ARTIFICIAL REEF STUDY REPORT Completed by the Sanctuary Advisory Council Artificial Reef Working Group, Flower Garden Banks National Marine Sanctuary March 1, 2013 Submitted to the Flower Garden Banks National Marine Sanctuary Advisory Council Page 1 of 76 ARTIFICIAL REEF STUDY REPORT e S S D Tabl of Contents 1.0 TUDY UMMARY ESCRIPTION 1.1 Background 1.2 Brief History of AR Working Group 1.3 Study Purpose and Goals 2.00 ONLINE SURVEY AND RESULTS 3. ADDITIONAL INPUTS - DATA & EVALUATION 3.1 Marine Life 3.2 Cost Comparisons 3.3 Regulations: o S BOEM/BSEE, USACOE and Coast Guard 3.4 Permittingsk 3.5 Life f tructure 3.6 Ri Register For Out-Of-Water Structure 3.7 Out of Water Options – Obstacles and Potential Solution s 4.0 SUMMARY ADVANTAGES & DISADVANTAGES FOR OPTIONS A to E 5.0 SSPECIAL EARLY RECOMMENDATION FOR HI-A389A TO 6.0 TUDY MAJOR FINDINGS & FINAL RECOMMENDATIONS SAC ADDENDUMS p A-1: AR Work ing Grou Members A-2: TPWD List of Partial Removals A-3: Recommendati ons for Boundary Expansion REFERENCE DOCUMENTS by S , , , R-1: FAQs U DOIo NOAA USCOE EPA and Coast Guard R-2: BSEE Rigs T Reef Program Page 2 of 76 1.1 BACKGROUND FOR THE ARTIFICIAL REEF STUDY e Substantial installations of oil and gas platforms in th northern Gulf of Mexico began i n the 1950s.e Ceu rrently t here are an estimated 30000 f platforms off the coasts of Texas an d Louisiana. Of that count, ms approx imately 3 30 ar off th coast of Texas and roughly 270 off o Louisiana. The oil and a gas industry proj ects the majority of these pl atfor will be remov o ed in th e n ext 10 to 2 0 years. Platform rem oval of this magnitude destroys thriving) artificial reef environment t. hat has been beneficial t marine life and “user groups” (fishermen, divers, boaters, researchers, and others since platfor m in stallation began m : According to the oil and gas Industry, the main reasons for platfor r•emovals are • s n • Depletione of reservesd in existings fields • Typically s maller reserve i new developments • Unstabl oil an natural ga perices m • New view of h urricanel risk • Difficultye obtaining affordabl platfor insurance Potential new oi and gas taxes Idl Iron policy requirements enacted by Federal Gov’t after Katrina e e e e w t Th longstanding debat of whether artificial reefse attract or Tproduc f lif g has generally been f resolved . Most marine scientists agree no tha artificialf f reefs both attract and produce marin populations . he ollowin is the definition o “A Reef” as described by Dr. Quenton Dokken, CEO of The Gul o Mexico e Foundation: He says a reef functions in three ways: 1) It accumulates energy andsnutrients via photosynthesis, recruitment, and th food web. 2) It diversifies and magnifie energy and nutrients through biodiversity, growth, and reproduction. 3) It exports ontendsenergy and nutrients through f emigration,of reproduction, hisand definition.the food web. Dokken c many platforms in the Gul Mexico clearly meet t There are hree bona e cGrail dozens ofonenatural hesebanks in the northern GOM aned tropicalat least t fid coral reefs (East an d West Flower Garden Bankss anartificiald M Bank). However, n of t Pagenatural 3 of 76 formations provid habitats at depths shallower than 55 feet, as the numerou easonable he ay he platform reefs do. Also,ei t’s r to suggest t many A Rs m e of actually support further developmente of corals on ervethe n atural reefs i nhott GOM or at least provid where “resilience” anksby p rovidingexist. an external sourc recruits. There is no debat that many of the ARs s as biological “ spots” in locales no nmatural b n , t Currently,e only o ne platfor exists in Flower Garde Banks National a e Marine Sanctuary (FGBNMS) High Island A-389A, e owned by sW&an T. I i 8-pil structure installed by Mobil Oil in 1981 appro ximately mil sou th of t he East Flower Garden e Bank n reeftop. o When th FGBNMSe boundary was implemented in 1 992, it wrapped around HI-eA389A thus including e it inside the sanctuary. Plans ar now i place3 t considerm futur expansion of the FGBNMS that can likely add at least two mor platforms to th sanctuary (HIA3 84 at West FGB and WC66 sat 28 Fatho Ba nk). f e This A rtificial Reef Study examine the impacts of removal o platforms within the FGBNMS and alternatives to full removal. Fiv different options were examined: e e 1. Full Removal 2. Leave essentially e as-is, out of th watere but less0 oil ando gas processings equipmentht and systems. 3. Leav outut of th water but only on deck at ~4 o ft. N provisioe ean for overnig stays. 4. Leave o of water wwith minimum structure t ~30 ft abov s level and no decks. 