LCUDC Opposes Sec. of Interior Salazar's "Idle Iron" Program

The LA Council of Underwater Dive Clubs (LCUDC) (www.lcudc.org ) has teamed up with Eco Rigs ( www.ecorigs.org ), Towers of Life ( www.towersoflife.com ), and other interested user groups to state our opposition to the Secretary of the Interior Ken Salazar Press Release dated 09/15/2010 concerning guidance for the “Idle Iron” Program. The Press Release stated that 650 decommission oil and gas platforms are scheduled for removal.
( www.doi.gov/news/pressreleases/Interior-Department-Issues-Idle-Iron-Guidance.cfm# )

The Gulf of Mexico is designated an Essential Fish Habitat (EFH) and/or Habitats of Particular Concern (HAPC) except for the offshore platforms. If the platforms could receive such status, then the National Marine Fisheries Service (NMFS) would have to recommend to Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) to not remove the platforms. (Paraphrase statements from ecorigs.org page title Essential Fish Habitat.)

The few studies done on the platforms, all indicated the offshore platforms are Essential Fish and/or Marine Habitats.
Proof of Concept for Platform Recruited Fish, Phase 1: Do Platforms Provide Habitat for Sub-adult Red Snapper?
The first and as of now, the only study (found) that shows a defining link that proves that the “platforms may constitute as red snapper essential fish habitat and, as such, should be considered as viable tools in management of red snapper”. From page 57 of the study, please note the wording: “essential fish habitat”. The Gulf Coast Council (GCC) is mandated under Magnum-Stevens to prevent overfishing and part of that mandate is the protection of known marine habitats important in their management.
( www.gomr.boemre.gov/PI/PDFImages/ESPIS/4/4898.pdf )

Other studies that indicated the upper part of platforms 85’ and up are the most productive part of the platform.
Rigs and Reefs: A Comparison of the Fish Communities at Two Artificial Reefs, a Production Platform, and a Natural Reef in the Northern Gulf of Mexico
( www.gomr.boemre.gov/PI/PDFImages/ESPIS/0/176.pdf )
Characterization of Alga-Invertebrate Mats of Offshore Platforms and the Assessment of Methods for Artificial Substrate Studies
( www.gomr.boemre.gov/PI/PDFImages/ESPIS/2/2962.pdf )
Seasonal and Spatial Variation in the Biomass and Size Frequency Distribution of the Fish Associated with Oil and Gas Platforms in the Northern Gulf of Mexico
( www.cmi.lsu.edu/index.php?option=com_content&view=category&layout=blog&id=6&Itemid=6 )

From the BOEMRE web site: Artificial Reefs: Oases for Marine Life http://gomr.boemre.gov/homepg/regulate/environ/rigs-to-reefs/artificial-reefs.html
On page 2: “each platform seasonally serves as critical habitats for thousands fishes, many of which are of recreational and commercial importance.” Please note the word “critical”.

The goal of this release is to inform the public, environmentalists, and other user groups (from one of studies ESPIS/2/2962) “Older structures will be removed, and even if large numbers are cut or toppled to create fish habitat, the most productive upper zone will be lost. From now on, the unique platform ecosystem is likely to be in decline.”

NOAA, NMS, BOEMRE, GCC aiding and abetting by such groups as the Environmental Defense Fund (EDF) are not doing their due diligence in protecting vital marine habitats as all known evidences point in that direction. The “Idle Iron” program should be renamed the “Idle Irony” program. The “Rigs to Reefs” program has become a slush fund for the governor.

Terry Migaud,
LCUDC Sec/tre
tgmigaud@cox.net