case of too little, too late. Another frequently cited hurdle is
the requirement that reefed structures have 85 feet of clearance to the surface. It was thought that this was a firm reg- ulation set by the Coast Guard that has prevented reefing in a lot of shallow areas that would be greatly cherished by anglers. However, at a meeting Nov. 16, 2012, in Houston, the Coast Guard clarified that the 85-foot “rule” is really more of a “rule of thumb” that would be applied in a case-by-case basis with consideration given to extra buoy requirements for depths shallower than 85 feet. This clarification could open up the possibility of creating more, and more accessible, areas to reef. The industry also used to have the
option to “reef in place,” but that alter- native was taken away in the aftermath of Hurricanes Katrina and Rita. Short of leaving the platform upright forever, this option has the most appeal for anglers. It entails removing the top decks and the platform jacket, lower- ing them to the seafloor and cutting the legs to a safe level below the surface. With more than 100 rigs on the seafloor after the hurricane season of 2005, the industry found ample opportunity to use the program to create permanent marine habitat and turned to regula- tors with requests to reef in place. Concerns from two familiar casts of
characters stopped the program in its tracks. Trawlers complained that all that structure would not leave them any place to drag the bottom with nets. At the same time, some environmental groups complained that reefing in place was nothing more than an excuse for the industry to dump their “trash” in the ocean. In response to those con- cerns, federal regulators abruptly placed a moratorium on reefing in place that remains in effect today. However, at the Nov. 16 meeting it
was announced by the Bureau of Safety and Environmental Enforce - ment (BSEE) that revisions are being made to the moratorium that will be released “soon.” Industry representa- tives seemed caught by surprise by this announcement, but if true, and if the revisions are significant enough, this could be a tremendous boon to reefing efforts. More reefing areas, clarification and
flexibility on the 85-foot rule, an end to the moratorium on reefing in place — these are keys to keeping more struc- ture in the water in places where they can be easily accessed by recreational anglers and we seem to be making
TIDE
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progress. Still, clear lines of communi- cation and cooperation between feder- al regulators and the industry seem to be lacking, and that is critical for reef- ing to be embraced as the preferred method of disposal for the industry.
REEFING AS A PRIORITY Over the history of offshore energy
development, somewhere in the neigh- borhood of 6,000 structures have been placed in the Gulf of Mexico and yet there are fewer than 3,000 out there today. Requirements to remove those structures have been written into leases since the first offshore well was drilled, and removals have been a part of the regular course of business for many decades. Anglers have only recently felt the removals more acutely as near- shore reserves play out, structures are removed and nothing new comes in to replace them. As the energy industry focuses more and more of its efforts in deeper water, anglers and divers are seeing their favorite platforms pulled and not finding any new places to go. Our engagement on this issue has
been enlightening, and frustrating. The obstacles to achieve our goals are real
and formidable. CCA will continue to push not only the key remedies described above, but also pursue a shift in federal policy that will make reefing the preferred alternative and drive regulatory efforts that encourage the industry to reef structures, rather than discourage them with a snarl of red tape. Our efforts will continue to focus on working with champions in Congress to step up and spearhead efforts to streamline the permitting process and improve the relationship between federal regulatory agencies and the industry with a goal to raise the percentage of reefed platforms well above the 11 percent where it stands today. We will continue to work with industry to explore ways to mitigate the loss of platforms through the placement of other mate- rials offshore. Like so many bureaucratic pro-
cesses, this one won’t change without constant pressure. CCA will remain committed to exploring every option that may leave structure in the Gulf, in places where recreational anglers can access it and where it will pro- vide the greatest benefit for the marine environment.
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