Petrobras America Inc. Page 2-1

Development Operations Coordination Document Cascade / Chinook Development Project 

## 2 General Information

2(a) Applications and Permits No individual or site specific applications or permits will be required for Phase II of the development plan beyond those required by 30 CFR 250 (e.g. Surface Safety Application, Application to Drill and Application to Modify). Per NTL 2008 G04, coverage under the National Pollutant Discharge Elimination System (NPDES) General Permit or Corps of Engineers (COE) permits are not described in this section.



### 2(b) Drilling Fluids Phase II of the development plan includes drilling and completing at least five new wells. Two wells are here proposed for the Cascade Unit and three wells have been proposed under separate cover (SDOCD) for the Chinook Unit. Appendix 7-A shows the types and amounts of drilling fluids that would be used to drill the two wells described in this SDOCD.



### 2(c) Production [Proprietary]

2(d) Oils Characteristics Table 2-2 describes the chemical and physical characteristics of the produced oil from the Cascade and Chinook reservoirs. The analytical methodology is compatible with the requirements of NTL 2008-G04 and the nomenclature and unit measurements reported below are consistent with ASTM measurement standards and protocol. The information included in Table 2-2 represents the chemical and physical characteristics of oil that could be spilled in the largest volume spill during Phase II of the development plan.2 General Information

Page 2-2 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Table 2-2 – Oils Characteristics

Area / Block WR Block 250 WR Block 425

BOEM Platform ID # N/A N/A

Field / Unit Cascade Unit 206 Chinook Unit 425
Sample Date (1) (2)
Sample # (1) (2)

Well # WR206#1, WR206#1bp1, WR206#2, WR250#2ST1 WR469#1
Storage Tank ID # N/A N/A

Gravity (API) 17 - 26 22 - 29
Flash Point (  C) Unknown Unknown

Pour Point (  C) -16 to -24 -6 to -12
Dynamic Viscosity (Centipoise at 16  C) 29 – 600 63 – 132
Dynamic Viscosity (Centipoise at 38  C) 18 – 221 1 -2
Wax Content (wt %) 1.7 – 4.1 2.8 - 4.9
Asphaltene Content (wt %) 4.7 – 22.2 5.1 – 12.6
Resin Content (wt %) 20.4 – 36.1 15.3 – 25.8
Sulphur (wt %) 3.5 3.5

(1) 184 samples from April 15, 2002 to June 17, 2009 [information above is representative]


### 2(e) New or Unusual Technology No new technology is proposed in this supplement however; the Conceptual Plan and the Initial DOCD, both previously approved by the BOEM identified six components of the phased Cascade / Chinook development plan that are considered technologies new to the GoM. These six components were addressed extensively in the Initial DOCD as well as the DWOP. BOEM Technical Assessment and Operations Support (TAOS) Section reviewed and approved the safety and reliability of the technologies new to the GoM in the approved DWOP (ref. Appendix 1a). There are no significant changes to the information previously submitted regarding new or unusual technologies and the information remains accurate and consistent. The most important safety and pollution prevention features that will be used to mitigate hazards related to technologies new to the GoM are described in Section 1(f).2 General Information

Petrobras America Inc. Page 2-3 Development Operations Coordination Document Cascade / Chinook Development Project 

### 2(f) Bonding Statement The bond requirements for the activities and facilities proposed in this DOCD are satisfied by an area wide bond and supplemental bonding furnished and maintained in accordance with 30 CFR Part 256, Subpart and NTL 2000 G16 “Guidelines for General Lease Surety Bonds,” and NTL 2003 N06 “Supplemental Bond Procedures.” 

### 2(g) Oil Spill Financial Responsibility PAI (Operator #1207) has demonstrated oil spill financial responsibility for the facilities proposed in this SDOCD in accordance with 30 CFR Part 253 and NTL 99 N01 “Guidelines for Oil Spill Financial Responsibility for Covered Facilities.” 

### 2(h) Deepwater Well Control Statement PAI (Operator #1207) has the financial capability to drill a relief well and conduct other emergency well control operations. 

### 2(i) Suspension of Production In accordance with the PAI’s latest SOP, which was approved by BOEM letter dated 28 September 2011, PAI has committed to begin producing the Cascade Unit by December 2011. The SOP activity schedules are included in Appendix 1. 

