fish habitats (sources) or do fish assemblages of such reefs contribute little to the gene pool of succeeding generations (sinks)? Similarly, an unanswered question suggests: Do these structures attract fish from nearby natural reefs?

This particular scientific report seems to me to be more of a PR piece, and as such, is a typical component in the Public Awareness campaign PR of corporate media. It's timing conjuncts with continuing discussions of the 2010 Rigs to Reefs decision in the California Legislature and the approaching timeline for decommissioning.

A New Modeling Metric:
Marine Resource Conservation and Boardroom Office Emerging Metrics (MRC and BOEM)

“To calculate the annual secondary production for a fish community the researchers developed a model based on previously collected fisheries-independent density and size structure data of fishes from visual surveys performed from a manned submersible once per year for between 5 and 15 years at each site.”

Per platform, the average data entry points were from 5 singular daytime observations with interval periods of one year. Not necessarily subsequent years, or even the same portion of water column, and often not even the same same platform for which data was eventually used to compute Total Production.

“Estimates of secondary fish production, particularly those which attempt to estimate the production of an entire community, have been relatively limited in marine ecosystems and most involve shallow nearshore and estuarine environments. Methods employed most commonly calculate fish production as the product of average biomass and specific growth rate over a time interval, typically one year. As average biomass is the metric used, this can account for immigration and emigration (of settlers, juveniles and adults), assuming that samples are taken frequently enough to accurately quantify fish in the sampling area during the time interval.”

“Assuming that samples are taken frequently enough to accurately quantify fish in the sampling area during the time interval.” That is not the case in the current study.

The metrics for the current 'Partial Platform Removal' study had to be changed, the model was built upon estimate after estimate of biomass production values with no empirical data, because the quantifiers (samples which are taken frequently enough to accurately quantify fish in the sampling area during the time interval) could not be attained with any certainty, with data collected through visual observations based on one day per year surveys of entire assemblages of marine life associated with offshore platforms. TD

Available for viewing - download PDF at:
http://www.oxy.edu/vantuna-research-group/publications

Biological Productivity Of Fish Associated With Offshore Oil And Gas Structures On The Pacific OCS - Authored by: Jeremy T. Claisse, Daniel J. Pondella, II, Milton Love, Ann S. Bull

The entire study breaks down right there, and should be renamed “2014 Partial Platform Removal And Decommissioning Study On The Pacific OCS”.

A Reel Big Fishing Tale

Secondary production is usually measured at the population level. This study summed it across members of a fish assemblage to yield an estimate of community secondary production.

As a metric of Secondary Production in this study, Total Production of the fish assemblage or community is actually the sum of two components: “Somatic Production” which is the difference between the observed biomass during surveys and the biomass predicted one year later using species-specific morphometric, growth and mortality functions, added to “Recruitment Production” which estimates production from the immigration, growth and survival of larval and pelagic juvenile fishes over the year time interval.

Specific Estimates Of Total Production, Somatic Production, Recruitment Production

Species-Specific Morphometric functions (the quantitative analysis of form) usually involve catching the observed fish and determining various relationships of characteristics to weight.

“Since 1993 when a study of Atlantic cod showed growth rates significantly correlated with otolith shape (parts of the inner ear in vertebrates), morphometric analysis has been used as a tool to detect stock structure and interannual variability in a number of fish species. Linear measurements between landmark points (truss analysis), calculated geometries (e.g., circularity), and two-dimensional (Fourier series) shape analysis of otoliths are methods typically employed. Otolith attributes are expressed under the control of genetic, physiological, and environmental factors. Finfish have three pairs of otoliths. The sagittae are largest, found just behind the eyes and approximately level with them vertically. The lapilli and asterisci (smallest of the three) are located within the semicircular canals.”

Now going to Wikipedia:
“The shapes and proportional sizes of the otoliths vary with fish species. In general, fish from highly structured habitats such as reefs or rocky bottoms (e.g. snappers, groupers, many drums and croakers) will have larger otoliths than fish that spend most of their time swimming at high speed in straight lines in the open ocean (e.g. tuna, mackerel, dolphinfish). Often, the fish species can be identified from distinct morphological characteristics of an isolated otolith.”

