Determining the energy budget of the oceans requires evaluating the rates of available potential energy conversion in the circulation. Calculating these conversion rates depends upon the definition of an appropriate "reference" state of the density field, but this definition is complicated in the oceans by the presence of bottom topography. The trapping of dense fluid by topographic barriers means that there are multiple definitions for the reference state. The approach taken in this paper is to examine the sensitivity of the available potential energy budget to several methods for defining the reference state. The first method makes allowances for restrictions imposed on the flow by topography, however it is computationally intensive. The ...