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Testimony of

Athan Manuel

Director, Lands Protection Program

Sierra Club

Before the

Committee on Energy and Natural Resources

United States Senate

Regarding:

Oil and Gas Resources on the Outer Continental Shelf

and Areas Available for Leasing in the Gulf of Mexico

January 25, 2007

Prepared by: Keren Murphy, Conservation Organizer

Mike Gravitz, U.S. PIRG Oceans Advocate

Athan Manuel, Director, Lands Protection Program

Mr. Chairman, ranking minority member, and members of the Committee,
good morning. My name is Athan Manuel, and I am the Director of the
Lands Protection Program for the Sierra Club.

I am here representing over 750,000 Sierra Club members who belong to
more than 65 chapters and 450 groups nationwide. We are the largest
environmental grassroots organization in the country.

I am very appreciative of the opportunity to testify this morning
regarding oil and gas drilling on the Outer Continental Shelf and areas
available for leasing in the eastern Gulf of Mexico. Most of my comments
will focus on the environmental problems caused by off shore oil and gas
drilling.

**New offshore oil and gas drilling**

It will come as no surprise that the Sierra Club strongly opposes
drilling in the eastern Gulf of Mexico, the area opened by the Gulf of
Mexico Energy Security Act of 2006 (S. 3711), or in any off shore areas
in the outer continental shelf currently off limits, for a number of
important reasons:

1.  New off shore oil and gas drilling represents a measurable hazard to
    the marine environment of the eastern Gulf of Mexico and all our
    coastal waters. We do not believe that the beaches, coastal
    environment, marine resources, and billion-dollar tourism industry
    of the eastern Gulf of Mexico should be sacrificed for a small
    amount of oil and natural gas.

2.  The natural gas and oil estimated to be recoverable in the eastern
    Gulf of Mexico will not solve our energy problems. According to the
    Minerals Management Service, offshore areas opened by S.3711 will
    supply only 25 days of oil and 35 days of natural gas over the next
    60 years at 2004 consumption rates. The new area, loosely called
    182, is in very deep water and contains relatively small amounts of
    oil and natural gas, about 525 million barrels of oil and 2.2
    trillion cubic feet of gas, according to MMS.

3.  Most off shore oil and gas reserves are already available. According
    to the MMS, 80 percent of recoverable oil and natural gas reserves
    are in areas already available for leasing and drilling. The Sierra
    Club feels that there is no justifiable reason to turn to our
    special places for drilling.

4.  Finally, there are smarter ways that we can and should address our
    energy needs rather than allowing our coastlines to be threatened
    with oil and gas drilling.

**1. New off shore oil and gas drilling is bad for our coastal
environment, our beaches, for marine life and their habitat, and for the
broader environment.**

While there have been many advances in oil and gas recovery technologies
in recent decades, many serious consequences still result from
exploration and drilling for either oil or gas.

***Harm to wildlife***

America's coasts are a complex mosaic of sea grasses, wetlands,
estuaries, beaches, and dunes. Off shore drilling is simply not
compatible with this fragile ecosystem.

The Gulf of Mexico is home to more than twenty species of marine
mammals, four species of shark, seven species of tuna and five species
of sea turtle. All five turtle species found in the Gulf are either
endangered or threatened, making any adverse effects very significant to
the overall populations.

This area is the heart of one of the most important migration corridors
in the world, traveled by hundreds of species of birds[^1]. Offshore oil
rigs interfere with migratory routes, spawning, and feeding areas for
target species, generate pollution that destroys crucial nursery habitat
for larval and juvenile stages, and cause large and small oil spills
that reduce catches.[^2] In addition to migratory birds, the eastern
Gulf of Mexico supports large populations of brown pelicans and bald
eagles.

The eastern Gulf coastal waters are also home to a number of important
environmentally sensitive areas like the Big Bend Seagrass Area and
Tortugas Ecological Reserve. These reserves and coastal shoreline host a
number of environmentally sensitive species such as:

Important beach areas include the: Florida Panhandle, the Big Bend area,
southwest Florida, and Ten Thousand Islands. Al these could be affected
by a large oil spill in the eastern Gulf with the beaches of the Florida
Panhandle most at risk.