### 2(j) Blowout Scenario Well Control during drilling and completion relies on a number of interrelated processes and procedures. The drilling or completion fluid provide Primary Well Control during operations with the fluid density providing hydrostatic pressure on the wellbore which exceeds the pore pressures within the drilled or open hole formations. This overbalance prevents fluid flow from the pore space in the formation to flow into the wellbore. Subsea-mounted Blowout Prevention Equipment (BOPE), will provide Secondary Well Control during drilling or completion operations. In the event that primary well control is lost, the BOPE will contain the influx of formation fluid and then allow safe circulation of the influx out of the wellbore. Generally speaking, the Cascade and Chinook wells are considered Development wells and should have less unknowns and risk when compared to Exploration wells. Measures to Enhance the Ability to Prevent a Blowout Well Control Training: PAI requires certified well control training for drilling supervisors, operations superintendents, drilling engineers, and the drilling contractor requires training for tool pushers, drillers & assistant drillers, floor hands, and other appropriate personnel through an operations training program with a professional organization and in accordance with BSEE/BOEM requirements. The curriculum consists of training in blowout prevention technology and well control. Successful completion results in participant certification.2 General Information

Page 2-4 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Well Control Monitoring and Procedures: Automatic and manual monitoring equipment is installed to detect abnormal variation in the mud system volumes and drilling parameters. If an influx of formation fluid into the wellbore occurs, the BOPE will be used to immediately shut-in the well. Each well will be drilled according to a location specific pore pressure profile anddetailed safe mud weight envelope. Too low of a mud weight could result in an underbalance in the well, and an influx of formation fluids. Conversely, too high of a mud weight may result in lost circulation to a weak formation, which could lead to a drop in fluid level (total hydrostatic column) resulting in an under-balanced condition. The mud weight envelope is designed to provide the proper balance for well control for the formation and pore pressure encountered. In case an uncontrolled influx of formation fluid (water or hydrocarbon), or “Kick” does occur, Secondary Well Control methods will be employed, i.e., the kick is quickly detected, the pumps are turned off, the annulus will be shut in using the annular, the drill pipe positioned relative to the annular, and the annulus isolated. The internal barrier in the Drill Pipe is a downhole check valve near the bit and a surface-mounted valve. These barriers will contain the influx and any associated build-up of surface pressure. It will also prevent further influx of formation fluid into the wellbore.
Measures to Reduce the Likelihood of a Blowout To kill an influx, surface pressures will be allowed to stabilize and then the SIDP (Shut In Drill Pipe) and SICP (Shut In Casing Pressure) are measured. These pressures will enable the calculation of the new kill-weight mud density needed to regain primary well control. A standard well-kill procedure will be implemented to circulate the kill-weight mud and safely remove formation fluids from the hole. Mud-gas separators and degassers will be used to safely remove gas from the mud as it is circulated out of the hole. After this procedure is completed, the kill effectiveness will be confirmed and the well will be circulated around, the BOPE opened up and the fluid levels monitored. Drilling operations will resume when the well has been brought under control and a static condition exists. Measures to Enhance the ability to Conduct Effective and Early Intervention in the Event of a Blowout Well Control drills/exercises are an integral part of the rig teams training and will be performed on a frequent basis to ensure the human element is prepared, and the well can be shut in quickly and properly. Certified training of Gulf of Mexico personnel will include hands-on simulator practice at recognizing kicks, well shut-in, and circulating the kicks out of the wellbore. Well specific shut-in procedures will be posted on the rig. In the unlikely event of a “kick” or loss of well control event, surface intervention, defined as the normal well control methods which include wellbore fluid control or overbalance, diverter and BOP operations to shut-in the well from the surface will be the primary response.2 General Information