“Fish otoliths accrete layers of calcium carbonate and gelatinous matrix throughout their lives. The accretion rate varies with growth of the fish, often less growth in winter and more in summer, which results in the appearance of rings that resemble tree rings. By counting the rings, it is possible to determine the age of the fish in years. Typically the sagitta is used, as it is largest, but sometimes lapilli are used if they have a more convenient shape. The asteriscus, which is smallest of the three, is rarely used in age and growth studies.”
http://en.wikipedia.org/wiki/Otolith

Total Production in this (2014 Claisse et al.) study is hardly a quantifiable numerical value. It's stated as the difference between predictions of future biomass and the estimated biomass of fishes observed during the surveys based on single day observations often over a year apart, added to estimates of production from the immigration, growth and survival of larval and pelagic juvenile fishes, based on previous publications....

The “Somatic Production” component, also accounts for “losses due to mortality by including a species- and size- specific natural survivorship function. Since rockfishes tend to have high site fidelity the calculations of the Somatic Production component also assume immigration and emigration of adults and post-settlement juveniles are equal. However, over the course of the one year time interval, it is estimated that additional larval and pelagic juvenile fishes will also recruit to the habitat. Therefore, the study accounts for the production from their subsequent growth and survival in the “Recruitment Production” component of Total Production.”

It Is Estimated That By Applying This Model

“Applying this model, it was found that oil and gas platforms off the coast of California have the highest secondary fish production of any marine habitat that has been studied, about an order of magnitude higher than fish communities from other marine ecosystems.”

But as described in California and The Nation “the researchers also point out that new offshore wind farms may have a secondary benefit of providing new, thriving habitats without some of the drawbacks of oil and gas rigs.”
http://www.allgov.com/usa/ca/news/california-and-the-nation/california-offshore-oil-rigs-are-the-worlds-best-fisheries-141024?news=854617

We've Lost The Gulf Of Mexico As A Productive Ecosystem,
But Not As An Oil And Gas Producing Region

A massive oil spill is difficult to compare to the steady leakage of oil around an offshore drilling platform and of which there are few studies in US waters. Yet given the loopholes in regulations for oil and gas exploration effluent discharge and 'State Primacy EPA Sanctioned Authorization and Permits for lethal toxicity levels of components in production drilling fluids, drilling muds, frac flowback and produced water effluent discharges, “the study does not touch on any possible health hazards that might accompany the world’s greatest fisheries.”

Oil-rig fishing though is “action-packed, and always full of surprises, as you never know what type of fish will be at the end of your line,” a charter company in the GOM (Gulf Of Mexico) says on its website. Experienced anglers speak of sets of tackle (rigging for the rigs) that are lost on every fishing trip. Another one of the surprises is the condition of the fish.

A study of the West Florida Shelf after the BP Deepwater Horizon spill found fish with lesions and deformities linked to chemical signatures of oil compounds in their systems.
http://www.roffs.com/2014/03/oil-research-western-florida-shelf/

Other studies have found that fish exposed to BP oil swim half as fast,
http://www.smithsonianmag.com/smart-news/fish-exposed-oil-bp-gulf-spill-swim-half-fast-180951828/?no-ist
the crab catch has declined dramatically
http://krilloil.com/blog/the-deepwater-horizon-oil-spill-and-its-aftermath/
and oysters disappeared. Dolphins were found suffering from numerous maladies. Other fish avoided horrible consequences by leaving the area and not returning.

In California offshore waters, the question remains open as to overall contribution to ecosystem functions and services of any remnants of platforms remaining on the ocean floor.

Decommissioned And Active Rigs As Artificial Reefs

Confusion in the press has recently led to disinformation and a general dumb down of the public regarding concerns of not only new offshore oil drilling, but the decommissioning of old offshore oil platforms worldwide. The Jonah Goldberg Commentary was only too obvious, but the National Academy of Sciences also has trumpeted; “one benefit of drilling... fish, it turns out, are turning the underwater portions of the rigs into the equivalent of apartment towers.” But drilling and effluent discharges are not the subject or even mentioned in the study, the issue of partial removal of offshore platforms and their subsequent use as artificial reefs, is the subject matter.

In 2010, after much public debate, California lawmakers fast-tracked and passed Assembly Bill 2503, which established a state program for artificial reef research and development that would allow conversion of decommissioned oil platforms into artificial reefs.

An important commentary, was published by the Environmental Law Center in L.A. subsequent to the 2010 passage of California's Rigs To Reefs Partial Removal Option For Offshore Platforms. It's a full review containing accurate history and critical analysis of the situation in California State waters and the OCS that we face today.

