Since the late 1970s, state administrations have considered decommissioned oil rigs viable alternative artificial reef structures. Rig platforms serve as habitat to marine organisms after they are installed, and provide substrate for coral and other invertebrates, shelter for fish, and enough biodiversity to attract predators and indicator species. Oil and gas companies are often financially incentivized to convert their rigs to reefs, saving up to $4 million by converting the rig rather than fully decommissioning it (Rigs2Reef Explorers). Fishermen, divers, and coastal state agencies first promoted the R2R program to address concerns about rig removal eradicating the marine species that populated the platform harbors. The U.S. requires its own policies for coastal management given its abstention from UNCLOS. In response to the cries of these stakeholders, the Bureau of Safety and Environmental Enforcement (BSEE) initiated a collaborative policy process, resulting in the creation of a federal Rigs-to-Reef program.
What is Rigs-to-Reefs?
Interest in fishing at offshore oil and gas platforms and support for effective artificial reef development from coastal states caused the U.S. congress to sign the National Fishing Enhancement Act (Public Law 98-623, Title II) on November 8th, 1984. The Act recognizes the social and economic values in developing artificial reefs, establishes national standards for artificial reef development, provides for creation of a National Artificial Reef Plan, and sets groundwork for the establishment of a reef-permitting system. While the NMFS is responsible for administering the 1984 act, it’s BSEEs responsibility to give out permits for the installation and decommissioning of temporary facilities on the Federal Outer Continental Shelf (OCS). Companies are required to remove structures and the clear the seabed of all obstructions, ostensibly returning the seafloor to its unaltered state. (Marine construction studies have shown that identical habitat to that which was lost to construction cannot always be created as a mitigation or restoration measure (see Mazik and Smyth, 2013), though.) However, coastal states were increasingly concerned by the damage done to marine life that had grown on the rigs during their installation when those structures are removed. BSEE responded by adopting this national Rigs-to-Reefs conversion policy.
For a rig-to-reef to work, a coastal state has to have an approved, state-specific artificial reef plan. All artificial reefs on the Atlantic Coast are regulated under the Atlantic States Marine Fisheries Commission. All the five Gulf of Mexico coastal states (AL, FL, LA, MS, TX) have individual plans and have incorporated decommissioned platforms into their artificial reef programs. For a platform to be suitable for use as a reef, it has to meet certain engineering and environmental standards established in federal and state codes. Platform size, complexity, structural integrity and location are the key considerations in evaluating its reef potential. Complex, stable, durable and clean platforms are generally candidates for reefing; those that toppled over due to structural failure are not eligible. As of July 1, 2015, 470 platforms had been converted to permanent artificial reefs in the Gulf of Mexico, each eight-leg structure providing habitat for up to 14,000 fish (Coastal Marine Institute).
Ecological and Economic Protections
The Rigs-to-Reef program is a long-term program for artificial reef development with the potential to aid habitat creation and conservation efforts, enhance fisheries, and expand economic opportunities. Depending on location, depth, and type, researchers continue to find ways in which rigs can be tailored to strengthen biodiversity and habitat quality at low cost.
Ongoing research notes the ways in which rigs replicate natural reefs and support the expansion of species range. Increased coral adhesion or growth and algae migration from other reefs found on oil rigs make them a fitting supplement to natural reefs (Powers et al., 2003). As time goes by and the reef matures, indicator species like Hawksbill Turtles (Eretmochelys imbricata) have been found foraging near artificial reef in offshore Borneo (Jagerroos and Krause, 2016). In California, offshore reefs show significant growth in the number of red snapper (Macreadie, 2011). Depending on the location and installation, Sayer and Baine (2002) note a difference in the number of species and depth profile on offshore oil rigs. More microinvertebrate taxa have been found on steel rigs, demonstrating that steel structures are suitable for invertebrates (Macreadie et al., 2011). Interestingly, that study also noted that deep sea geographic connectivity to other reefs might contribute to the distribution of taxa. Adding artificial reefs could increase ecological connectivity, and their location can be specifically calculated to maximize ecological benefits. Being near oil drilling activity does not necessarily provide negative affect to growth or physical condition for reefs (Sayer and Baine, 2002), except in the obvious instances of major spills like Deepwater Horizon in 2010. (This feels like a massive oversimplification of the environmental, economic, and social cost of oil spills and oil-dependency in general, but what do we do with these dinosaur skeletons sitting thousands of feet deep in the Gulf?)
Rigs of great size and complicated structure have their own specific benefits. Rigs provide protection for marine species, and can be used for rejuvenating of reef communities (Macreadie, 2011) or protecting post – recruitment fishery resources (Sayer and Baine, 2002). Near-shore rigs contribute significantly more protection than offshore rigs (Sayer and Baine, 2002), and offshore reefs provide a sheltering area for demersal fish, as well as foraging and consuming reef activities (Powers et al., 2003). This is especially the case given the habitat created by the armouring to protect the cabling and main structure (Wilson and Elliott, 2009).
Moreover, Powers et al., (2003) note that protection from fishing activity could significantly contribute to a regional system of marine reserves and play a large role determining level of fish production. Some scientists propose rigs-to-reef sites as de facto marine protected areas, due to their size, ease of defining boundaries relative to the structure, and their interruption of trawling activity (Jagerroos and Krause, 2016; Gonzales et al., 2005;Macready, 2011; Schroeder and Love, 2004). There are specific ecological benefits to a national rigs-to-reefs program in terms of stock enhancement, MPA creation, and coral propagation.
Many of the aforementioned environmental benefits of the Rigs-to-Reefs program are fundamentally connected with the extractive economic use of ocean resources. Primarily, the use of R2R sites as either opening fishing grounds or marine protected areas can benefit the overall health and utilization of existing fish stocks. Most notably, the tendency for fish to congregate around rigs-to-reef structures improves the use of the fishery by commercial fishers, recreational fishers, and recreational divers. Commercial fishers that harvest from artificial reef systems often experience reduced Catch-per-unit-effort (CPUE), a measure of overall cost associated with harvesting fisheries resources (Cripps and Aabel, 2002). On the recreational side, sports fishers and divers that routinely use these artificial reefs stimulate the nearshore economy by chartering boats, guides, and gear. Furthermore, costs saved from not completely decommissioning rigs are shared between the lessee and the governing entity. Under the current implementation of the Rigs-to-Reefs program, approximately $4 million is saved by oil companies that participate: At least $2 million of these savings go directly to the government. Between the stimulation of regional economies and the development of direct revenue streams for the governing entity, rigs-to-reefs policy supports the economic use of artificial reefs systems in an environmentally-conscious manner.
This logic is deeply compromised and pragmatic. Oil rig infrastructure skates across the Gulf floor like a hard rhizome and, increasingly, semi-submersible rigs are floating islands with their own social and professional standards – floating islands tied to the mainland through imagined (and sometimes possible) economic growth while really tethered, instead, to the seafloor. 71% of global emissions come from just 100 fossil fuel companies, the Guardian notes, doubly contributing to a changing climate and our changing seas. So isn’t the Rigs-to-Reef program a band-aid on a larger, spurting wound? Can it be more? The most recent articles on energy infrastructure reef conversion, however, are part of a different energy future that that of oil and gas.
A Note on Standing Literature, and Alternative Energy
While rigorous literature reviews on R2R, and artificial reefs overall, are these days rarely seen in major science or management journals, wind energy has brought renewed attention to the transformation of submerged structures to productive artificial reefs. Smyth et al. (2015) summarize the standing literature on adapted artificial reefs and promote a rigorous framework for adjudicating decommissioning protocols (through DSPIR analysis) for offshore wind energy structures. As opposed to retroactively compensating for the manifold damages of oil rig construction, use, and decommissioning, offshore wind entrepreneurs are concerned with the complete “Life-cycle management” of wind turbines, adjudicating the relative benefits of partial or complete removal. To that end, they concluded that “environmental and economic benefits in partial as opposed to complete removal, especially if habitat created on the structures has conservation or commercial value, is higher.” Furthermore, they considered the legal precedents and repercussions of both options through the 10-tenets of sustainable marine management (Elliot 2013).
Suggestions of reef conversion for ocean energy and other types of alternative energy infrastructure are fresh air in a stagnating literature around artificial reefs. In the heyday of artificial reef policy in the early 1980s, there was national attention on the political and ecological possibilities of artificial reefs more generally. Just as a more critical conversation around artificial reef literature was getting underway in the mid-80s, research was increasingly focused on policy development, not design efficiency or specific standards for specific ecologies. By 1990 artificial reefs had a national program but little further critical attention.
McGurrin et al. (1989), noted the following State of the Union vis-a-vis artificial reefs in 1989:
23 coastal states and documents
572 permitted artificial reef sites in U.S. marine or estuarine waters as of October.
14 of the 23 coastal states had government (state or local) sponsored ocean reef programs.
Collectively resulting in an estimated 44,643 individual structures in some 1,582 bodies of water, including 427 coldwater streams, 45 warm water streams, and 1,110 lakes and reservoirs.
Where are we now?
In collaboration with some classmates in the Marine Affairs program we proposed to augment and adapt standing policies (Public Law 98-623, Title II; 16 U.S.C. 1220-1220C, 43 U.S.C. section 1331) and perhaps propose new policy to enable rig conversion as early as possible in the lifetime of the rig. As part of the proposed National Infrastructure bill, early decommissioning could reduce risk and enhance local ecologies with an economic incentive for oil developers. As artificial reefs, rigs are a long-term investment in our coral ecosystems, shoreline climate mitigation, and keeping oil in the ground through early decommissioning.
After completing an analysis of the coast and benefits to a more rigorous federal rigs-to-reefs program, we proposed incentivising the early decommissioning of rigs by federal subsidy. Significant government tax breaks to oil and gas companies will get smaller as rigs reach the end of their lifetime and/or lease, encouraging companies to decommission early. Not only will this make Rigs-to-Reefs structures more readily available to be turned into a fishing ground or MPA (perhaps at state discretion), but it will keep the carbon otherwise emitted as gas under the ocean floor and reduce greenhouse gas emissions. Rigs will then be permitted as artificial reefs under section 10 of the Rivers and Harbors Act of 1899, section 404 of the Federal Water Pollution Control Act, or section 4(e) of the Outer Continental Shelf Lands Act (this is standing legislation, Public Law 98-623). Keep the oil in the ground.
Supplement the National Artificial Reef Plan with more formal legislation to incentivize wind farm production, management, and maintenance, including professional development to transition workers from extractive industries to complete lifecycle management.
Contributions from Ivy Akuoko, Sam Poli, and, Fitri Silaen.
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