Petrobras America Inc. Page 2-5 Development Operations Coordination Document Cascade / Chinook Development Project Should surface intervention prove unsuccessful, PAI has evaluated two additional potential scenarios to kill a blowout; seafloor intervention and a relief well. This would involve subsea intervention in the form of; ROV control of the BOP stack via hot stabs, a shut off device mounted on the BOP stack or LMRP, or diverting flow to a surface vessel.
WCD and the Blowout Scenario The Initial DOCD provided for two worst case discharge (WCD) scenarios identified for Phase 1 of the development plan. The scenarios assumed the mechanical barriers to flow to have failed, which would allow the well to flow uncontrolled at the sea floor. In both cases, the ability to intervene before this occurrence is valid assuming that the subsea wellhead connector profile remains undamaged. A blowout preventer stack or isolation assembly could be positioned and latched on the profile and the well brought under control. This operation would take 3-10 days, excluding the time required to mobilize the rig. The chances of a well bridging over in this scenario would be reasonably likely in anexploration well, although the compressive strengths of the Wilcox group (EocenePaleocene), a prolific hydrocarbon producing sediment, make it more difficult. The chances of a well bridging over in a completed well are very unlikely. In light of the tragedy surrounding the Macondo incident of April 2010 and in accordance with NTL N06, PAI has reevaluated the blowout scenario for an exploratory / development / drilling operation in the Cascade Unit. In summary, according to the instructions and direction of NTL N06 the PAI calculations and concurrence for the WCD flow rates for the field result in rate of 18,135 barrels of oil per day (BOPD) for Cascade (see Table 2-3). The main factors controlling these rates include reservoir permeability, net pay thickness and oil viscosity. This information is described in detail in Section 9 – Oil Spill Information. The values chosen for all the input parameters are conservative (conservative in the sense of maximizing rate) estimates based on available data gathered from drilling, cores, and detailed petrophysical analysis of wells drilled and completed in these fields.2 General Information

Page 2-6 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Table 2-3 – Worst Case Discharge Scenario

In the event of a blowout, a total of 110-days may be necessary to secure a rig, mobilize to the location, drill the relief well and kill the blowout well. Utilizing the maximum discharge calculation from BOEM, the calculated Total Volume in barrels of a spill lasting 110 days is: 18,135 bbls / day X 110 day = 1,994,850 total bbls. PAI has the capability to respond, to the maximum extent practicable, to a worst-case discharge, or a substantial threat of such a discharge, resulting from the activities proposed in the DOCD. Category OSRP WCDS Drilling DOCDWCDS

Drilling OSRP WCDS

Production DOCD WCDS

Production

Type of Activity Drilling Drilling Subsea Production Subsea

Production

Facility Location(s) WR 206
OCS-G 16965 WR 206

OCS-G 16965 GB Block 244

OCS-G 15860 WR 206

OCS-G 16965

Facility Designation Subsea Well
Cascade #5 Subsea Well

Cascade #5 Subsea Well

Cottonwood #2 Subsea Well

Cascade #5

Distance to Nearest Shoreline (Miles) 165 165 134 165

Volume (barrels) : Storage Tanks (total) 0 0 0 0 On-facility Flowlines 0 0 0 0 Lease Term Pipelines 0 0 0 0

Uncontrolled Blowout (volume per day) 18,135 18,135 18,000 16,281
Total Volume 18,135 18,135 18,000 16,281
Type of Oil (e.g. Crude, Condensate, Diesel) Crude Crude Crude Crude

API Gravity 23 23 32 232 General Information

Petrobras America Inc. Page 2-7 Development Operations Coordination Document Cascade / Chinook Development Project PAI will work with specific partners and industry to develop rig-sharing agreements to allow faster mobilization in the event of an emergency. In the event a relief well is required, a deepwater rig currently located in the GOM would be contracted to drill the relief well. As of July 2011, there are approximately 20 rigs in the GOM capable of drilling a Cascade or Chinook relief well. The rig must be capable of drilling to a depth of ~29,000 feet in a water depth of 9,000 feet. This Rig will be a Rig of no constraints. There are no platforms or other structures in the vicinity for drilling a relief well. PAI expects to have a 2-rig operation by 2012, Phase II operations, with a rig operating in each field. 