Southern California Environmental Report Card, Fall 2010
http://www.environment.ucla.edu/reportcard/article9389.html

In PDF format:
http://www.environment.ucla.edu/media/files/RC-Rigs-to-Reef-Law-Fall2010.pdf

“In the 1960s, both the California state government, which owns the seabed up to three miles offshore pursuant to the federal Submerged Lands Act of 1953, and the federal government encouraged offshore oil drilling. In 1969, an enormous quantity of oil leaked from an offshore drilling site and blanketed over 30 miles of coastline in the Santa Barbara area. After that, California stopped permitting development of new drilling platforms in State waters. The federal government continued to make new oil leases available until 1984, when Congress enacted a moratorium on using federal funds for new oil lease development off the California coast.”

With the passage of AB 2503 in 2010, “The California Marine Resources Legacy Act”, the State of California is now considering the option of partial removal for decommissioning offshore oil platforms as an alternative to complete removal. Specified criteria must be met, including a finding that conversion to an artificial reef would provide a "net benefit" to the environment as compared to removal of the facility (California Marine Resources Legacy Act 2010).
http://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=200920100AB2503

Decommissioning May Begin In 2015 Offshore Of California

“Given the quantity of biological information currently available for platforms in California, the determination of what constitutes a “net benefit” is still under consideration, and therefore there is a critical need to understand the biological productivity of these structures and how partial removal may impact associated processes.”(Claisse et al. 2014)

Please read that again. “Given the quantity of biological information currently available for platforms in California....”The only citations listed are “(e.g., Love et al. 1999; Love et al. 2003; Schroeder and Love 2004; Love et al. 2006; Love et al. 2012)”

Remember now, the research paper, perspective and methodology of modeling used to compute Total Productivity of 16 California Offshore Platforms were based on observations made during one day per year of site sampling, in the fall, during daylight hours, leading to great deficiencies in the calculated margin of error inherent in the new modeling and metrics, and gleaming gaps in the general confidence level of non-consecutive year field data sets.

Even Oceana, an advocacy organization that supported California's rigs-to-reefs law, has noted that "while oil platforms may appear to benefit certain species and recreational stakeholders, decisions on decommissioning must also take into account there is no evidence platforms provide net ecological benefits to the marine ecosystem as a whole relative to areas left in their natural state."

The current study, “Biological Productivity Of Fish Associated With Offshore Oil And Gas Structures On The Pacific OCS”, was jointly authored by: Jeremy T. Claisse, Daniel J. Pondella, II, Milton Love and Ann S. Bull, and recently submitted for peer review in 2014 by Jeremy T. Claisse. But only the title of Chapter one has made the headlines in every State; “Oil Platforms Off California Are The Most Productive Marine Fish Habitats.”

“Rigs To Reefs” The California Marine Resources Legacy Act 2010

There is the likelihood that the Pacific may be the first region where platforms in deeper water are going to be decommissioned. California's process for decommissioning under AB 2503, “The California Marine Resources Legacy Act” will undoubtedly be used as a model for offshore deepwater platform decommissioning elsewhere in the world.

According to the authors, there are two stated goals of the study. The first is to determine the patterns of standing stock (fish biomass) and production at platforms throughout southern California and compare these metrics to natural reefs in the region and to 'published estimates of production from other marine ecosystems.' Remember that phrase.

Only one source is ever cited throughout the 2014 study, and that is in relation to studies of global estuarine environments (Costanza et al. 1993).

One day per year was devoted to field observations gathering critical data!

The second goal of the study is to estimate the amount of fish biomass and production that will be retained after partial removal and for fish communities that reside on the platform and on shell mound habitats which surround some of these platforms. Biological metrics were estimated on the shell mounds surrounding 12 platforms. Total Production density on shell mounds varied considerably across sites. The shell mounds that covered small areas of seafloor had very low estimates of Total Production.

Two Goals, Two Chapters

Chapter One:
Oil Platforms Off California Are The Most Productive Marine Fish Habitats Globally

Chapter one compares the density, biomass and annual secondary production of fish communities on 16 oil and gas platforms to those on 7 natural reefs off the coast of southern California and to secondary production estimates of fish communities from other marine ecosystems. “To calculate the annual secondary production for a fish community we developed a model based on previously collected fisheries-independent density and size structure data of fishes from visual surveys performed from a manned submersible once per year for between 5 and 15 years at each site.”

