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Towers Of Life

Abandoned oil platforms in the North Sea;

A SWOT analysis of the Rigs to Reef (RtR) project

By:

Remmelt Boiten, Renee Melkert, Maud Slippens and Remy Hogeboom

Source: www.rig2reefexploration.org

Course: Future Planet Studies, Interdisciplinary Project

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Table of content

1. Introduction p. 3 2. Technical feasibility p. 5 3. Theoretic framework p. 6 3.1 Circular economy 4. Methodology p. 8 5. Results p. 10 5.1 Strengths 5.2 Weaknesses 5.3 Oppurtunities 5.4 Threats 6. Conclusion p. 15 7. Discussion p. 16 8. References p. 17

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1. Introduction

Oilrigs are massive metal frames rising out of the sea; abandoned structures that look like ghost towns. About 20% of the 180 wells in the Dutch part of the North Sea have now been closed down (Dutch Oil and Gas portal, 2016) and the rigs abandoned. The North Sea has been, for more than 50 years, a vital energy supplier for the countries surrounding it. The upcoming transition towards renewable energy and the rapid decrease in oil prices the last two years accounts for an increase in abandoned production rigs, as oil companies focus on the more profitable wells (Grol, 2016).

According to the OSPAR Commission (2016), the international association that regulates cooperation on the environmental protection of the North-East Atlantic ocean, there are a total of 1350 offshore installations in the North Sea. From these rigs there are 245 that should be decommissioned according to the Atlantic Marine and Offshore (AMO, 2016). Decommissioning is the removal or relocation of a rig after it has reached the end of its lifecycle, usually comprising30-40 years (Lakhal et al., 2009).

Figure 1 shows a typical life cycle for an offshore oil rig. This figure highlights the environmental damages during the life cycle. Operational stages such as production, exploitation and development are well reported and studied (Lakhal et al., 2009) but little attention is given on the decommissioning phase in an Oil and Gas Industry. Decommissioning of offshore production rigs is a complex process and goes through

different stages: planning, gaining government approval, implementing the removal, and disposal or reuse of the material (Lakhal et al., 2009). Oil companies are required to decommission their old and abandoned rigs but most companies postpone this phase because of the high expenses (Grol, 2016).

The “Rigs-to-Reefs” project (RtR), a

project developed by the former Minerals Management Service of the US Department of the Interior, has taken a novel approach to decommissioning and tested it in the Gulf of Mexico (Macreadie, 2011). Offshore rigs are converted into artificial reefs with the aim to integrate them in the circular economy. A ‘win-win’ situation is created: fisheries benefit from the increased biomass, and the oil-and gas companies avoid a substantial cost (Marceadie, 2011).

Removing the abandoned oil rigs in the North Sea is expensive and harms the developing ecosystems. The case of the Rig-to-reef program in the Gulf of Mexican demonstrates that these artificial reefs do more good than harm. However, the environmental conditions differ with the conditions in the North Sea and other rules and stakeholder are involved. This research will discuss

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An interdisciplinary approach is essential in researching the different perspectives regarding the beneficiary of the RtR in the North Sea, since it is a complex issue consisting many different stakeholders and perspectives. In this research, we will focus on the technical, political, ecological and business perspective of the possibilities of the RtR program in the North Sea. In this research, we start with a theoretical framework to explain the circular economy and the implementation of this concept in our research. In the next section of this research the methodology will be

Figure 2: production rigs and pipelines offshore (01-01-2006)

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-2. Technical feasibility

There are three different ways to change an abandoned, oil- or gas rig into an artificial reef (Kaiser et al., 2007). Different water depths and differently sized rigs require specific dismantling techniques. The “RtR” programme tries to implement one of three methods.The so called: “Tow and Place” method, the “partial removal” method and the “Toppling” method. To investigate which technique suits the Dutch situation the best, an explanation of the methods is given.

Method 1 “Tow and Place” means trying to leave the complete

construction of the rig intact. The construction is disconnected from the sea floor using small explosives. Afterwards the entire construction can be relocated to a position in the sea where the sea is deeper. Fully emerging the construction and forming the reef (Kaiser et al., 2007). Within the Gulf of Mexico, the ocean depth fluctuates significantly more than the North Sea. In order for the entirety of the metal

construction of the oil rig to be submerged, an increase of water depth of over 20 metres is required. In the Dutch part of the North Sea the are no locations with these qualifications.

