Hurricane clean-up activity in the Gulf of Mexico, 2004-2013

The offshore oil and gas industry is susceptible to natural and man-made disasters. From 2004 to 2008, five major hurricanes-destroyed 181 structures and 1673 wells in the Gulf of Mexico. State and federal regulatory agencies were forced to deal with an unprecedented number of applications to Rigs-to-Reef Programs because operators wanted to permit their toppled structures as reefs. In 2009, the Minerals Management Service issued a moratorium on reef proposals outside of established planning areas in response to public criticism and NGO assertions that Rigs-to-Reef was becoming a de facto “Ocean Dumping Program”. In 2013, the moratorium was lifted, and in a recently released Rigs-to-Reef Interim Policy Document 2013-07, the Bureau of Safety and Environmental Enforcement specified that no departures from regulatory requirements will be granted for toppled structures. The purpose of this article is to describe the status of hurricane clean-up activity in the Gulf of Mexico, and to identify the challenges associated with unconventional decommissioning operations. Through 2013, 141 hurricane-destroyed structures and 1537 wells have been decommissioned. Remaining structures that await regulatory approval are likely to be more expensive and difficult to decommission relative to previous activity. Federal regulatory responses in the aftermath of the hurricane destruction are described.