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Posts Tagged ‘Decommissioning EIS’

Add the Record of Decision for California decommissioning to DOI’s immediate review list

Posted in California, decommissioning, energy policy, Offshore Energy - General, tagged , , , , , , , on February 13, 2025| Leave a Comment »

PNAS: “among the most productive marine fish habitats globally”

Secretarial Order No. 3418 identified energy policies and regulations requiring immediate Interior Dept. review. A policy decision that should be added to the list is BSEE’s Record of Decision (ROD) for the Programmatic Environmental Impact Statement on Pacific OCS Decommissioning.

Inexplicably, BSEE’s ROD designates the most environmentally harmful, unsafe, and costly alternative as the “preferred alternative.” The decision is contrary to the opinions expressed by the leading experts on the ecology of California offshore platforms, most notably Dr. Milton Love of the University of California at Santa Barbara.

Why did BSEE select alternative 1 (complete removal) when their $1.6 million EIS acknowledges that alternative 2 (partial removal) is environmentally preferable? Was their decision influenced by activists who support the alternative that is most punitive to the industry they despise?

The Interior Dept. needs to immediately review this decision so that stalled decommissioning projects can move forward in a manner that is most efficient and best protects “the most productive marine habitats per unit area in the world.”

beneath Platform Gilda, Santa Barbara Channel

“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

More posts on California decommissioning

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Excellent article on BSEE’s inexplicable Record of Decision on the decommissioning of California OCS platforms

Posted in California, decommissioning, tagged , , on January 10, 2024| 2 Comments »

Giant Plumose Anemones standing on mussels 75 feet down Platform Hilda (Decommissioned) (photo courtesy of BobEvansPhotography.com), Montecito Journal

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.

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California platform decommissioning takes a step backward

Posted in California, decommissioning, Offshore Energy - General, tagged , , , , , , on December 19, 2023| Leave a Comment »

PNAS: “among the most productive marine fish habitats globally”
beneath Platform Gilda, Santa Barbara Channel

“These platforms are habitat for millions of animals. My opinion is that it’s immoral to kill huge numbers of animals in any kind of habitat.”

Dr. Milton Love, UCSB marine biologist

Inexplicably, BSEE’s Record of Decision (ROD) for the Programmatic Environmental Impact Statement on Pacific OCS Decommissioning (EIS cost: $1,604,056) endorses such habitat destruction by designating the most environmentally harmful, unsafe, punitive, and costly alternative as the “preferred alternative.”

Alternative 1 (the preferred alternative) calls for “the complete removal of platforms, topside, conductors, the platform jackets to at least 4.6 m (15 ft) below the mud line, and the complete removal of pipelines, power cables, and other subsea infrastructure (i.e., wells, obstructions, and facilities).”

Ironically, the ROD correctly acknowledges that alternative 2 (partial removal) is environmentally preferable. So what drove the decision to select the alternative that destroys “the most productive marine habitats per unit area in the world?” Was there pressure to choose the alternative that is most punitive to an industry that is despised by California activists? If so, their schadenfreude is certain to be delayed by administrative and legal challenges that draw further attention to the social costs and environmental damage associated with “complete removal.”

In 2020, BOEM estimated the total cost of decommissioning the 23 Federal offshore platforms at $1.7 billion, and today’s real costs are likely to be much higher. Also, keep in mind that some thorny decommissioning liability issues remain to be resolved, particularly with regard to Platforms Hogan and Houchin.

The decommissioning costs for Hogan and Houchin are estimated by BOEM at $85.6 million, even though the cost of completing removing Platform Holly (single platform in similar water depth in CA State waters) may reach $475 million. Per the BOEM data, there is no collateral, supplemental financial assurance, or third party guarantee that could defray the Hogan and Houchin costs. The extent to which prior lessees could be held accountable is questionable given that the lease was assigned to (now bankrupt) Signal Hill in 1991, well before the predecessor liability language was added to the MMS bonding rule. Irregularities in the management of Signal Hill’s Abandonment Escrow Account for Hogan and Houchin further complicate the liability issues.

The path for timely facility decommissioning with the least environmental damage and safety risk has two essential elements:

Absent those steps, the noise will continue, the platforms will remain in place, and the best outcome for all parties will not be achieved.

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Programmatic EIS for Pacific OCS platform decommissioning presents 4 alternatives, none of which are workable

Posted in California, decommissioning, Offshore Energy - General, Regulation, rigs-to-reefs, tagged , , , , on October 20, 2022| Leave a Comment »

The 23 platforms in Federal waters offshore California are from 33 to 55 years old. Most are no longer producing and 8 are on terminated leases. Some of the platforms are massive structures in water depths up to 1200′ (list of platforms and map below).

BOEM’s draft programmatic EIS evaluates 4 decommissioning alternatives, none of which appear to be workable for a combination of economic, environmental, and legal reasons:

  • Alternative 1 involves the complete removal of platforms and pipelines. This alternative is cost prohibitive and environmentally unfavorable.
  • Alternatives 2 and 3 evaluate prudent and environmentally responsible partial removal options. Unfortunately, partial removal and reefing are not feasible under the California Resources Legacy Act (AB 2503). This legislation holds the donating company perpetually liable for any damages associated with the reef structure. While not assuming any liability, the State nonetheless collects 80% of the savings (reefing vs. complete removal). As a result, it’s no surprise that no company has applied to participate in the State’s program.
  • Alternative 4 calls for leaving platforms and pipelines in place after emptying tanks and flushing pipelines. This “no action” baseline alternative violates the lease agreement and 30 CFR 250.1725, and would only be permissible if an alternate use was approved for the platforms per 30 CFR Part 585.
  • The EIS, with minimal discussion and no supporting data, rules out alternate uses at any of the 23 platforms. This exclusion would seem to be premature given the win-win-win opportunities for industry, government (Federal, State, and local), and academia. These include deferred decommissioning liabilities, a wide range of research opportunities, security and defense applications, weather observation and climate studies, maritime communications support, education programs, marine seismicity studies, and hydrokinetic energy projects. With proper maintenance, platforms can continue to provide social benefits long after all wells are plugged and production equipment is removed. However, once removed, replacement costs would be prohibitive.
  • Lastly, the EIS avoids the thorny financial responsibility issues that will complicate decommissioning decisions. Note the questions raised in the “troubling case of platforms Hogan and Houchin.”
  • Those wishing to comment on the draft EIS should follow the posted instructions.

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