Chapter Two:
The Impact Of Partial Removal Of Southern California Oil And Gas Platforms On The Associated Fish Biomass And Production

The second chapter evaluates the potential effects of partial removal of 16 platforms off of the coast of southern California on the biomass and production of the fish associated communities.

In Chapter one it is discussed how it is determined that oil and gas platforms off the coast of California “have the highest secondary fish production of any marine habitat that has been studied, about an order of magnitude higher than fish communities from other marine ecosystems”.

Chapter two, discusses that on 15 out of the 16 platforms modeled, at least 80% of both fish biomass and secondary fish production would be retained after partial removal, with above 90% retention expected for both metrics on many platforms. It was also found that shell mounds are moderately productive fish habitats. The shell mounds are composed of mostly the shells of mussels, which live attached, to the steel ecosystem nearer the surface waters.

The two main goals of this research are related by default. The first is to determine the patterns of fish biomass and production at platforms throughout southern California and compare these metrics to both natural reefs in the region and to previously published estimates of production from other marine ecosystems (Costanza et al. 1993). The second is to estimate the amount of fish biomass and production that will remain on platforms after partial removal and for fish communities that reside on the shell mound habitats which surround some of these platforms.

Standing Stock Biomass Modeling Metrics (SSB)

The computational modeling of Total Production in the study paper “Biological Productivity Of Fish Associated With Offshore Oil And Gas Structures On The Pacific OCS”, has only recently been submitted for peer review in 2014. In it, the oil and gas platforms off the coast of California have the highest secondary fish production of any marine habitats that have been studied. “The mean annual production per square meter of seafloor for the platforms was 27.4 times as much as is produced per square meter on natural reefs.”

“When platforms are evaluated individually, their annual production tended to be an order of magnitude higher than that of fish communities in other marine ecosystems where similar types of measurements have been made. Most previous estimates have come from estuarine environments, generally regarded as one of the most productive ecosystems globally.

Only one source is ever cited throughout the 2014 study, that being (Costanza et al. 1993).”

“The high rate of fish production on these platforms ultimately results from high levels of larval and pelagic juvenile settlement and subsequent growth of primarily rockfishes (genus Sebastes) to the substantial amount of complex hardscape habitat created by the platform structure distributed throughout the water column.”

“Further, partially removed platforms would still have some of the highest production values (scaled to per square meter of seafloor) of any marine habitat globally. Many of the rockfishes that make up a substantial proportion of the biomass and production on platforms are important to recreational and commercial fisheries, and two, bocaccio and widow rockfish, are currently managed under federal rebuilding plans. The fisheries rebuilding potential of these platform habitats should not be substantially affected if partial removal is chosen as the preferred option for decommissioned platforms.”

But there is no proven fisheries rebuilding potential of these platform habitats! The debate over AB 2305 went something like this: sport fishing supported it, commercial fishing opposed it. Of course for the really big picture, it is best to visit the (EDC) Environmental Defense Center website. The EDC were deeply involved (the platforms are just offshore) and took a strong stance of opposition to AB 2305 The California Marine Resources Legacy Act 2010. Learn about Oil Platform Decommissioning on the Pacific OCS:
http://www.edcnet.org/learn/current_cases/offshore_oil/rigs_to_reefs/

“2014 Pacific OCS Partial Platform Removal And Decommissioning” Study Highlights

“High rates of fish production for the complete platforms are achieved because the platform jacket, horizontal crossbeams, conductors, and pilings create a complex structure that provides a large surface area of hard substrate throughout the water column. This supports a diverse community of sessile and motile invertebrates that, along with planktonic food resources, provide the base of the food web for platform fishes.”

“Relatively few taxa contributed more than 5% of the Total Production across all habitats. This is a common pattern in other ecosystems, where the production of a fish assemblage is typically dominated by a few of the species. In all habitats studied here, the biggest contributors were various rockfish species (genus Sebastes) and Lingcod (Ophiodon elongatus). Larger-bodied species such as Lingcod (Ophiodon elongatus) and Bocaccio (Sebastes paucispinis), contributed more to production because they have relatively high growth and survival rates even though they were not the most abundant species. However, some smaller-bodied species, such as Halfbanded Rockfish (S. semicinctus) and Squarespot Rockfish (S. hopkinsi), also contributed substantial amounts of secondary production because they were very abundant.”