Method 2 “Partial Removal” requires halving the construction in size

and placing the top halve next to the bottom halve on the seabed. This method eliminates the formation of an ecosystem in the top layer of the sea. No explosives are required with this method, making it less impactful to the surrounding ecosystems (Kaiser et al., 2007).The “Partial Removal” method does not require a change in water depth. This is because the original length of the structure is altered. When implementing the “Partial Removal” method, the overall height of the structure decreases by a third (Kaiser et al., 2007).

Method 3 “Toppling” also requires the use of small explosives to

disconnect the construction from the seabed. The next step is laying the construction on its side. This method eliminates ecosystem formation in the top and middle layer of the ocean. Positive aspects of this method are that it can be implemented in shallow parts of the sea or ocean (Kaiser et al., 2007). However, if the “Toppling” method is used, a larger area of newly reinforced seabed has to be created. The entire length of the construction needs to be supported. Also the originally placed rocks and concrete serve no purpose anymore, because this is where the construction is detached from the seabed.

From a Technological and sustainable point of view, the “Partial Removal” method is therefore recommended for the Dutch part of the North Sea. This will require the least materials and is the easiest to implement. Also this method provides a larger array of ecosystem services due to its greater reach towards the warmer upper layers of the sea.

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3. Theoretical framework

Figure 3: Conceptual framework. This figure shows the concepts that were used in making a SWOT-analysis (see methodology). The concepts “Rig to Reef” and “Circular economy” connects all the disciplines in general. There can also be connections found between the different concepts within the disciplines Each discipline performed an individual swot analysis, which was then combined into a subordinate SWOT.

3.1 Circular Economy

Interdisciplinarity can mostly be found in the ecological, political and business disciplines. The technical discipline only focuses on the SWOT-analysis (see methodology) of decommissioning process. The other three disciplines focuses on creating a SWOT analysis for the implementation of the RtR project. Within these disciplines, multiple concepts are connected (see figure 3).

The concept of circular economy integrates the four disciplines. The CE emphasises a circular flow of materials, energy, labor and information reduces the environmental impact and increases resource efficiency (Saavedra, Iritani, Pavan. & Ometto, 2018).

The First Law of Thermodynamics highlights that matter can neither be created nor destroyed. In the past, this has meant the production of vast quantities of waste from industrial processes. The notion

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of the circular economy argues that industrial processes can serve as starting point for other processes (Frosch & Gallopoulos, 1989) (Pomponi & Moncaster, 2017). For instance, biological ecosystems can use the old, industrial ecosystems to thrive and increase its biodiversity. The

approach of ecosystem services could be used as a tool to illustrate the internal and external benefits of businesses would gain from these biological ecosystems.

Also, Corporate Social Responsibility (CSR) is also an important aspect of CE and needs to be considered. CSR can be effective because it creates a strong feedback to society by creating awareness about sustaining the habitat quality of former industrial structures.

Policy is a fundamental block for the RtR project for it can create barriers in the form of taxes, laws and regulatory frameworks (Pomponi & Moncaster, 2017). Currently, the Mijnbouwwet obligates the removal of rigs that are not productive. The Mijnbouwwet concept illustrates how the OSPAR is a big component in decision making. OSPAR also sets guidelines for the actual decommissioning but also for performing Risk Assessments to determine the ecological risks of implementing the RtR projects. These assessments can be used to illustrate how corporations are responsible for the status of environment around the rigs.

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4. Methodology

This chapter provides the methodology used for this research, including the type of data was collected per discipline. The method used for this research is the SWOT analysis. SWOT assists the formulation of strategy (Dyson, 2004). It is a structured planning method that evaluates possible actions on the basis of four elements: Strengths, weaknesses, opportunities and threats (Pahl & Richter, 2007). In the case of this research a SWOT analysis is used to assess whether a rigs-to-reef program could be a viable strategy in decommissioning oil rigs in the Dutch part of the North Sea.