5. Cut structureo belo the ewaterline 40-85 feet. e e e Refer• t isSection 1.3 for th formally stated Purpos and Goals, but note that som• oft th estkey questions the Study addresses for each option are: • Whatt bestest for the marine environment? • Wha is b for tthe FGBNMS? • WhatWha is b for the users/constituencies? • What aree tthehe cos ramifications? • t are the regulatory c onstraints? structure? What ar permitting roadblocks? Wha is the expected life of an offshore Page 4 of 76 1.2 BRIEF HISTORY OF SAC AR WG (Artificial Reef Working Group) a ee o e Preceded by Platform Decommissioning a Subcommitt from 2010 t 2011, aTh FGBNM SAC AR Working Group was established April 20, o 2011 with Franke Burek as the Chairman. Frank put together team, mset goalsnk andk purposes, developed Study approachs , and established 14mdifferent AR alternativesnk k t study. In Jun 2012, s the leadership of the AR WGe transfer red frop Fra Bure tohJesse Cancelmo because Burek’ SAC membership ter expired. e Fra Bure remained ina the WG a a participant. At the tim ofsthis leadershi transition , mucs information s was collected and organized on artificial reefs and th foundatione was set for constituency/user “Survey”e on artificial reef ine the FGBNMS. During Burek’ tenurep a chairman, 19 different AR coordination documents wer distributed and several work sessions wer conducted. At the tim of leadership change, the make-u of the AR WG was as follows: Irby Basco Frank Burek 1. Jesse Cancelmo– (SAC Recreational Fishing) 2. John Embesi – Ex-team leader ) (ex SAC Recreational Diving) 3. Joe Hendrix x– (SAC Recreational Diving) 4. Will Heyman– (FGBNMS staff (ex SAC Research) 5. John Hoffman– (e SAC Commercial & Fishing) 6. Mike Jennings– ( SAC Research) 7. Daniel (Herb) –Leedy(SAC Oil Gas Operations) 8. Clint Moore – ( SAC Commercial & Fishing) 9. Rebecca Nadel –(BSEE) 10. Ellis Pickett – (ex SAC Oil Gas Operations) 11. Paul Sammarco–(ex SAC Oil & Gas Operations,s Shell) 12. James Sinclair– ( SAC Conservation) 13. Frank Wasson –( Louisiana Universitie Marine consortium, LUMCON) 14. – (SAC BOEM) 15. – (SAC Diving Operations) Pastt parti ci pants: 2 Emma S HickersonQ (FGBNMS a Staff, AR Library) e th e e e A the May 9 e, 012 AC uarterly meeting motion was mad (by Cancelmo) and accepted (non opposed and non abstaining) regarding th disposition of HI-A389A platform “The Flowerin th Gardensanctuary: Banks National Marine Sanctuary Advisory Council endorses deferring removal activities of HIA-389-A until September 2013 to allow the sanctuary’s Artificial Reef Working Group to gather further stakeholder input to make a recommendation to the council and sanctuary management. However, if Page 5 of 76 removal activities commence prior to that date the Sanctuary Advisory Council recommends leaving all or a significant portion of HIA-389-A in place.” e o a p Soon after Cancelmo assumed the AR WG leadership, du t variety of reasons, the make -uo ofe the AR WG changed as follows: Adds t th AR WG: Cher Walker (Diving Operations) and Jorge Brenner (The Nature Conservancy).s m nk , Resignation fro the AR WG: Fra Wasson (Diving Operations) and Rebecca Nadel (Oile & Gas Operations). Th •key milestones that followed were: o e o e e • The SAC AR Surve y for constituents t consider 5 options was conducted onlin from September 4 t October 1, 2012. Ther wer 432 survey participants. Workf sessions conducted on September 12, 2012 and October 11, 2012. • Attendees at latter session includede Dale Shively of TPWD and Marsh Armitage o W&T e e e An “early” and specialn stand -alon recommendation for disposition e of HI-A389A waso mad by the AR WG to SAC on November 14, 2012. Th SAC accepted th • recommendatio for 389 partial removal and forwarded th TBDrecommendation t Sanctuary Management ns • A speciale WG “work session” was held on Januarye 9, 2013 to make final TBD determination o of Study recommendatio to SAC. Th Final Report and recommendations wer completed February X, 2013 and sent t SAC. Page 6 of 76 1.3 PURPOSE AND GOALS 07August 2012 FGBNMS SAC – ARTIFICIAL REEF STUDY PURPOSE and GOALS Study Purpose op e e o e : Devel alternatives to removing hydrocarbon platforms in Flower Garden Banks National Marin Sanctuary and mak recommendations t th SAC and StudyFGBNMS Goals:Sanctuary e Manager. e e k s m Th recommended alternative(s) willns b developed by th Workingm Group using feedbac and input fro the SAC, Sanctuary Management and Sanctuary users/constituents.• The Study and determinatios will consider at a minimu the following: • e • Maximizing benefit for the marine environment Maximizing benefits, access and usag by all stakeholder groups • Order of magnitude costs for conversions and for annual • maintenance Risks and Liabilities Federal regulatory implications t t In addition, a critical goal is to complete this study prior to the star of any significan Page 7 of 76 structural decommissioning activities at HI A-389A platform.