“It has been demonstrated that rockfish and mussels (Mytilus spp.), one of the dominant filter feeding invertebrates on platforms, can grow faster in these offshore artificial environments than they do in their corresponding natural habitats” (Love et al. 2007).

Steel Girders And Shell Mounds

“Shell mounds” are biotic reefs that surround some of these platforms resulting from an accumulation of shells that have fallen from the shallow areas of the platform structure mostly above the depth of partial removal. The study found that shell mounds are moderately productive fish habitats, similar to or greater than natural rocky reefs in the region. The complexity and areal extent of these habitats, and the associated fish biomass and production, will likely be reduced after either partial or complete platform removal. Habitat augmentation by placing the partially removed platform superstructure or some other additional habitat enrichment material (e.g., rock boulders) on the seafloor adjacent to the base of partially removed platforms provides additional options to enhance fish production, potentially mitigating reductions in shell mound habitat.”

The Steel Ecosystem Food Web

The shells that fall only exist near the surface segment of the platform, the section considered for 'partial removal'. The shells will not continue to fall to the seafloor and build up as mounds. The mussel, while in the shell is considered to be an essential component of that “diverse community of sessile and motile invertebrates that, along with planktonic food resources, provide the base of the food web for platform fishes.” The logic seems to falter here a bit with the partial removal option and “additional options to enhance fish production, potentially mitigating reductions in shell mound habitat.”

But aggregate biomass computations can be like that.

Globally thousands of oil and gas platforms are set to be decommissioned over the coming decades, new structures associated with emerging wind and wave energy technologies are being deployed in the marine environment, and human activities are threatening fish populations on natural reefs. AB 2305 notes that the 23 platforms in federal waters offshore of California, are not expected to be ready for decommissioning until sometime between 2015 and 2030.

Vertical Horizons And Rock Substrate - Population Biomass Mitigation 101:

“The first key difference between the Gulf of Mexico and California is the amount of natural nearshore rocky bottom and reef area. In the northern Gulf of Mexico where the majority of the oil and gas platforms are located, the ocean bottom is typically clay, silt or sand with little or no relief (Kasprzak 1998) and the few natural reefs that do occur are located 75 or more miles offshore (Stanley and Wilson 1989). There is a paucity of nearshore rocky reef habitat, particularly off the coasts of Louisiana and Texas. It has been estimated that hard bottom and reef habitats constitute about 1.6% of the total area of the Gulf of Mexico (Wilson et al . 1996). By contrast, rocky reef habitat is far more abundant along the coast of Southern California and within the Southern California Bight. Although the precise amount of subtidal rocky habitat off the California coast is not known, there are extensive areas of rocky intertidal and shallow subtidal habitats as well as offshore reefs.”

“A second difference between the Gulf States and California involves the level of oil and gas development in each region. There are several thousand oil and gas platforms in the Northern Gulf, and only twenty-seven off California.”

The “Partial Platform Removal And Decommissioning Study” published Oct 13, 2014, concludes that although platforms represent a small contribution to the overall hard substratum of California offshore waters, “these structures may be providing a large amount of the hard substrate below a depth of 50 meters. Therefore, deeper water platforms may provide considerable hard substrate in the soft-bottom outer shelf regions in which they occur.”

Now is that a tongue twister of mind boggling logic from the:
Oil and Gas Industry PR Preparedness Program Campaign On Public Perception (PRPPCPP)

Another dissenting opinion...
Blogging On Peer Reviewed Research
Artificial Habitat - Adventures in marine biology and science

“One of the longest running controversies in artificial reef research has come to be known as the ‘attraction versus production’ debate. This concerns the high densities of fish often found around artificial reefs (in many cases greater than those around natural reefs). The question, essentially, is this: are these high densities the result simply of attraction of fish from the surrounding areas (which might be undesirable), or do artificial reefs actually provide additional useful resources which translate into increases in fish biomass?”

“A 2006 study of artificial reef systems in the waters off California compared two offshore oil platforms (artificial reefs) with two natural rocky reef outcrops. The results were interesting in a number of respects.”