The SWOT analysis consists of 2 components: the internal analysis and external analysis. The internal analysis consists of the strengths and weaknesses and the external analysis consist of the opportunities and threats (Pahl & Richter, 2007). First, you have to look inside of an organisation or entity and evaluate its strengths and weaknesses. During the analysis of the internal factors, the organization’s objectives are very important, because it can lead to different strengths and weaknesses. To evaluate the strengths, both the internal perspective and the point of view of others should be taken into consideration. Also, when looking at strengths, it is important to think about them in relation to competitors. Similarly, when

looking at weaknesses, consider it for both an internal and external perspective. After understanding the strengths and weaknesses, the opportunities open to you and the threats you face can be identified. The opportunities and threats are part of the external analysis, because they are outside of the organisation or entity. To identify opportunities, it is useful to look at the strengths and see if these open up any opportunities. Alternatively, looking at weaknesses and see if it opens opportunities when eliminating them is also an option. To find ant threats, it is important to look at what competitors are doing and what obstacles you face. Finally, after doing the internal and external analysis the results of a SWOT analysis are often shown in a matrix (figure 4).

A SWOT analysis is a method of categorization and has some weaknesses that need to be taken into consideration. For instance, it makes users compile lists instead of thinking about actual important factors to achieve objectives. Also, results may appear to be out of balance as the resulting matrix does not critically prioritize the results (Pahl & Richter, 2007).

For this research, the concept of Rigs-toRo-Reefs is used to find out if it can contribute to a circular economy. The SWOT analysis provides a structured planning method to create and implement the best strategy for a circular economy (Pahl & Richter, 2007). This method is used for each discipline: technical, ecological, business and politics. Subsequently, the results of these four analyses will lead to one big analysis of the four disciplines together which will result in an overall conclusion (see figure 5). The data collected to do the analysis will be both primary and secondary data differing for each perspective.

Figure 4: The four aspects of a SWOT-analysis Figure SEQ Figure \* ARABIC 1: SWOT matrix

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5. Results

This chapter provides the results of the SWOT analysis, detailing the strengths, weaknesses, …. Of an RtR project in the Dutch North Sea. Each element is discussed separately, and a concluding section presents the overall evaluation. In order to answer the main question, four sub-questions have to be answered first. To begin with, the strengths of the RtR program are examined. Subsequently, the weaknesses of the RtTR program are examined giving together the internal analysis. After that, the opportunities and threats are examined which make up the external analysis.

5.1 Strengths

The RTR program has proven to be successful on a number of fronts (Ajemian et al., 2015). For the Netherlands, success can be found in the strengths of climate accountability and CSR because this could drive Shell towards making the transition of the industrial ecosystems towards biological ecosystems. This transition conserves the ecological habitat and provides the opportunity to increase the marine biodiversity.

In the Netherlands regular citizens have managed to hold their government accountable for taking insufficient action against climate change. The Urgenda Climate Case (2015) is the first case in the world where citizens have used the District Court (of The Hague) to force their government to reduce emissions. On June 24 2015, the Court decided that the Dutch government is required to reduce emissions by at least 25% by the end of 2020 in comparison to 1990 levels. This means that the Dutch government is forced to take more effective action on climate change from now on (Urgenda, 2015).

Shell is another important stakeholder in reducing the emissions. It is the only company that owns oil rigs in the North Sea, therefore it is the local market leader which gives them a lot of power. Moreover, it also has complete control over the production of oil in the Dutch part of the North Sea (Pirog, 2007). A strong position in the global market gives Shell a significant bargaining power in the industry and can therefore help in implementing the RtR project.

In order to decrease its carbon footprint and develop better methods in producing oil, Shell has been constantly trying to improve its technologies (Innovation Through R&D, 2017). Strong research and development provides competitive advantage and helps to reduce expenses. Decommissioning abandoned oil rigs costs a lot of money. An alternative like the RtR project can be great for a company like Shell to reduce its costs. In addition, the RtR program can help reduce Shells debt, because the past few years shell has experienced an increase in debt. Its debt increased from 37774 million in 2012 to 58379 in 2015 (Debt Information, 2017). Increasing debt leads to more risk and more cash flow is paid in interest. These increasing financial obligations might affect the firm in some way in the future.

The oil- and gas rigs owned by Shell provide a hard substrate in the soft-sediment dominated ecosystem of the North Sea (INSITE, 2017). Benthic communities have colonized these structures and attract organisms from higher trophic levels (INSITE, 2017). The food web build upon the communities that live on these structures increases to total biomass in the North Sea, which consists mainly of species-poor, and sandy bottom ecosystems (INSITE, 2017)(Verbeek, 2011).

