Dear Fellow Committee Members,
Well, it may be Saturday night, but Im afraid I need to alert you to some very bad news.
After having some Idle Iron discussions here in the Gulf Coast and during a trip to Washington D.C. these past few days, I have learned to my dismay that W&T may have already filed plans with BSEE to quickly move forward to remove ALL of the HI-A-389 platform from the Sanctuary, as soon as later this month. Their purported plans are to physically move the entire structure about 13 miles away to a Texas Artificial Reef site on HI-A-349, and to tip it over on its side, as consistent with the RTR program and Coast Guard regulations.
Obviously, this was a great fear of many of us, that W&T would quickly move ahead with the quickest solution for removal, and completely reject the SACs request for delay until at least September 2013. True, it has always been in their financial interest to do so, but we had all hoped that they and the federal and state agencies would be able to work expeditiously together to find a win-win solution, and agree with the SAC that it was worth taking the time to find an optimal solution.
Just the other day, I watched my DVD again of W&T CEO Tracy Krohn being interviewed by Jean Michel Cousteau a few years ago, in his PBS documentary on all the Sanctuaries. Tracy seemed to really care about the marine life under the platform, and hopefully he still does, and may not know what his people are going to do to it all. Moving this jacket to a RTR site will be near-totally destructive of the marine life on and around the platform, as well as potentially damaging to the Sanctuary Coral Cap nearby.
It will be critical to see if their plan calls for mechanical cutting of the 8 legs, or are they going to move ahead with explosives on each one. Will they use explosives on each of the 8 conductors too? It is my recollection that the grandfathering of the platform into the Sanctuary, AND then into the MMS No Activity Zone, allowed the use of explosives on both counts, which was a mistake, in my view. Explosives on this structure could be near-totally destructive of the top-to-bottom marine life, not to mention the silt cloud impact on the EFGB coral cap, during the removal process. Barge anchor chains and lift equipment could potentially also have a significant impact on the coral cap, since its barely a mile away.
Hopefully, Sanctuary Management will have to grant approval of the plan/permit, and W&T wont just move ahead later this month.
I strongly recommend that GP immediately send a letter to W&T and BSEE reminding them that the Sanctuary has not granted approval, and they should not proceed with any activity until further notice. Unfortunately, if a plan has indeed been submitted to remove it, precious time and money have already been invested by W&T in preparing such a proposal, and companies are often resistant to changing their plans, once theyve set upon a course of action. Still, hopefully, theyll be willing to change their plans.
This situation is rapidly deteriorating. Some configuration of reefing-in-place was always the preferred alternative. Ive heard several reasons for the failure to reach a better solution, but Im not going to go into all of those in this e-mail. Suffice to say, no one has been able to find a win-win solution yet, but for sure, treating this very unique platform as just another RTR donation is truly a mistake.
I can only hope that someone in a position of authority can cause a better outcome. Optimally from my viewpoint, a 25 above the waterline abandonment solution would be ideal, just as John Hoffman has suggested with his Save-the-Blue model. Somehow, someway, someone has to have the regulatory power to make this happen.
No matter what is ultimately decided, W&T needs to be released from any future liability or expense, after they sign an agreement and deposit at least 50% of funds saved to either RTR or the Sanctuary. Monthly operating expenses, including liability insurance, continue to add up, with no offsetting revenue. I do not know why the production (and thus the offsetting revenue) stopped. The last producing well, a satellite well 6 miles to the south, either depleted the gas reservoir or became uneconomic at current low gas prices. No matter which reason, theyre losing money monthly, and want to end their expenses as soon as possible.
Time may indeed have just about run out on HI-A-389, unless we can figure out how to influence the people with the power to change what is truly going to be a tragic outcome, if a reef-in-place solution is not found instead. Lets all encourage all the decision making authorities to find a better solution than RTR for HI-A-389.
Regards,
Clint
