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The Case for Reefing California Platforms by John Smith

Environmental groups like the Environmental Defense Center and Get Oil Out continue to oppose converting the jackets of California oil and gas platforms to artificial reefs despite scientific studies (Claisse et al. 2014) showing “oil and gas platforms off the coast of California have the highest secondary fish production per unit area of seafloor of any marine habitat that
has been studied.

Another important factor environmental groups and the 2023 BOEM Programmatic EIS for Decommissioning failed to consider and acknowledge is the huge amount of air emissions that would be released by world-class heavy lift vessels like the Thialf or Balder Semi-submersible Crane Vessels (SSCVs) that would be required to safely and efficiently remove the large federal OCS platforms like Harvest, Hermosa, and Hidalgo (HHH). The HHH platforms are in waters depths ranging from 430-675 feet and have combined deck and jacket weights ranging from 20,000 – 25,000 tons. In comparison, the wrought iron structure of the Eiffel Tower weighs about 8,000 tons.

The SSCVs and accompanying Anchor Handling Tugs (AHTs) used to remove the HHH platforms will likely to be mobilized from distant locations like the North Sea or Gulf of America where they typically operate. Because SSCVs like the Thialf and Balder are too large to enter the Panama Canal, this would involve a 20,000 nautical mile roundtrip voyage around the tip of South America.

Three to four campaigns, and separate SSCV and AHT mobilizations and demobilizations, are projected to be required to fully remove the HHH platforms because the challenging oceanographic conditions offshore Point Arguello restrict heavy lift operations to a 150-day period between May and October.

Four campaigns by the SSCV and AHT would consume about 300,000 metric tons (mt) of marine diesel oil and release approximately 470,000 mt of CO2 and 11,000 mt of NOX emissions. To put these numbers into context, 470,000 mt of CO2 and 11,000 mt of NOX are:

  • the amount of CO2 emissions released by providing electrical power to 97,600 homes annually (the city of Santa Barbara has about 38,000 housing units).
  • the amount of CO2 emissions released by burning 1.1 million barrels of oil.
  • the amount of CO2 emissions released by 102,000 gasoline burning cars annually.
  • the amount of NOX emissions released by four large oil or coal-fired power plants annually.
  • the total annual NOX emissions in Santa Barbara County.

And this is only the emissions released during mobilization and demobilization of the SSCV and AHT. If full removal is required, an additional 50 days of operational time by the SSCV and AHT is estimated to be required to remove the topside and jacket of each HHH platform. This could be reduced to about 15 days per platform if the jackets are converted to artificial reefs. Only one SSCV and AHT campaign may be required if the HHH jackets are reefed, compared to the four campaigns required for the full removal scenario. This would result in a 75 percent reduction in CO2 and NOX emissions.

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damaged Vineyard Wind turbine – Cape Cod Times photo

Excerpt from p.3 of Vineyard Wind’s suit against GE Renewables (attached):

“As was widely reported in national and local news, in July 2024, one of the GER offshore blades collapsed and fell into the waters off Nantucket, necessitating a massive environmental cleanup, and a six-month construction hiatus during which GER performed a “root cause” analysis. That analysis concluded that 68 of the 72 GER blades installed at the Project (nearly all manufactured by GER in Gaspé, Canada) were also defective because they were inadequately bonded together, and were so poorly made that they were beyond repair. GER’s remediation plan required it to remove all of the blades and to replace all Gaspé blades with others manufactured at a different facility in Cherbourg, France.

Regulatory issues of concern:

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    John Smith’s decommissioning presentation in Santa Barbara

    John Smith‘s excellent comments on the BOE post about the proposed revisions to decommissioning financial assurance regulations warrant a separate post. John’s comments are pasted below.

    It’s clear the proposed rules have been designed to reduce financial burdens on OCS oil and gas operators, especially small independents. The proposed rules do this by:

    1. Waiving the requirement of the operator/lessees to obtain supplemental financial assurance to cover decommissioning obligations if jointly and severally liable predecessors are determined to have the financial capability to cover the obligations.
    2. Lowering the credit rating threshold BOEM uses for evaluating the financial health lessees and grantees from BBB- to BB- from S&P Global Ratings (S&P) or Baa3 to Ba3 from Moody’s Investor Service Inc.
    3. Revising the level of BSEE probabilistic estimates of decommissioning cost used for determining the amount of supplemental financial assurance required from P70 to P50.

    I don’t see any rationale for lowering the credit rating threshold, which would apply to both current and predecessor lessees.  A BB- and a Ba3 rating is considered “non-investment grade” or “junk,” meaning the company is more vulnerable to adverse economic conditions, such as a downturn in oil and gas prices.  Current market estimates place the 3-year probability of default for a BB- rating at approximately 12.5% to 13%. Lowering the credit rating significantly increases the risks of default by lessees and transfers the risk to the federal government and taxpayers.

    Reducing the BSEE probabilistic criteria for determining the amount of supplemental financial insurance required from P70 to P50 means there is a 50% chance BSEE cost estimates for decommissioning are underestimated further increasing risks borne by the federal government and taxpayer.  

    BOEM should reverse course and maintain the current credit rating threshold (BBB- and Baa3) and the P70 criteria.

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    Background: By a 3-2 vote, the Santa Barbara County Planning Commission, acting under the direction of the Board of Supervisors (also by a 3-2 vote), passed ordinances to ban new onshore oil and gas wells and phase out old wells.

    The quote:

    “We keep discovering new oil and new techniques to recover it,” said Commissioner John Parke. “The only thing to stop the oil industry and the production of oil is legislation.”