Mussel species, such as the Ostrea edulis, are early colonizers, which have been found on these structures (Smaal, Kamermans, Engelsma & Sas, 2015). Ostrea edulis has been reintroduced in the Dutch part of the North Sea and are valuable for the overall ecosystem functioning (van der Stap, Coolen & Lindeboom, 2016). They create oyster beds which attracts epibenthic- and mobile species species. They provide substrate for other species and filter the water column, which enhances pelagic-benthic ecosystem coupling. This stimulates phytoplankton turnover resulting in more

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primary production and thus leads to a more productive and diverse ecosystem (Smaal, Kamermans, Engelsma & Sas, 2015).

These oysters could mean a lot for the creation of ecosystems of the rigs but it is unknown whether they have already settled here because of the restricted 500m zone (Smaal, Kamermans, Engelsma & Sas, 2015). Other important species found on the hard substrate in the North Sea: Electra, Tubularia, Lophilia pertusa (Coolen, et al., 2016)

5.2 Weaknesses

In 1998 in the Portuguese town of Sintra, the future of oil and gas industry in the North Sea was decided by the creation of “the decision of 98/3”. This decision recorded the obligation for licensees to dismantle offshore rigs (OSPAR, 1998). In the Netherlands, the OSPAR decision of 98/3 is retrieved in “de mijnbouwwet” (the mining law), which obligates that all rigs in the Dutch part of the North Sea should be removed after use (Mijnbouwwet, 2002).

According to the Central Bureau of Statistics (2016) the Dutch gas is running out; the Netherlands has 20% of their initial reserves left. This means that the coming years more rigs will not be producing and need to be dismantled according to the law. In total the Dutch part of the North Sea hosts 180 rigs, of which at least 22 needs to be decommissioned (Atlantic Marine and Offshore, 2016). The OSPAR convention, in which 15 member states of the OSPAR Treaty and the EU work together to protect the marine environment of the North Sea, was founded in 1992. The OSPAR convention called on all members to negotiate during a large conference because of the Brent Spar issue of public concern (OSPAR, 1998).

The Brent Spar was a North Sea oil storage and tanker which protest became an issue of public concern in 1995, when the British government announced its support for Shell's application for its disposal in deep Atlantic waters at the west coast of Scotland. Shell U.K. decided that this was the Best Practicable Environmental Option (BPEO) (Zyglidopoulos, 2002). However, this decision caused a great deal of controversy, and Greenpeace organized a campaign opposing this deep-water-disposal plan for more than three weeks. The occupation of the oil storage buoy received a great deal of publicity, which led to a greater opposition to the disposal plan by the general public (Zyglidopoulos, 2002). In the end, even though Shell had the support of the British government, Shell abandoned its plans to dispose the Brent Spar. In January 1998, Shell announced its decision to re-use much of the structure in the construction of a new harbour in Norway. This made the EU realize that the oil/gas sector needed a shared vision about the decommissioning of production rigs at the end of their lifecycle, therefore the conference in Sintra was called on (Zyglidopoulos, 2002).

OSPAR can choose between three types of measures: decisions, recommendations and guidelines. Decisions are binding measures for the member states of OSPAR, which means that its decisions should be converted into national law and regulations. During the OSPAR conference in Sintra, the member states jointly voted for such a binding measure: the OSPAR decision 98/3. This states that what you can remove after use, you have to remove. If the rig is too large and puts human lives in danger by removing it, then there are exceptions and an operator can request a permit from the Minister of Economic Affairs to leave parts of the rig in the sea. But in the Netherlands those exceptions are not in order because of the smaller rigs that do not match those exceptional criterias (OSPAR, 1998).

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Article 47 of the legislation that it is within the mandate of the Minister to force operators in providing financial security, such as a bank guarantee. The Minister (EZ) can therefore, according to the law, impose a deadline in which an operator must dismantle a non-producing rig (Mijnbouwwet, 2002).

‘Energiebeheer Nederland’(EBN), the state-owned company that participates in all Dutch oil and gas fields, however, states in a report that this never happened. So far there are only a few rigs decommissioned in the Dutch part of the North Sea and on average it took four to twelve years before that rig was completely removed (EBN, 2015). According to law, at the time that an oil- or gas field is empty, the operator must submit a plan about the future of the rig. This plan is then reviewed by the government and approved or not (EBN, 2015).

5.3 Opportunities

Multiple opportunities can be found for implementing the RtR project in the Dutch part of the North Sea. The OSPAR has a great influence in the fate of the rigs owned by Shell. Rigs could be designated as Marine Protected Area (MPA) or decisions on decommissioning are made by the OSPAR. There are opportunities for the ecology and Shell.