### 2(k) Chemical Products Per NTL 2008 G04, information regarding chemical products is not required for DOCDs submitted of the BOEM GoM region.2 General Information

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Development Operations Coordination Document Cascade / Chinook Development Project 

## 3 Geological and Geophysical (G&G) Information

3(a) Geological Description [PROPRIETARY]

3(b) Structure Maps [PROPRIETARY]

3(c) Interpreted 2-Dimensional and or 3-Dimensional Seismic Lines [PROPRIETARY]

3(d) Geologic Structural Cross-Sections [PROPRIETARY]

3(e) Shallow Hazards Reports [PROPRIETARY]

3(f) Shallow Hazards Assessment [PROPRIETARY]

3(g) High-Resolution Seismic Lines [PROPRIETARY]

3(h) Stratigraphic Column Per NTL 2008-G04, biostratigraphic / lithostratigraphic column information is not required for DOCDs. 

### 3(i) Time vs. Depth Tables Per NTL 2008-G04, this information is required only for Exploration Plans where there is no well control. As a result, this information is not provided in this DOCD. 

### 3(j) Geochemical Information Per NTL 2008-G04, geochemical information is not required for DOCDs submitted in the BOEM GoM region. 

### 3(k) Future G&G Activities Per NTL 2008-G04, information related to future geological and geophysical activities is not required to be included in DOCDs submitted to the BOEM GoM region.3 Geological and Geophysical (G&G) Information

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Development Operations Coordination Document Cascade / Chinook Development Project 

## 4 Hydrogen Sulfide (H 2 

## S) Information
4(a) Concentration Samples from the Cascade and Chinook Units indicate that the estimated concentration of H 2 S is approximately 0.6 parts per million by volume (ppmv). Simulations indicate a maximum H 2 S concentration of 10.3 ppmv at arrival conditions. The pressure-volumetemperature analyses performed did not show any presence of H 2 S.



### 4(b) Classification [PROPRIETARY]

In accordance with Title 30 CFR 250.490(c), PAI respectfully requests that Walker Ridge Blocks 206 and 250 be classified by the BOEM as an area where the absence of H 2 S has been confirmed.



### 4(c) H 2 

### S Contingency Plan

A H 2 S contingency plan is not necessary.



### 4(d) Modeling Report

A H 2 S contingency plan is not necessary.4 Hydrogen Sulfide (H 2 S) Information

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Development Operations Coordination Document Cascade / Chinook Development Project 

## 5 Mineral Resource Conservation Information
5(a) Technology and Reservoir Engineering Practices / Procedures Due to the water depth, wellbore depth, and low bubble point of the production fluids, the hydrostatic pressure losses in the system are expected to be significant. Therefore, some form of artificial lift is required to enhance the production flow rates. PAI has decided to utilize subsea booster pumps during the development for enhancement of production flow rates. Other artificial lift options either do not meet field life boosting requirements (e.g. gas lift) or they are not sufficiently proven or practical for high subsea flow rates. Although subsea booster pumps may not be needed in the early stages of Phase I and Phase II of the development plan, the boosting system will be used to test various scenarios on the boosting pump operating curve as well as to assure that production rates remain high enough to avoid flow assurance issues (hydrate formation / wax deposition). PAI will be utilizing electrical submersible pumps (ESP) mounted in a frame on the seafloor for boosting. ESP’s have a proven track record in the industry when installed in wellbores. Installation of ESP’s on the seafloor is considered technology new to the GoM by BOEM and the ultra deepwater industry. Since there is indication of a large aquifer in both the Cascade and Chinook fields, the base scenario assumes water influx as the primary recovery drive for long term reservoir planning. During early production, the reservoir performance will be monitored to evaluate the degree of pressure maintenance and the aquifer's strength. Depending on the observed results, the recovery mechanism for the future phases will be selected. At this time, PAI considers water injection (if needed) to likely be the best alternative among the options for enhanced recovery methods for future phases of the development plan. Recovery methods to be utilized in future phases of the development plan will be further defined in a Supplemental DOCD. 

