[Coral-List] Bring Back the Gulf

Tue Aug 12 10:20:18 EDT 2014

Thanks Steve for bringing out all the facts of this issue. As you may 
know back in the early 1970s My job at Shell Head office was to find 
alternative uses for old platforms and also work with Senator Babe 
Swartz to locate areas for placing old rigs and victory ships on the 
bottom to function as designated artificial reef sites. There were only 
a few hundred rigs to worry about back then. The number of rigs has has 
dramatically increased since then. Dana Larson and I became long lasting 
friends back then. We still commiserate of the situation. We do seem to 
be going back to the emotions/politics of young people during the 1960s. 
I guess it is just human nature. Gene
On 8/4/14 6:26 PM, Steve Kolian wrote:
> Dear Ms. Quirolo,
>
> It is not true that major oil and gas (O&G) companies in the Gulf of 
> Mexico (GOM) want to leave their retired offshore platforms in the 
> water after their useful life in minerals production. O&G companies 
> are responsible for platform navigational, personal, environmental, 
> and fishery liabilities from cradle to grave. The coastal states in 
> the north-central and western GOM have created artificial reef 
> planning areas in an effort to provide a liability firewall to the 
> previous O&G owners.
>
>
> O&G companies have only “reefed” 8-10% of all the structures (~3,500+) 
> removed from the GOM. The State artificial reef programs are a 
> modestly profitable (for the O&G industry) or break-even economic 
> option for the participating O&G companies. When a platform is 
> “reefed”, the majority of fish either perish or are lost to the 
> environment. The invertebrate community that exhibits a preference for 
> the upper 25 meters of the water column beneath a platform^usually do 
> not survive when a platform is re-oriented in the water.
>
>
> The O&G companies, Bureau of Ocean Energy Management (BOEM), and 
> National Oceanic Atmospheric Administration (NOAA) know that there are 
> protected coral, octocoral, and hydroids attached to many of the 
> existing operating and idle structures. It is estimated that 49 
> species of Federally managed fish and 25 species of protected 
> invertebrates utilize, to varying degrees, the platform substrates for 
> feeding, spawning, mating, and growing to maturity. Two species of 
> endangered turtles including the Hawk’s bill turtle (/Eretmochelys 
> imbricate/) and threatened Loggerhead turtle (/Caretta 
> caretta/)//forage, rest, and sometimes sleep on offshore platforms.
>
>
> The removal of offshore platforms conflicts with the laws published in 
> Sustainable Fisheries Act/Magnuson-Stevens Fishery Conservation and 
> Management Act (“Magnuson Act”, 16 U.S.C.A.§ 1801, et seq.), 
> Endangered Species Act (“ESA”, 16 U.S.C.A.Ch. 35, et seq.) and 
> National Environmental Policy Act (“NEPA”, 42 U.S.C.A.Ch.55, et seq.).
>
>
> The primary concern amongst all parties is that the cost of 
> environmental compliance associated with producing a barrel of oil in 
> the GOM will increase.Platform operators would accrue NEPA, ESA, and 
> EFH compliance expenses when they perform routine maintenance, as they 
> often scrape off thousands of marine invertebrates during routine 
> subsurface maintenance.
>
>
> NEPA compliance for routine maintenance would be a minor annoyance 
> compared to the more difficult legal problem of removing a 
> platform.Federal regulations (30 CFR 250.1725 through 250.1730 Subpart 
> Q) require that the platforms be removed and the site turned to 
> pre-production conditions.If these environmental laws applied to the 
> offshore oil and gas industry, the offshore operators would have to 
> prepare a NEPA-compliance document for the platform that describes the 
> routine subsurface maintenance.When an oil and gas company removed a 
> platform, they would have to mitigate for the loss of coral reef 
> habitat, which may include creating coral reef habitat elsewhere.
>
>
> Money cannot be a reason to avoid mandates issued in NEPA, ESA and the 
> Magnuson Act. It does not matter if they are man-made. NEPA obligates 
> the lead Federal agency to evaluate reasonable alternative actions to 
> blasting oil and gas platforms for platform removal and consider 
> avoidance and mitigation of adverse environmental effects.If there are 
> coral, octocoral, and hydroids are on them, they cannot be 
> removed.BOEM and NOAA Fisheries must rigorously explore and 
> objectively evaluate alternatives to destroying the coral reef 
> organisms on oil and gas platforms.Therefore, the NEPA analysis should 