    Comments:

    • The first sentence is perceptive, acknowledging that resources are not really finite given the ingenuity of engineers and geologists.
    • The second sentence is disturbing. The Commissioner believes he is legally and morally entitled to terminate an industry that has been present in Santa Barbara County for >130 years. He believes the Commission can do so by a slim majority and without compensation to those whose property rights are being abrogated.
    • The 2 Commissioners voting against euthanizing the County’s oil industry represent Districts 4 and 5 (maps below) where most of the wells are located. In essence, South County Santa Barbara is terminating an industry that is important to North County.
    • Pertinent to the County’s action is a suit filed by John and Melinda Morgan, who inherited the mineral rights to two parcels in the Cat Canyon Field (District 4). They argue that a similar provision in CA Senate Bill 1137 amounts to an unconstitutional taking of their property.

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    Three wind turbines, including one with a damaged blade, at the Vineyard Wind offshore site in November 2024. Credit: Eleonora Bianchi / The New Bedford Light.

    Yet another chapter in the Vineyard Wind saga:

    New Bedford Light: Vineyard Wind on Wednesday sued its turbine supplier, GE Renewables, in civil court in Boston, alleging GE is breaching its contract and planning to abandon the project by April 28 — during the critical final stage of coming fully online.

    According to the complaint, GE filed a termination notice with Vineyard Wind in late February for its contracts to supply wind turbines and service and maintain them, citing more than $300 million in claims unpaid by Vineyard Wind.

    If GE exits, Vineyard Wind says, the project “will likely fail, leaving the windfarm stranded.”

    The New Bedford Light provides more details on the litigation.

    Remember, BOEM waived the “pay as you build” decommissioning financial assurance requirement for Vineyard Wind and subsequently relaxed financial assurance requirements for all offshore wind projects.

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    Honored to be named Inspector of the Year. I’m sincerely thankful to my supervisor and the management involved for recognizing my commitment to this mission, and I’m proud to work alongside the Well Operations Inspection team, whose support and professionalism elevate all of us. This award reflects our shared dedication to safety and the environment.”

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    Wamsutta Frank James speaking in Plymouth, at the statue of Massasoit.

    My wife has native American (Micmac) heritage. Her family has deep respect for the Wampanoag tribe, in part because of their friendship with Aquinnah Wampanoag elder and activist Frank B. (Wamsutta) James.

    Frank rescued my father-in-law after a car crash on Cape Cod and was a close friend for the rest of his life. Frank and my father-in-law, who headed the Art Dept. at Barnstable H.S., had common interests in art and history. Frank was also a talented musician, and was my wife’s music teacher at Eastham Elementary School on the Outer Cape.

    Frank fought for the rights of Native Americans long before it was fashionable. In 1970, the speech be wrote to commemorate the 350th anniversary of the arrival of the Mayflower was never delivered, because it was deemed to be inflammatory. In his draft remarks, Frank succinctly summarized the tribe’s recent history:

    Although time has drained our culture, and our language is almost extinct, we the Wampanoags still walk the lands of Massachusetts…. Our spirit refuses to die.”

    This spirit is evident in their opposition to wind projects that impact their historic and cultural homeland.

    If Frank was alive today, he would no doubt be tirelessly supporting the preservation efforts of the Aquinnah Wampanoag Tribe. Most recently, the tribe joined the Narragansett Tribe, Green Oceans, commercial fishermen, and others in a suit challenging federal approvals for the Sunrise Wind project. Green Ocean’s press release is attached.

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    I’m attaching the complete comment letters from Sable Offshore and their main antagonist, California Attorney General Bonta, in response to PHMSA’s public notice and request for comments on Sable’s special permit application.

    Summary of the California AG’s assertions:

    “First, PHMSA is without authority to grant such a special permit because Lines CA-324/325 are intrastate pipelines and California regulators have sole regulatory oversight over any attempt to restart these Lines and issue state waivers. Second, California has vested interests in ensuring Lines CA-324/325 operate safely and PHMSA’s proposed special permit would dilute the higher state safety standards that were imposed on Sable and therefore it is inconsistent with pipeline safety. 49 C.F.R. § 190.341(d). Third, given the fact Line CA-324 already failed and caused a catastrophic oil spill in 2015 in Santa Barbara County, even if PHMSA had authority to issue a special permit (which it does not), a more robust environmental analysis needs to be performed. Fourth, PHMSA unlawfully invokes the Endangered Species Acts’s emergency consultation procedures and has given no indication that it will consult with the National Marine Fisheries Service, in violation of the Act. Finally, Secretary Wright’s March 13, 2026, order (“DPA
    Order”) does not change anything about the propriety of the Application, because the DPA Order itself is unlawful.”

    Summary of Sable’s position (screenshot):

    You can sample the other public comments, some of which are quite good, by visiting the Regulations.gov docket.

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    The Department of the Interior today announced the start of a phased plan to establish the Marine Minerals Administration, bringing together the functions of the Bureau of Ocean Energy Management and the Bureau of Safety and Environmental Enforcement. This action is intended to improve coordination and increase efficiencies across offshore leasing, permitting, inspections and environmental oversight, while maintaining all existing regulatory protections and rigorous safety standards. 

    This streamlined approach reflects the evolution of offshore energy development and the need for a more integrated approach to managing conventional and emerging resources such as critical minerals. By aligning planning, leasing and oversight functions, the Department is positioning the agency to better meet current and future energy demands.

    This is an excellent step that many OCS program veterans have been advocating. In addition to the inefficiencies associated with overlapping and intertwined BOEM and BSEE responsibilities, the associated regulatory fragmentation is a significant safety risk factor.

    See the comments that I submitted to the Dept. of the Interior in response to their request for regulatory reform recommendations.

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    For those who haven’t suffered enough following the BOE blog😉, you can listen to me on the G’Day Mate podcast hosted by offshore industry veterans Evan Zimmerman and Tom Pado. You may also want to check out other episodes on their excellent podcast.

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