### 5(b) Technology and Recovery Practices / Procedures and Reservoir Information Drilling and Completion The Cascade discovery well WR Block 206 #1 spudded on January 31, 2002 and reached total depth of 26,710 feet on April 14, 2002. The Chinook discovery well WR Block 469 #1 spudded on January 13, 2003 and reached total depth of 26,652 feet on June 19, 2003. The Cascade and Chinook Project was sanctioned in 2006 and included Phased development with 3-Phases. Phase I of the development plan includes the drilling and completion of three new wells. Phase II will be full development of the drill centers & manifolds, and Phase III will likely include new topsides, additional wells and potential water injectors.5. Mineral Resource Conservation Information

Page 5-2 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Two of the wells in Phase I have already been drilled and completed: one well in the Cascade East drill center (Walker Ridge 250, Well No. CA 003, OCS G-16970), and one well in the Chinook Drill Center (Walker Ridge 469, Well No. CH 002, OCS G-16997). This supplement covers the first two wells of Phase II in the Cascade Drill Center in WR 206 Wells No. 6 and 7. These two wells will be drilled and completed applying standard GoM best practices and technologies. The objective of Phase II is to delineate the reservoir, add production, and continue to gather sufficient information about the well productivity to optimize future completions and development, including:

 Number and type of wells

 Completion design

 Production system capacity and type

 Subsea layout and boosting system

 Secondary recovery assessment

Figure 5-1 illustrates the casing program being utilized in Phase II of the development program.5. Mineral Resource Conservation Information

Petrobras America Inc. Page 5-3 Development Operations Coordination Document Cascade / Chinook Development Project Figure 5-1 – Casing Program

DEPTH (RT) HOLE SIZE CASING MW/PP/FG/FIT
FMC UWD-15K-LB 18-3/4" Wellhead top @ 8,215' MD,TVD

36" Housing @ 40° F

JET 36" X 2.0", X-60, RL-2HCX JET 36" X 1.50", X-56, RL-2HCX 36" X 1.0", X-56, RL-4F 8.6 PP 36" @ 8,553

0' MD/TVD (322' BML) 42° F 8.6 FG Cement circulated to mudline

22", 1.0" wall, X-80, RL4S RISERLESS 10 3/4" x 10 1/8" XO @ 11,300' 26" 8,215' - 11,552' MD SW / WBM 16" TOL @ 11,173' MD,TVD 22", 0.75" wall, X-60, RL4S 18" Landing Sub @ 11,506' MD,TVD 11,552' - 11,995' MD 8.6 PP

20" @ 11,995' 22" @11,992' MD/TVD (3,764' BML) 90° F 10.7 FG

18 1/8" x 19-1/2" 16", 96 ppf, HCQ-125 H511 weight up to

9.9 ppg SBM 16" TOC @ 20,764' MD

9.7 PP 16" @ 21,764' MD, 21,510' TVD 198 °F 13.6 FG Drill Depth 22,000' MD 13.2 FIT

TOC @ 23,250' MD for Production Tieback

13 5/8" TOC @ 23,766' MD Hold Inclination and Azimuth to 23.6° @ 162.5° Drill out with 11.2 ppg SBM HCQ - 125 H 523 weight up to Wireline: GR / Resistivity / Density/ Neutron / Sonic 10,200' - 24,766' MD 12.6

10 1/8" TOL @ 24,250' MD / 23,782' TVD 12.0 PP 14" x 13 5/8" @ 24,766' MD, 24254' TVD 234°F 15.4 FG

Drill Depth 24,900' MD MWD: GR/Res/Sonic/PWD/Neu/Den 10-3/4" 79.2 ppf

TOC @ 25,174' MD for 10 1/8" Liner 12-1/4" HCQ-125 VAM HP MW Hold Inclination and Azimuth to 23.6° @ 162.5° 8215' - 11,300' MD 14.5 -14.7 ppg Earth Imager / 3DEX / XMAC / FLEX / SL 10-1/8" 79.2 ppf HILD / MREX / ZDL / CN HCQ-125 VAM SLIJ-II RCI (pressures and fluids) 11,300' - 27,211' MD 14.5 PP Rotary SWC 10 1/8" Prod liner run and cemented @ TD ZVSP / Checkshot 27,211' MD / 26,493' TVD 252 °F 10 3/4" x 10 1/8" Tieback run and cemented prior to completion 16.1 FG Wireline Success Case:

MUDLOG MUDLOG MWD: GR/Res/PWD

MUDLOG MWD: GR/Res/PWD LOGS

8,218' MD,TVD

22" x 4' Hunting burst disk sub at 11,087' MD (6,092 psi burst)

16" x 4' Hunting collapse disk subs at approximately 11,200' and 13,500' MDMD/TVD (7,000 psi minimum back pressure, 2200 psi collapse 16" x 22" annulus} OH TD @12,043' MD (3,815' BML)

Start directional Rev I.2 17,259' MD, TVD BUR 1.5°/100' Build to 23.6° inclination and 162.5° Azimuth.