***Onshore damage***

The onshore infrastructure associated with offshore oil or gas causes
significant harm to the coastal zone. The shoreline processing
infrastructure for offshore drilling often requires industrialization
within the coastal zone of affected states, using installations similar
to onshore storage and processing facilities including miles of pipeline
and roads and other industrial apparatus like ports, helipads, and
dorms.

For example, OCS pipelines crossing coastal wetlands in the Gulf of
Mexico are estimated to have destroyed more coastal salt marsh than can
be found in the stretch of coastal land running from New Jersey through
Maine.[^3] Years of wear and tear by the oil and gas industry had torn
apart the coastal wetlands of the Louisiana Bayou. Thanks in part to
drilling operations, Louisiana is losing 25 square miles of coastal
wetlands each year, eating away at natural storm barriers.

***Water pollution***

Drilling muds are used to lubricate drill bits, maintain downhole
pressure, and serve other functions. Drill cuttings are pieces of rock
ground by the bit and brought up from the well along with used mud.
Massive amounts of waste muds and cuttings are generated by off shore
oil and gas drilling operations -- an average of 180,000 gallons per
well.[^4] Most of this waste is dumped untreated into surrounding
waters. Drilling muds contain toxic metals, including mercury, lead and
cadmium. Significant concentrations of these metals have been observed
around drilling sites.[^5]

A second major polluting discharge is "produced water," the water
brought up from a well along with oil and gas. Offshore operations
generate large amounts of produced water. The Minerals Management
Service estimates that each platform discharges hundreds of thousands of
gallons of produced water every day.[^6] Produced water typically
contains a variety of toxic pollutants, including benzene, arsenic,
lead, naphthalene, zinc and toluene, and can contain varying amounts of
radioactive pollutants. All major field research programs investigating
the fate and effects of produced water discharges have detected
petroleum hydrocarbons, toxic metals and radium in the water column down
current from the discharge.[^7]

***Air pollution***

Drilling an average exploration well for oil or gas generates some 50
tons of nitrogen oxides (NOx), 13 tons of carbon monoxide, 6 tons of
sulfur dioxide, and 5 tons of volatile organic hydrocarbons. Each OCS
platform generates more than 50 tons per year of NOx, 11 tons of carbon
monoxide, 8 tons of sulfur dioxide and 38 tons of volatile organic
hydrocarbons every year.[^8]

***Global warming pollution***

Methane hydrates are ice-like structures formed from frozen water and
methane. These structures are found in Arctic permafrost and beneath the
seafloor of the Outer Continental Shelf where water depths are greater
than 500 feet. The Congressional Research Service reports "safety
problems related to gas hydrates may be anticipated. Oil and gas
operators have recorded numerous drilling and production problems
attributed to the presence of gas hydrates, including uncontrolled gas
releases during drilling, collapse of well casings, and gas leakage to
the surface." The report continues that methane hydrates easily become
unstable, potentially triggering seafloor subsidence and catastrophic
landslides. In addition, a single unit of methane hydrate can release
160 times its own volume in gas.[^9] As methane is a greenhouse gas more
than twenty times more potent than carbon dioxide in contributing to
global warming, this volume of gas release would be extremely dangerous.

***Oil spills***

If offshore areas are leased for gas exploration there is always the
possibility that oil also will be found. There is no known example of a
case where a lease prohibits an oil company from developing oil if oil
is found in a "gas prone" region. There is no documented instance of any
company ever agreeing to such a condition in the history of the OCS
leasing program. Without such a restriction included in a lease there
would be no assurances that oil would not in fact be developed, raising
the possibility of an oil spill. According to statistics compiled by the
Department of the Interior, there were some *3 million gallons* of oil
spilled from OCS oil and gas operations in 73 incidents between 1980 and
1999.[^10] Oil is extremely toxic to a wide variety of marine species,
and as noted by a recent National Academy of Sciences study, current
cleanup methods are incapable of removing more than a small fraction of
the oil spilled in marine waters.