“Firstly, there were differences in the assemblages of small mobile invertebrates. On the natural reefs a greater proportion of potential prey animals were non-amphipod species, whereas amphipods (small shrimp-like crustaceans) were more numerically dominant on platforms. Within the amphipods, there were further differences. The platforms had large abundances of certain exotic (invasive) amphipod species absent from or very rare on the nearby natural reefs. And so it’s worth making note of the fact that these structures provide suitable habitat for invasive species, and that this might be a concern.”

“Why might platforms have different species compositions than reefs? Platforms are built from different material than natural reefs and they have a very different structure. Platforms extend from the seabed, vertically up to the sea surface, so a high proportion of the available surfaces are vertical instead of horizontal or more gently sloping (as on most natural reefs). They are also often quite far offshore, and are very young habitats compared with natural rocky outcrops.” Andrew Guerin, January 16, 2008
http://artificialhabitat.wordpress.com/2008/01/16/comparing-fish-feeding-on-rigs-and-reefs/

The Laws Are Flawed, But The Model Outputs Are Robust

US Global Offshore Energy Resources, including the Arctic, Alaska, Washington, Oregon, California, North Carolina and New York are being mapped and explored. Environmental protections and Public Health Safeguards are relegated to the fine print of appendixes and future mitigation scenarios and economic feasibility of best available technologies.

The authors of the 2014 Partial Platform Removal And Decommissioning Study On The Pacific OCS state that “complete platform removal is typically done by detonating explosives 5 m below the seafloor to sever the well conductors, platform anchor pilings, and support legs. The use of explosives results in the mortality of most fishes associated with the platform, i.e., effectively the eliminating the entire fish biomass and subsequent production associated with the platform.” This ridiculous explosive technique can never be allowed in California Offshore waters! Mechanical methods are used in approximately 35% of all removal operations. Bureau of Safety and Environmental Enforcement (BSEE)
http://www.bsee.gov/Exploration-and-Production/Decomissioning/FAQ/

“One of the few known observations of fish damage in zones of explosive activity was done in 1992 in the Gulf of Mexico near the shore of Louisiana and Texas. In order to remove over 100 fixed platforms and other structures, more than 12,000 kg of plastic charges were exploded. The amount of dead fish floating on the surface was visually recorded after the explosions. It totaled to about 51,000 specimens. The actual number of killed fish was undoubtedly higher because many specimens could not float to the surface or did not get in the zone of visual observation.”

Offshore Oil Rig Abandonment Detonations, Idle Iron: Gulf of Mexico
https://www.youtube.com/watch?v=zsL7NcBoNIU&list=PLtz8Vqwa9PrtjPSgglAJrk8Nm4W5GzpzC

Decommissioning oil and gas installations can cost operators an average of $4-$10 million in the shallow water Gulf of Mexico. Thus when the US Department of the Interior Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE) Gulf of Mexico OCS Region issued a new decommissioning regulation in September 2010, operators knew they'd take a hit.

The Notices to Lessees and Operators NTL 2010-G05 require wells that have not been used for the last five years to be to be permanently abandoned, temporarily abandoned, or zonally isolated within 3 years after Oct. 15, 2010. If wells are zonally isolated, operators have 2 additional years to permanently or temporarily abandon the wellhead. Plus, platforms and supporting infrastructure that have been idle for five or more years must be removed within 5 years as of the Oct. 15, 2010 effective date.
http://www.rigzone.com/training/insight.asp?i_id=354


The Huffington Post ran a piece in Sept 2014 and then updated it on November 3, 2014.

“The Realities of Decommissioning an Active, Offshore, Oil-producing... Fish Skyscraper”

“Currently, complete or partial removal of steel or concrete fixed platforms that weigh thousands of tons is practically impossible without the use of explosive materials. In most cases, bulk explosive charges have been used as a means to this end. These explosives have a very powerful, short-term impact on the marine environment and biota, which should not be neglected. For example, detonating a 2.5-ton (TNT equivalent) charge, would typically result in a mass of killed fish weighing about 20 tons. This number does not account for the passing school of herring that happens to pass through that zone, in which case the fish kill figure may be much higher. So how is an offshore platform decommissioned?”

The Huffington Post goes on to say that; “There are several steps involved in the process which could take upwards of 2-3 years to complete, and create removal costs of about $4-$10 million for a shallow water platform (this does not reflect the cost of removing deep water platforms where the cost exponentially increases).”
http://www.huffingtonpost.com/emily-callahan/the-realities-of-decommis_b_5761842.html

Claisse et al. and BOEM, and the OST expect removal costs of the 23 platforms on the OCS in Southern California to cost roughly $1 billion dollars.