> examine a range of alternative beneficial uses for retired platforms, 
> which should include alternatives that preserve the coral reef habitats.
>
>
> Best Regards,
> Steve Kolian
>
>
>
> > Date: Sun, 3 Aug 2014 20:06:24 -0400
> > From: dquirolo at gmail.com
> > To: eugeneshinn at mail.usf.edu
> > CC: coral-list at coral.aoml.noaa.gov
> > Subject: Re: [Coral-List] Bring Back the Gulf
> >
> > Sorry to burst your bubble Gene, but there is no money trail here. I am
> > not on anyone's payroll. This was a six month grant to investigate this
> > topic and we've done our work and published our findings. It is a timely
> > release of our extensive review of the issue, free of the excessive
> > influence of the oil and gas lobby as has been the case previously 
> on this
> > issue. Now it is up to Interior to reassess the program as they have
> > announced they intend to do. All the best, DeeVon
> >
> >
> > On Fri, Aug 1, 2014 at 1:56 PM, Eugene Shinn <eugeneshinn at mail.usf.edu>
> > wrote:
> >
> > > Having served on the Dept. of Interior Minerals Management Service
> > > science committee (3 years and before the name change) and having 
> spent
> > > many hours diving and researching and photographing marine life under
> > > offshore rigs I am well aware of the extensive scientific research 
> done
> > > on the environmental effects of rigs and artificial reefs in general.
> > > These rigs exist in an area consisting of miles and miles of 
> featureless
> > > gooey mud populated mainly by shrimp. I am also aware of the 
> marine life
> > > lost when explosives are placed in the rig legs in order blow them off
> > > below the "mud line" as stipulated by existing regulations.Almost 
> every
> > > fish down there including thousands of pounds of red snapper, grouper,
> > > angel fish and other tropicals that depend on these habitats, 
> including
> > > protected turtles, become shark food when rigs are blasted loose from
> > > the bottom. Why is there no concern for the bicatch discarded by
> > > shrimpers. One has to consider where the idea and political motivation
> > > to remove these essential marine habitats from the Gulf is coming 
> from.
> > > The decision certainly is not science or humanitarian-based and 
> neither
> > > does it make ecological sense. We can only scratch our heads and 
> wonder,
> > > especially since the secretary of the interior who created the 
> idle iron
> > > project has moved on. The authors of this book have mixed damage from
> > > oil with iron, a primary ocean nutrient. These rigs are no longer
> > > extracting oil so oil is irrelevant to their argument. Is the 
> makings of
> > > another NGO being developed to provide tax benefits to the unwary?
> > > Follow the money. Gene
> > >
> > > --
> > >
> > >
> > > No Rocks, No Water, No Ecosystem (EAS)
> > > ------------------------------------ 
> -----------------------------------
> > > E. A. Shinn, Courtesy Professor
> > > University of South Florida
> > > College of Marine Science Room 221A
> > > 140 Seventh Avenue South
> > > St. Petersburg, FL 33701
> > > <eugeneshinn at mail.usf.edu>
> > > Tel 727 553-1158
> > > ---------------------------------- -----------------------------------
> > >
> > > _______________________________________________
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> > > Coral-List at coral.aoml.noaa.gov
> > > http://coral.aoml.noaa.gov/mailman/listinfo/coral-list
> > >
> >
> >
> >
> > --
> > DeeVon Quirolo
> >
> > www.bringbackthegulf.org
> > www.neighborsagainstmining.org
> > www.reefrelieffounders.com
> > www.reefreliefarchive.org
> > www.sunshinestatecleanenergycoalition.org
> >
> > You must be the change you want to see in the world.
> > Mahatma Gandhi
> >
> > We can do no great things; only small things with great love.
> > Mother Theresa
> >
> > The problems of the world cannot possibly be solved by skeptics or 
> cynics
> > whose horizons are limited by the obvious realities. We need men who can
> > dream of things that never were.
> > John Fitzgerald Kennedy
> > _______________________________________________
> > Coral-List mailing list
> > Coral-List at coral.aoml.noaa.gov
> > http://coral.aoml.noaa.gov/mailman/listinfo/coral-list

-- 


No Rocks, No Water, No Ecosystem (EAS)
------------------------------------ -----------------------------------
E. A. Shinn, Courtesy Professor
University of South Florida
College of Marine Science Room 221A
140 Seventh Avenue South
St. Petersburg, FL 33701
<eugeneshinn at mail.usf.edu>
Tel 727 553-1158
---------------------------------- -----------------------------------