During the OSPAR convention, OSPAR agreed to promote the creation of a MPAs network in the North-East Atlantic. Expansion of this network can be improved by integrating the abandoned rigs that are suitable as artificial reef, which will be known after performing ecological Risk Assessments. If the rigs and the 500 safety zone become designated as Marine Protected Area, the ecological habitat around these structures could thrive further. The 500 safety zone is an area around the rigs where fisheries are prohibited to come. No fishing activity around the rigs could make the area interesting for conservation studies on increased biodiversity (

van der Stap, Coolen & Lindeboom,

2016) (Smaal, Kamermans, Engelsma & Sas, 2015).

As a result, designated MPAs could then act as a fish-stock (MVI, n.d.). This creates a provisioning ecosystem service for fisheries because they could profit from the migrating fish between these MPAs. The North Sea lab is currently researching the possibilities of offshore windmill parks to function as a collective source for energy companies, fisheries and other stakeholders (MVI, n.d.). This research will be done in 2018 and could give an example of how artificial reefs can contribute to the economy.

According to the US Energy Information Administration (EIA) the energy consumption of the world will increase by 40% by the year 2040. Additionally, demand for cleaner energy is also increasing. Shell is a huge multinational acting all over the world. In order to meet future energy demands of developed and emerging nations shell has been focussing on expanding its operations even more strategically across the globe. The RtR program gives the opportunity to fully focus on those new markets.

From a political perspective, the RtR program is already blocked because of the OSPAR Decision 98/3 from 1998 and the ‘Mijnbouwwet’. However, it is not written in the “Mijnbouwwet” (2002) how and when the rigs must be removed. The Minister for Economic Affairs may even, in accordance with this law, impose a deadline for dismantling of the rig towards the operator. This deadline however keeps being postponed because of the loophole and high expenses for oil companies to decommission the rigs.

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5.5 Threats

Results of the Risk Assessments could conclude that the RtR program is unsuitable for the rigs. Both invasive species and contaminants pose a threat and could seriously do damage to the marine ecosystems. The EBN discourages the development of Risk Assessment by preventing the appearance of abandoned rigs on the political agenda. On the contrary, the start of the RtR project could

promote this. However, another threat is the crooked character of Shell in obeying the law; even RtR laws could be violated.

The oil and gas rigs provide an ecological addition to the sandy bottomed environment and thus create a new habitat for species that are not able to procreate on the sandy bottoms. Also, the increased connectivity between natural sub-populations increased the function of the rigs as “stepping stones” (Coolen et al., 2015). This could increase the biodiversity of species in the North Sea, depending on the dynamics between indigenous and non-indigenous species.

Non-indigenous species (NIS) are introduced in the North Sea with ballast water and fouling on ships’ hulls as main route. With more ship traffic, as a result of a growing global economy, comes a greater risk of new species being introduced through biofouling (Stap, 2016). NIIS could affect the existing ecosystems by either facilitating or preventing the establishment of other species and thus altering the food web (Mesel de, 2015).

However, lack of data on NIS could create uncertainties in calculating risk of possible invasive species. NIS could pose a threat by interfering with communities’ dynamics and performance but co-existence is also possible (Coolen et al. (2016). It is therefore important to stimulate research on NIS in order to determine whether they pose a threat or not. However, biological surveys cannot be performed because of the 500m prohibition zone (Smaal, Kamermans, van de Have, Engelsma & Sas, 2015). This hinders the research of species distribution.

An addition to biological threats, Poly Aromatic Hydrocarbons (PAHs) are organic compounds that have threatening, toxic, mutagenic and/or carcinogenic properties (Hussein & Mansour, 2016). They are highly lipid soluble and can therefore be transported over great distances. PAHs bio-accumulate and can especially be found in filtering organism such as mussels and oysters (Abdel-Shafy, H. & Mansour, M., 2016) (Hussein & Mansour, 2016).

PAHs in the North Sea are discharged with the produced water of the offshore industry during the treatment process. The OSPAR has set an upper limit of 30 mg per liter for dispersed oil in discharged production water. In 2005, this limit was exceeded in the southern part of the North Sea (Ospar, 2009). Emissions of oil has decreased (Rijkswaterstaat, 2016) but monitoring current and future emissions is needed.

Another source of PAHs is the drill cutting piles. Disturbance of the cutting piles causes translocation and spreading of the sediment particles, which are contaminated with PAHs and metals, and can thus cause disturbance in a larger area compared to undisturbed cutting piles (Henry et al., 2017). Even though there is much known about the possible effects PAHs can have on the environment, there is little data on the emissions of PAHs. This makes it hard to calculate the risk.