1,000,000,000 dollars divided by 23 platforms... that's less than $44 million per platform.
How much has been pumped over the lifetime of each of these platforms?

How many total years of production (aggregate) from the 23 platforms and what are the total economic production figures both in dollars and barrels of oil? These are relative metrics to be included perhaps under CEQA evaluation of each permit authorized per AB 2305 for decommissioning offshore platforms?

Let's not forget, when the leases were signed, everyone knew the cost of doing business.

For a comparison of profits and political expenditures by the Oil and Gas Industry in California visit these sites:

Stop Fooling California:
http://www.stopfoolingca.org/about/the-facts/

So far this year, Chevron has poured an astounding $2.9 million into three campaign committees in Richmond. Of that, at least $1.4 million has gone to a committee supporting the pro-Chevron candidates and $500,000 to a committee opposing the candidate critical of Chevron, including the current mayor, Gayle McLaughlin. The figures suggest that Chevron is preparing to spend at least $33 for the vote of every resident of the city 18 or older.
http://www.latimes.com/business/hiltzik/la-fi-mh-chevron-deluge-of-campaign-money-20141013-column.html#pag&page=1

Federal Level
http://priceofoil.org/campaigns/separate-oil-and-state/

And at the State level, see the article:
A State Capitol Awash in Oil Money by Dan Bacher
http://www.californiaprogressreport.com/site/state-capitol-awash-oil-money

Oil Lobby Has Spent over $45.4 Million since 2009

“Prior to the latest Secretary of State filing, a report released by the American Lung Association revealed that the oil industry lobby, the biggest corporate lobby in California, has spent $45.4 million in the state since 2009. The Western States Petroleum Association (WSPA) alone has spent over $20 million since 2009.”

“Oil and gas companies spend more than $100 million a year to buy access to lawmakers in Washington and Sacramento, according to Stop Fooling California, an online and social media public education and awareness campaign that highlights oil companies’ efforts to mislead and confuse Californians.”

This November 4, 2014 election stakes are high dollar! Read the latest at Climate Progress.

“For evidence of the stakes in California, look no further than the industry investment in fighting the measures. Major oil and gas companies such as Chevron, ExxonMobil, and Occidental Petroleum have pumped more than $7.5 million into the pro-oil coalition Californians for Energy Independence in an attempt to defeat the bans, according to the California Secretary of State’s campaign finance database.”
http://thinkprogress.org/climate/2014/11/02/3586202/california-fracking-ban/

Based on an internal review of actual subsea wells in greater than 1,000 feet of water, BSEE in December 2013 estimated the time from start to finish as follows:
Subsea Well 25 days $20,560,000
Subsea Well 16 days $13,250,000

I suppose it's a matter of scale, like rock substrate and hardscape habitat.

NO PARTIAL REMOVAL FOR CALIFORNIA OFFSHORE PLATFORMS (OCS)

Ban Fracking And Extreme Extraction
Toms DiFiore

By invoking the 'Copyright Disclaimer' Under Section 107 of the Copyright Act 1976, allowance is made for "fair use" for purposes such as criticism, comment, news reporting, teaching, scholarship, and research. Fair use is a use permitted by copyright statute that might otherwise be infringing. Non-profit, educational or personal use tips the balance in favor of fair use."

§ 107. Limitations on exclusive rights- Fair use: Notwithstanding the provisions of sections 106 and 106A, the fair use of a copyrighted work, including such use by reproduction in copies or phonorecords or by any other means specified by that section, for purposes such as criticism, comment, news reporting, teaching (including multiple copies for classroom use), scholarship, or research, is not an infringement of copyright. In determining whether the use made of a work in any particular case is a fair use the factors to be considered shall include (1) the purpose and character of the use, including whether such use is of a commercial nature or is for nonprofit educational purposes; (2) the nature of the copyrighted work; (3) the amount and substantiality of the portion used in relation to the copyrighted work as a whole; and (4) the effect of the use upon the potential market for or value of the copyrighted work.

If you or anyone wish to use copyrighted material from this article for purposes of your own that go beyond 'fair use', you must obtain permission from the copyright owner.

STEAM INJECTION IS LITERALLY GLOBAL WARMING
constant comments, and informative research links;
http://banslickwaterfracking.blogspot.com/

Tomas DiFiore


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