13-5/8", 88.2 ppf 14", 113 ppf HCQ -125 H 523 8215' - 10,200' MD

14-3/4"x16 1/2" MWD: GR/Res/Sonic/PWD MWD: GR/Res/Sonic/PWD

Wireline: GR / Resistivity / Density/ Neutron / Sonic5. Mineral Resource Conservation Information

Page 5-4 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Given the challenging reservoir characteristics of low permeability (between 5-100md) and low gravity oil (around 20° API), the completion of the wells must include reservoir (near wellbore) stimulation techniques. The stimulation design must incorporate hydraulic fracturing to improve conductivity and improve flow rates. Due to uncertainties regarding the sand production potential and in order to achieve greater levels of depletion prior to final abandonment, a fit-for-purpose Sand Control Frac-Pack completion is the preferred choice in Phase II. To address the geological andlithological challenges presented by the need for both stimulation and sand control, fracpacks with several stages in each well will be used to effectively stimulate the wells. A Single-Trip Multi-Zone Frac Pack system is currently the completion design for the lower completion of Cascade & Chinook development wells. This technology is being developed by PAI and its vendors to reduce the complexity and cost of the completion when compared to stack-frac completion systems. See Figure 5-2 for a conceptual representation of a completion schematic for the downhole completion (upper and lower).

The Cascade and Chinook reservoir depletion mechanisms and zonal contribution are not yet fully understood. To understand this more a downhole remote flow control and monitoring system (“intelligent completion” - IC) is being developed for the upper completion in Phase II wells. The IC provides the ability to select or isolate intervals producing in order establish a relative contribution from each zone. The system will also aid in monitoring and control, isolation of water influx, minimizing cross-flow among intervals, and managing real-time reservoir data. All intelligent completion hardware will be installed above the sand face, providing reservoir and production management capabilities from two “intervals”, regardless of the number of frac-pack intervals completed in the lower completion.5. Mineral Resource Conservation Information

Petrobras America Inc. Page 5-5 Development Operations Coordination Document Cascade / Chinook Development Project Figure 5-2 – Completion Schematic

RKB (West Sirius): 85.5' WATER DEPTH: 8143' ML (RKB est.): 8228.5' WH (HP HSG) ELEVATION: 8219'

TH ELEVATION: 8211' Prepared by: OM/ZH 05/27/2010

CASING MD (top) ID OD COMPLETION CONNECTION MAT-GRADE 8,211 ft 4.674 in n/a TBG HANGER (w/ 9 penetrations) 5-1/2" 26# Box down F6NM 80ksi 4960 psi 8,239 ft SAVER SUB ASSY 5-1/2" 26# Pin x Pin 13Cr HP1 110ksi 8,260 ft 4.548 in 6.075 in X-OVER SUB 5-1/2" 26# VamTop Box x Super 13Cr 110ksi 4-1/2" 15.1# VamTop Pin 8,267 ft 3.826 in 7.750 in ECCENTRIC BUMPER SUB (NOT SHOWN) 4-1/2" 15.1# VamTop Super 13Cr 110ksi (T&C) 10-1/8" x 10-3/4" 79.22# HCQ-125 tieback to wellhead FLAT PACK #1 ( SCSSV ) - 2ea. 1/4"x.065"wt INC825 FLAT PACK #2 ( DHCI and DHMS ) - 2ea. 3/8"x.065"wt and 1ea. 1/4"x.049"wt (TEC) INC825 11,236 ft 3.688 in 7.560 in 4-1/2" 15Kpsi DHSV (N 2 charged) w/ 3.688" ID Sealbore 4-1/2" 15.1# Box x Pin Super 13Cr 110ksi (7.560"OD/3.688"ID)