It would only take 24 hours after a petroleum spill in the eastern Gulf
of Mexico\'s Lease Sale 181 area for oil to "sully Florida\'s Panhandle
beaches if the spill was swept up by the gulf\'s powerful Loop Current.
This spill could travel around the Florida Keys and contaminate
estuaries and beaches from the Everglades to Cape Canaveral," according
to Congressional testimony by oceanographers from the University of
South Florida.

It is important to note that, with the exception of oil spills, the
environmental damages described above result from drilling or exploring
for either oil *or natural gas*. Any suggestion that restricting leases
to natural gas drilling only will not adequately reduce risk of
environmental impacts i

***Hurricane risks***

The Gulf Coast and East Coast - the two offshore areas most coveted by
the oil and gas industry - are no strangers to destructive hurricanes
that could wreak havoc on offshore drilling operations. The 2005
hurricane season highlighted the danger of depending on this vulnerable
offshore oil and gas infrastructure. It was the first year in recorded
history with three category 5 storms\-\-- Katrina, Rita, and Wilma.

[]{.mark}

In 2005, Hurricanes Rita and Katrina caused massive spills of oil and
other pollutants and seriously affected the production, refinery
capacity, and price of oil in the United States. The storms caused 124
oil spills into the waters of the Gulf of Mexico. During Hurricane
Katrina alone 233,000 gallons of oil were spilled. There were 508,000
gallons spilled during Hurricane Rita.[^11] The U.S. Minerals Management
Service reports that Hurricanes Katrina and Rita destroyed 115 petroleum
production platforms in the Gulf of Mexico. The storms also damaged 457
pipelines connecting production facilities in the Gulf and bringing oil
and natural gas to shore[^12].

[]{.mark}

A full year after Katrina, BP admitted that a damaged oil well valve in
the Gulf of Mexico was still leaking oil. The knee-jerk reaction to
throw up more rigs offshore -- especially in hurricane-prone waters like
Florida's Gulf Coast and the Eastern Seaboard -- is precarious at best
and not smart energy policy. For more on the pollution and hurricane
risks of offshore drilling:

***Drilling and testing***

*Seismic Surveys*

The first step to drilling for oil and gas involves doing an inventory
of estimated resources. One technology used for this type of inventory
is a "seismic survey." This technology involves ships towing multiple
"airgun" arrays with tens of thousands of high-decibel explosive
impulses to gather geologic profiles of seabed rock structures. These
airgun arrays fire regular bursts of sound at frequencies in the range
of 20 to 150 Hz, which is within the auditory range of many marine
species, including whales.

Marked changes in behavior in marine species in response to loud
underwater noises in the ocean have been well documented. Seismic survey
devices and military sonars (which operate at a similar decibel level)
have been implicated in numerous whale beaching and stranding incidents,
including a December 2001 mass stranding of 16 whales in the Bahamas, an
incident of Cuviers beaked whales being beached and stranded in the
Galapagos Islands and a more recent stranding in the Canary
Islands.[^13]

The auditory organs of fish are particularly vulnerable to loud sounds
such as those produced by survey airguns. As fish rely on their ability
to hear to find mates, locate prey, avoid predators, and communicate,
damage to their ears can seriously compromise their ability to
survive.[^14] In addition, mortality is possible in species like salmon
that have swim bladders (the flotation organ that fish use to orient
themselves vertically in the water), which have been shown to rupture on
exposure to intense sounds.[^15]

*"Dart Core" Seabed sample extractions*

"Dart core" sampling, another survey technique, consists of dropping
large hollow metal tubes from ships to vertically puncture the seafloor.
The samples are retrieved and analyzed for information about subsea rock
structures. This technique is extremely destructive to seafloor benthic
organisms and fish habitat, discharging silt plumes that are transported
on ocean currents and smothering nearby life on the seabed.

*Seafloor "Grab samples"*

"Grab samples" are retrieved from the seafloor sediments with large
hinged "buckets" dropped from the shipboard into the seafloor to analyze
silt, rocks, and seabed sediments and seafloor organisms. These buckets
damage benthic organisms at the seafloor and cause silt plumes.

*Directional Drilling*

Directional drilling has been used to access oil and gas reserves under
our National Parks, the Great Lakes, and the Gulf of Mexico. In the case
of drilling off shore, the wellhead is on shore while the bottom of the
well may be thousands of feet offshore. In 1997, Governor Engler of
Michigan directed the Michigan Environmental Science Board to study the
impacts of directional drilling on environmental and human activities.
This study concluded impacts from directional drilling could result in
the contamination of groundwater aquifers and loss of habitat while also
increasing noise levels, odor, and congestion, impacting recreation and
tourism.[^16]

***Impact on coastal economies***

Our coasts and marine waters provide the economic lifeblood for
thousands of tourism and fishing communities, providing billions of
dollars of economic activity and millions of jobs. They are destinations
for thousands of vacationing families each year, sanctuary for fish and
wildlife and a critical part of America's "sea to shining sea" natural
heritage. Offshore drilling is simply not compatible to the quality of
economy and life this fragile ecosystem supports.

There are five main economic benefits attributed to beaches and
coastlines.

1.  Increased sales, income and employment opportunities resulting from
    spending.

2.  Enhanced property value,

3.  Expansion of the federal, state and local tax base.

4.  Protection of developed shorefront property from storm surges,

5\. Provide recreational opportunities for people

Tourism in America is a \$1.2 trillion industry with coastal communities
representing over \$700 billion annually[^17]. Travel and tourism is one
of the largest employers in America, employing approximately 16.9
million people[^18]. It is estimated that in 1992 beaches contributed
approximately \$170 billion annually to the national economy[^19]. In
South Carolina alone, beaches generate \$1.54 billion in wages and
earnings[^20].

Florida is one of the world's top travel destinations with 825 miles of
beaches.[^21]. With nearly 80 million tourists in 2005, the hospitality
industry generated approximately \$57 billion for Florida's economy and
helped create nearly one million jobs. Florida's tourism industry is
responsible for 20 percent of Florida's economy. Miami Beach alone
reports approximately 21 million tourist visits annually. In 1992, about
40 million tourists visited Florida, spending nearly \$14 billion and
creating about 630,00 jobs with a payroll of \$8.9 billion [^22].

In addition to potentially catastrophic effects on the tourism industry,
drilling for gas and oil off our coasts could have significant negative
impacts on commercial fishing. Florida generates more then 800 million
dollars worth of commercial fish caught annually. Florida also has more
then \$5.6 billion in annual recreational fishing expenditures.

In a Norwegian study conducted in the central Barents Sea, seismic
shooting severely affected fish distribution, local abundance, and catch
rates over a large geographic area. In this study, catch of cod and
haddock fell precipitously within a 38-nautical-mile by 38-nautical-mile
area, and remained depressed for at least five days following the
conclusion of seismic survey activities.[^23]

In addition, the Canadian T. Buck Suzuki Environmental Foundation and
the United Fishermen and Allied Workers Union -- CAW recently weighed in
on the Canadian Statement of Practice on the Mitigation of Seismic
noise, citing their concern for the B.C. marine-based industries, which
employ over 20,000 and contribute over \$2 billion in revenues and
\$600,000 in total GDP. These groups point to mortalities in fish eggs,
fish and shellfish larvae, and adult fish with swim bladders; trawl
catch declines from 50 to 70 percent and long line catch declines by 44
percent for 5 days after cessation of seismic shooting; and the
particular concern about seismic activity during salmon migration or
herring spawning. Salmon are of particular concern because of the
endangered status of some populations off the Atlantic and Pacific
coasts, and because of their apparent inability to detect and avoid
low-frequency sound until damaging levels are reached.

**2. More offshore oil and gas drilling will NOT solve our energy
problems**

The natural gas and oil estimated to be recoverable in the eastern Gulf
of Mexico will not solve our energy problems. According to the Minerals
Management Service, offshore areas opened by S.3711 will supply only 25
days of oil and 35 days of natural gas over the next 60 years at 2004
consumption rates. The new area, also referred to as lease sale 182, is
in very deep water and contains relatively small amounts of oil and
natural gas, about 525 million barrels of oil and 2.2 trillion cubic
feet of gas, according to MMS.

The same is true for oil and gas in areas in the eastern Gulf of Mexico
outside of Lease Sale 182. There is an estimated 930 million barrels of
oil in the entire eastern Gulf of Mexico, which breaks down to
approximately 47 days worth of oil when you consider that Americans use
about 21 million barrels of oil a day. Obviously, that is not enough oil
to impact the price of a gallon of gas or solve our energy problems.

Drilling anywhere on the Outer Continental Shelf will not solve the
problem of high natural gas prices either. It simply takes too long to
develop a natural gas field to impact prices in the short term (1-3
years). Natural gas from areas currently off limits to drilling will not
reduce prices in the long term either, since there is not enough gas
there compared to either annual U.S. production or consumption.

A Department of Energy, Energy Information Administration study done in
2001, *U.S. Natural Gas Markets: Mid-Term Prospects for Natural Gas
Supply*, SR/OIAF/2001-06, compared the price of natural gas with the OCS
moratoria areas kept out of production and the price of natural gas with
all of the moratoria areas opened for drilling in the 2007-2012 MMS 5
Year Plan.

With all of its supply and demand information, DOE's National Energy
Model Modeling System (NEMS) predicted that the price of natural gas
would be \$3.26 per thousand cubic feet in 2020 without the gas under
moratorium and \$3.22 per thousand, or four (4) cents less with access
to the additional gas in moratoria areas. This is a predicted price drop
of a 1.2 percent from the addition of 10 times more gas reserves than
would be freed up under this bill.

This is hardly major or even significant price relief. The effect is of
such a magnitude that it would probably be drowned out by the
marketplace or normal fluctuations, or by catastrophic events we have no
control over like the impact of a Hurricane Katrina. Catastrophic events
that effect production or distribution assets clearly have the ability
to move prices much more than a mere addition of 5 TCF of technically
recoverable resources.

**3. Most off shore oil and gas reserves are already available**

The vast majority -- 80 percent -- of the nation's undiscovered
technically recoverable OCS gas is located in areas that are already
open to drilling, according to the Department of the Interior's 2006
[Report to Congress: Comprehensive Inventory of U.S. OCS Oil and Natural
Gas Resources]{.underline}. There are estimated to be 86 TCF of
Undiscovered Technically Recoverable Resources (UTRR Mean Estimate) in
all OCS areas withdrawn from leasing compared to 479 TCF of Reserves,
Reserve Appreciation and UTRR in the total OCS of the U.S. Therefore,
all the potential gas placed off limits to drilling at present
constitutes less than 20 percent of the gas thought to exist in the OCS.

Furthermore, according to the 2003 Energy Policy and Conservation Act
(EPCA) report issued by the Department of the Interior, 85 percent of
federal onshore oil resources and 88 percent of federal onshore natural
gas resources (122.6 trillion cubic feet, or tcf) occurring on federal
lands in Montana, Colorado, New Mexico, Utah and Wyoming are already
available for leasing and development. Only 12 percent of federal
onshore natural gas resources are off-limits to leasing.[^24]

Thus, permanent protection for the coastal moratorium areas will leave
the vast majority of the nation\'s OCS gas available to the industry.

In addition to availability for leasing, Bureau of Land Management (BLM)
data indicates that the vast majority of federal lands currently under
lease are not being developed. Of the more than 35,000,000 acres of
public lands under lease, development is occurring or has occurred on
approximately 12,000,000 acres.[^25] Drilling permit approvals on
Western public lands by the BLM increased by 62 percent in 2004, to a
record number of 6,052, while the number of new wells that were drilled
declined by nearly 10 percent, to 2,702.[^26]

Based on this data, it is clear that the vast majority of federal oil
and gas resources occurring on federal lands and waters are available
for development. The oil and gas industry clearly has plenty of access
to our public lands already; there is no reason to grant access to
additional areas currently under moratorium for additional leasing.

**4. There are smarter, cheaper, and faster solutions for rising
gasoline and natural gas prices**

America's coasts and marine waters provide the economic lifeblood for
tourism and fishing communities, a destination for thousands of
vacationing families each year, and sanctuary for fish and wildlife.
Offshore drilling would industrialize our coasts and put our coastal
communities and economies at risk.

Sacrificing America\'s shoreline is not what will bring down --- and
keep down --- energy prices. The United States has about 5 percent of
the world's population but consumes about 25 percent of the world's
energy. Instead of drilling off out coasts, which will only add to the
billions in profits already being made by Big Oil, Congress should raise
the fuel economy of our cars, encouraging the use of renewable energy
like wind and solar power, and adopting other, existing energy-saving
technologies that cut pollution, curb global warming and create good
jobs.

For example, if our cars, trucks and SUVs together averaged 40 miles per
gallon --- something that is achievable with existing technology --- we
would save as much oil as the United States currently imports from the
Persian Gulf, with another million barrels to spare. And the average
driver would save nearly \$600 a year at the pump[^27]. A single modern
turbine can produce enough power to meet the annual electricity needs of
500 average homes.[^28]

There are other examples of clean energy solutions and alternatives to
off shore oil and gas drilling. Many states have adopted renewable
energy standards. By 2017, the renewable energy standards already
enacted by states such as New Mexico, California and Texas will produce
as much renewable energy as would be produced by gas fired power plants
using 0.6 TCF of gas per year. That is twice as much gas annually than
the amount of oil and gas thought to be in the area covered by the
original Lease Sale 181.

By simply making our homes, offices, cars and trucks more efficient we
will save energy and money today and far into the future. Instead of
relying on volatile and expensive sources of oil and gas, we can use
better technology to reduce our energy demand while producing more
energy from renewable sources of energy like wind and solar power. These
cheaper, cleaner and faster policies reduce short-term demand and costs
while also providing long-term solutions to our energy needs. And it
does not require you to put your favorite vacation spot on the chopping
block.

**Conclusion**

The Sierra Club strongly opposes efforts to open areas currently off
limits to off shore oil and gas drilling. Off shore oil and gas drilling
is a dirty business, one incompatible with America's coastal ecosystems
and economies.

We feel that the oil and natural gas thought to be in these areas will
make, at best, a very marginal difference in the supply or price of gas
in the future. Any oil and gas found would not be available any time
soon and therefore would not address immediate concerns regarding prices
or supply.

We suggest that a better way to address these concerns is to promote
energy efficiency and renewable energy programs. For instance, it
typically takes seven to ten years to bring an oil or gas field on line.
But it only takes one year to build a 50-megawatt wind farm that can
produce 50 megawatts of clean, renewable electricity.

Finally, we do not believe that the beaches, coastal environment, marine
resources, and billion-dollar tourism industry of the eastern Gulf of
Mexico should be sacrificed for a small amount of oil and natural gas,
especially when efficiency and renewable energy solutions to our energy
problems are available right now.

We strongly feel that it is time to begin to wean America off of fossil
fuels, and in their stead promote energy efficiency programs such as
increased fuel economy for our cars, trucks and SUVS, and to promote
renewable energy such as wind, solar and other clean energy sources.

Once again, thank you for the opportunity to testify before this
committee.

[^1]: Deepwater Gulf of Mexico Environmental and Socioeconomic Data
    Search and Literature

    > Synthesis. Volume I: Narrative Report. 2000. Minerals Management
    > Service.

[^2]: Interactions Between Migrating Birds and Offshore Oil and Gas
    Platforms in the Northern Gulf

    > of Mexico. Final Report. 2005. Minerals Management Service.

[^3]: Boesch and Rabalais, eds., "The Long-term Effects of Offshore Oil
    and Gas Development: An Assessment and a Research Strategy." A
    Report to NOAA, National Marine Pollution Program Office at 13-11.

[^4]: MMS, 2000. Gulf of Mexico OCS Oil and Gas Lease Sale 181, Draft
    Environmental Impact Statement (DEIS), p. IV-50.

[^5]: *Id.*

[^6]: *Id*., p. IV-32.

[^7]: *Id.,* p. IV-32-33.

[^8]: *Id*., p. IV-40.

[^9]: Congressional Research Service, Report RS20050, "Methane Hydrates:
    Energy Prospect or Natural Hazard?" James E. Mielke. February 14,
    2000

[^10]: MMS, 2000. Gulf of Mexico OCS Oil and Gas Lease Sale 181, Draft
    Environmental Impact Statement (DEIS), pp. IV-50.

[^11]: U.S. Minerals Management Service. Estimated Petroleum Spillage
    from Facilities Associated with

    Federal Outer Continental Shelf (OCS) Oil and Gas Activities
    Resulting from Damages Caused by Hurricanes Rita and Katrina in
    2005. 8 August 2006.

[^12]: U.S. Minerals Management Service. News Release. MMS Updates
    Hurricanes Katrina and Rita Damage. 1 May 2006.

[^13]: NMFS, NOAA Fisheries Status Report: Preliminary Findings on the
    Stranding of Beaked Whales in the Bahamas (June 14, 2000); NMFS,
    NOAA Fisheries Status Report; NMFS, NOAA Fisheries Status Report on
    the One Year Anniversary of the Stranding of Beaked Whales in the
    Bahamas (Mar. 26, 2001).

[^14]: McCauley.R.D., J. Fewtrell and A.N. Popper, 2003. "High intensity
    anthropogenic sound damages fish ears." J.Acoust.Coc.Am. 113,
    January 2003.

[^15]: Id.

[^16]: Long, D.T., W.E. Cooper, W.B. Harrison III, R.H. Olsen, B.J.
    Premo and K.G. Harrison. 1997. *Evaluation of Directional Drilling
    under the Great Lakes,* October 1997. Michigan Environmental Science
    Board, Lansing, Michigan.

[^17]: Houston, James R. (2002). The Economics Value of Beaches. U.S.
    Army Engineer Research and Development Center.

[^18]: World Travel and Tourism Council. (2001). Year 2001, World,
    United States, TSA Research Summary and Highlights.
    www.wttc.org/ecres/pdfs/a111/pdf

[^19]: U.S. Travel and Tourism (1993). World Tourism at the Millennium.
    U.S. Department of Commerce.

[^20]: Marlowe, Howard. Assessing the Economic Benefits of America's
    Coastal Regions. Trends and Future Challenges for U.S. National
    Ocean and Coastal Policy.

[^21]: Murley, James, Lenore Alpert, William Stronge. (2005). Tourism in
    Paradise: The Economic Impact of Florida Beaches. 14^th^ annual
    Biennial Coastal Zone Conference.

[^22]: Strong, W.B. (1994) Beaches, tourism and economic development.
    Journal of the American Shore and Beach Preservation Association.
    62(2).

[^23]: Engas, Arill, Svein Lokkeborg, Egil Ona, and A.V. Soldal.
    Institute of Marine Research, 1996. Effects of Seismic Shooting on
    Local Abundance and Catch Rates of Cod (Gadus morhua) and Haddc
    (Melanogrammus aeglefinus). Can. J. Fish. Aquat. Sci. 53: 2238-2249.

[^24]: BLM, "EPCA Inventory Fact Sheet," 1/15/03, p. 3

[^25]: BLM, "Total Number of Acres Leased" (unpublished table, January
    31, 2005) and BLM, "Number of Producible Acres on Federal Lands"
    (unpublished table, January 31, 2005)

[^26]: BLM, "Number of APDs approved by Year on Federal Lands"
    (unpublished table, January 31, 2005) and BLM, "Number of Well Spud
    During the Year on Federal Lands" (unpublished table, January 31,
    2005)

[^27]: Freidman, David, et al. "Drilling in Detroit: Tapping Automaker
    Ingenuity to Build Safe and Efficient Cars." Union of Concerned
    Scientists. June 2001. p. 41.

[^28]: American Wind Energy Association --
    http://www.awea.org/pubs/documents/FAQ2002percent20-percent20web.PDF.