BILL ANALYSIS                                                                                                                                                                                                    �





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          |                                                                 |
          |         SENATE COMMITTEE ON NATURAL RESOURCES AND WATER         |
          |                   Senator Fran Pavley, Chair                    |
          |                    2011-2012 Regular Session                    |
          |                                                                 |
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          BILL NO: AB 2267                   HEARING DATE: June 26, 2012  
          AUTHOR: Hall                       URGENCY: No  
          VERSION: April 26, 2012            CONSULTANT: Alena Pribyl
          DUAL REFERRAL: No                  FISCAL: Yes  
          SUBJECT: Marine resources and preservation.  
          
          BACKGROUND AND EXISTING LAW
          In 2010, the California Marine Life Legacy Act was passed (AB 
          2503), authorizing the conversion of decommissioned offshore oil 
          platforms or production facilities into artificial reefs under 
          specified conditions.  

           Existing Law
           1) Allows the owner or operator of an offshore oil structure to 
            apply to the Department of Fish and Game (DFG) for approval to 
            partially remove the structure if specified conditions are met 
            and if the Ocean Protection Council (OPC) determines that 
            partial removal of an offshore oil structure provides a net 
            benefit to the environment compared to full removal. 

          2) Requires the owner or operator of the offshore oil structure 
            to fund the application costs, which include an Environmental 
            Impact Report (EIR) according to CEQA guidelines, a 
            determination by the OPC of the net environmental benefit of 
            the project, a determination of the cost savings by the State 
            Lands Commission (SLC), and preparation of a management plan 
            by DFG.  Application costs are not included in the calculation 
            of cost savings.

          3) Requires the first person to file an application to partially 
            remove an offshore oil structure to pay the startup costs 
            incurred by DFG or the SLC to implement the program, including 
            the costs to develop and adopt regulations. This payment of 
            startup costs will be reimbursed by DFG. 

          4) Requires that a portion of the cost savings to the applicant 
            be shared with the state as follows:
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                  55% of cost savings if the application is transmitted 
                 before January 1, 2017.
                  65% of cost savings if the application is transmitted 
                 between January 1, 2017 - 
                    January 1, 2023
                  80% of cost savings if the application is transmitted 
                 after January 1, 2023
               
          5) Requires state revenue from the program be apportioned as 
            follows: 85% into the California Endowment for Marine 
            Preservation, 10% into the General Fund, 2% into the Fish and 
            Game Preservation Fund, 2% into the Coastal Act Services Fund, 
            and 1% to the board of supervisors of the county immediately 
            adjacent to the project.
                                             
          6) Requires DFG to take title and responsibility for management 
            of the decommissioned offshore oil structure once the partial 
            removal has been granted final approval by DFG and the 
            applicant enters into an agreement with the state to indemnify 
            the state and DFG from liability, to the extent permitted by 
            law, for any claims against the state for actions the state 
            undertakes in implementing the program.

          PROPOSED LAW
          This bill would revise the calculation of cost savings under the 
          Marine Life Legacy Act and require that air quality impacts be 
          considered when calculating the net benefit to the marine 
          environment. Specifically this bill:

          1) Requires that all costs to the applicant of participation in 
            the program be included in the calculation of cost savings 
            until January 1, 2017.

          2) Requires that startup costs paid by the first applicant of 
            the program be included in the calculation of cost savings, 
            and that the funds shall not be reimbursed by DFG.

          3) Requires the OPC to take impacts to air quality into account 
            and to consult with the State Air Resources Board when 
            determining the net environmental benefit of partial removal 
            compared to full removal of an oil structure.

          ARGUMENTS IN SUPPORT
          According to the author, clarifications regarding the Marine 
          Resources Legacy Act are needed to help ensure that the 
          rigs-to-reefs program operates smoothly, encourages 
          participation, protects the environment and expands reef habitat 
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          for marine life along California's coast. Supporters contend it 
          is appropriate that all actual costs incurred by an applicant to 
          partially remove an offshore oil structure be considered when 
          determining the cost savings that must be shared with the state. 
          They also state that the carbon footprint of partially removing 
          an oil platform is much less than that of fully removing an oil 
          platform, and this should be taken into account to honestly 
          assess all environmental impacts.

          ARGUMENTS IN OPPOSITION
          None received

          COMMENTS 
           Loss of state revenue
           Southern California has 27 offshore oil and gas platforms that 
          will eventually need decommissioning. Between 2015 and 2030, 23 
          of the platforms will reach the end of their useful production 
          lifetimes. In a study completed by the Ocean Science Trust that 
          evaluated the available options for decommissioning offshore oil 
          and gas platforms, the estimated cost of complete removal of all 
          27 offshore platforms was $1.09 billion. Partial removal of 
          these platforms was estimated at $478 million, with an estimated 
          cost savings of $616 million (with minor rounding).  

          The calculation of cost savings for each applicant determines 
          the amount of funds the applicant will be required to share with 
          the state.  By including costs to the applicant for 
          participation in the program, this increases the cost for 
          partial removal of an oil platform and reduces the cost savings, 
          and therefore the amount of money to be shared with the state.  
          Although it is not possible to estimate the cost per applicant 
          to participate in the program because of differences in the 
          location and size of oil platforms, EIRs for partial removal of 
          an oil structure can total in the millions of dollars, resulting 
          in a significant reduction of revenue to the state.

          The addition of "air quality" to the list of marine 
          environmental impacts to be considered by the OPC are estimated 
          to be approximately $15,000 - $25,000 per air quality audit, 
          depending on the complexity of the project and how much modeling 
          would have to be done.  

           Air Quality
           According to the Coastal Conservancy, the potential for air 
          emissions for any platform removal is large and highly variable 
          depending on the type of equipment used, the depth of the 
          platform, and the amount of the platform to be decommissioned.  
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          Generally speaking, greater emissions are associated with deeper 
          water (they can be in anywhere from 150 to 1,000 feet of depth) 
          and a higher percentage of platform removal.  A full platform 
          removal can result in 6.75 times the amount of pollutants 
          emitted than a partial removal.  
          
          SUPPORT
          Coalition for Enhanced Marine Resources (co-sponsor)
          Sportfishing Conservancy of California (co-sponsor)
          California Ships to Reefs

          OPPOSITION
          None Received


































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