11,254 ft 3.826 in 7.750 in ECCENTRIC BUMPER SUB (NOT SHOWN) 4-1/2" 15.1# VamTop Super 13Cr 110ksi (T&C) 36" x 2", 1.5" & 1" wt X-56 RL-4S 8,550' MD
22" x 4' Hunting burst disk sub @ 11,117' (6,092psi) FLATPACK PROTECTION CLAMP compatible with Cast steel 16" FMC submudline hanger @ 11,243' MD (NOT SHOWN) 4-1/2 VamTop 16" x 4' Hunting collapse disk sub @ 11,307' (2,200psi) 18" FMC submudline hanger @ 11,534' MD 22" 1.00" wt 224# & .75" wt 170# X-80 RL-4S 11,993' MD

16" x 4' Hunting collapse disk sub @ 13,500' (2,200psi)

16" 95# HCQ-125 Hydril 511 20,446' MD 4-1/2" 15.1# VamTop PRODUCTION STRING 4-1/2" 15.1# VamTop 13Cr HP1 110ksi 3.826" ID (T&C)

10-3/4" x 10-1/8" X-over sub 21,949'MD/21,942'TVD

21,701 ft 3.688 in 6.287 in 4-1/2 Inj. Mandrel w/ Inj. valve for Scale Inhibitor 4-1/2" 15.1# VamTop PxP Super 13Cr 110ksi (Complete with cplg) 21,709 ft 3.688 in 6.287 in 4-1/2 Inj. Mandrel w/ Inj. valve for Asphaltene Inhibitor 4-1/2" 15.1# VamTop PxP Super 13Cr 110ksi (Complete with cplg)
21,718 ft 3.815 in 6.187 in 4-1/2 Dual Downhole Pressure/Temperature Mandrel 4-1/2" 15.1# VamTop BxP Super 13Cr 110ksi

13400 psi 22,241 ft 3.750 in 8.310 in 9-5/8" x 4-1/2" Retrievable Prod Packer 4-1/2" 15.1# VamTop BxP Super 13Cr 110ksi 22,259 ft 3.562 in 5.000 in 4-1/2" x 3.562 Top No-Go Seating Nipple (lock OD: 3.610") 4-1/2" 15.1# VamTop BxP Super 13Cr 110ksi 22,267 ft 3.750 in 5.880 in Baker SCT (single Cycle Tool) 4-1/2" 15.1# VamTop BxP Super 13Cr 110ksi 14.7 PPG TOC (tie-back and 13-5/8") 22,670' MD ZnBr

15100 p[si ISOLATION STRING ASSY (Drawn in RED) 22,881 ft 6.000 in 8.420 in 10-1/8" x 6" ID SealBore Ret. Packer 22,887 ft 6.000 in 7.000 in 40ft long x 6"

4.600 in 5.985 in 6" OD Seal Nipple Assy w/ spacers - 10' minimum 22,910 ft Top of Seals are 21' into 40' seal bore assembly. 22,936 ft End of Upper Completion

10-1/8" x 13-5/8" liner hanger 23,148' MD 14.7 PPG 22,990 ft 3.870 in 8.015 in HES FS-1 Fluid Loss Control Device (Ball Valve) 5-1/2" 15.1# VamTop (w/ x-overs) Super 13Cr 110ksi ZnBr 14" 113# HCQ-125 Hydril 523 (2000') x 23,102 ft 3.510 in 5.130 in 4-1/2" x 3.562 Bottom No-Go Seating Nipple 13-5/8" 88.2# HCQ-125 Hydril 523 23,835'MD/23,762'TVD ☼ 17600 psi BJ MST Single-Trip FRAC-PACK ASSY 25,067 ft 8.420" x 6.000" ID XTR Sealbore Ret. Packer

Inner Production String: 2-7/8" PTS-8 Mechanical Tubing 2-7/8" 6.5#/ft PTS-8 Super 13Cr 110ksi

3.220" OD 2.371" ID

☼

25,282 ft ** Premium Screens Assy w/ 1ea. pos A22 prod MSV and 1ea. Pos 2 monitor & production MSV (114 ft Screens) - 2 Production Sleeves at 25,313' & 25,373' 25,379 ft **

25,390 ft 2.371 in 3.750 in 30' - 3.750" Slick Joint 2-7/8" 6.5#/ft PTS-8 Super 13Cr 110ksi
25,397 ft 8.310" x 3.785" ID MST ISO Packer

25,496 ft ** Premium Screens Assy w/ 3ea. pos A33 prod MSVs and 1ea. