Montecito Journal: Oil Platforms’ Removal?:Reefing the Superior Environmental Option
On December 7, 2023, the Bureau of Safety and Environmental Enforcement (BSEE) issued a Record of Decision (ROD) recommending the full removal of California’s 23 offshore oil platforms in federal waters, following a Programmatic Environmental Impact Statement (PEIS) conducted to assess decommissioning options for platforms, pipelines, and other related infrastructure. However, upon close review, the PEIS and ROD appear to have reached misguided and detrimental conclusions due to critical oversights in their analyses.
Asher Radziner, Montecito Journal
The author aptly summarizes the flaws in the PEIS and the BSEE decision document. Very good analysis.
Bud's Offshore Energy (BOE) 
The PEIS ROD decision is not binding in terms of totally precluding partial removal of OCS oil and gas platforms and pipelines; BSEE will have the option to approve partial removal alternatives for project specific EIS’s. The ROD decision, however, will make it more difficult to overcome legal challenges to partial removal. This will increase the risks faced by operators and it may deter them from moving forward with decommissioning projects during the Biden administration, which they perceive as very anti-oil (e.g., the lack of lease sales in the new 5-Year OCS Leasing program). The ROD also sends a signal to OCS operators the removal requirements and mitigation measures placed by BSEE on decommissioning projects during the Biden administration will be very onerous (e.g., full removal of platforms, pipelines, and shell mounds). Consequently, operators may opt to delay decommissioning for years until a new, more balanced, and pragmatic administration is in place. Rather than encouraging the timely removal of aging platforms and associated infrastructure, the ROD decision is likely to have the opposite effect of delaying decommissioning for years.
Well said!