In addition to quantitative shortages, most Risk Assessment on PAHs focus on the health effects of humans, which causes lack of qualitative data on toxic effects of these contaminants. Projects on

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human activities that act as pressures so that the state of the marine ecosystem can be determined. Again, lack of data input is the main obstacle in performing such projects.

As for political and business threats, money seems to play a big role for both the government and Shell. Keeping the decommission costs low is in the interests of the Dutch government because the she participates in the oil industry through its state company EBN (Energiebeheer Nederland). 40% of the gas/oil fields in the Dutch part of the North Sea is owned by EBN (EBN, 2017). After decades of benefits from the gas/oil reserves, which nearly three quarters of every euro of pumped up gas ended up in the state treasury, should the decommissioning or ‘clean-up costs’ now also be shared by the operators and society through the Dutch government or the EBN?

The estimated cleanup costs are rising each year. Especially the process of closing the wells often proves to be an expensive process: costs are sometimes up to 50 percent higher than estimated according to EBN (2015). The EBN holds on to a reserve of 3.9 billion euros for the decommissioning of offshore installations (EBN, 2015). This estimation is probably too low and the correct amount of money necessarily for clean-up will be around 11 billion euros. These clean-up costs are the drivers of the crooked character of shell. In 2007, Shell violated corruption rules from the Foreign Corrupt Practices Act (FCPA) in the US and had to pay a fine of 30 million euro’s (The FCPA Blog, 2017). Violations of rules and regulation affect brand image and goodwill. Due to the fact that Shell has already violated laws in the past, they should be careful in taking other steps like the RtR project.

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6. Conclusion

In this research we discussed the strengths, weaknesses, opportunities and threats of the RtR program to develop an argument about implementing the RtR program in the Dutch part of the North Sea. Our main research question was: To what extend could the Rigs-to-Reef program benefit

the Dutch circular economy in the Dutch part of the North Sea?

This research argues that the RtR program can definitely benefit the circular economy in the North Sea, because of the cheap way to recycle a production platform and make it sustainable for the environment at the same time. The RtR program is the most realistic way to remove old production platforms. It is a good program for oil and gas businesses because of the cheap removal costs which makes it the best solution business wise. Ecologically the RtR program is beneficiary because of the creation of ecosystems. The rigs create the food web build upon the communities that live on these structures increases to total biomass in the North Sea. From a Technological and sustainable point of view, the “Partial Removal” method is recommended for the Dutch part of the North Sea. This will require the least materials and is the easiest to implement. Also, this method provides a larger array of ecosystem services due to its greater reach towards the warmer upper layers of the sea. From a circular economy point of view the RtR program is a good way to remove the structures in a cheap way and therefore the most realistic program to make the removal of production platforms more sustainable.

Nevertheless, there are some problems regarding the RtR program that need to be sorted before this program is possible in the North Sea. First of all, the legislation needs to be changed in the

Netherlands and whole of Europe to even make this program possible. Right now, the RtR program is illegal because according to the Dutch law a production platforms needs to be removed in its entirely. Secondly, more research needs to be done in order to know if the platforms really increase biomass as much as is known now. To do more research the 500-meter prohibited zone around platforms need to be open for research.

As a policy, we recommend to start the awareness about old production platforms in the North Sea to get it on the political agenda. It needs to be on the political agenda to change the legislation regarding deep-sea disposal and to open the 500-meter prohibited zone around platforms for further research. The research needs to give more information about the nature conservation and biomass increase around the production platforms. If this turns out positive and the legislation is changed, implementing the RtR program in the Dutch part of the North Sea will benefit the circular economy.

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7. Discussion

The lack of data and research on the ecological side of the RtR program is a big problem to even know to what extend the RtR program is not just a cheap way for an energy company to remove their platforms instead of real increase in marine biomass. The SWOT analysis is a method of

categorization and has some weaknesses that need to be taken into consideration. For instance, it makes users compile lists instead of thinking about actual important factors to achieve objectives. Also, results may appear to be out of balance as the resulting matrix does not critically prioritize the results. In a follow-up research, there needs to be more information about a policy recommendation to make sure the RtR program can happen in the Netherlands. Which stakeholders can help and how the RtR program can become legal and on the political and business agenda.

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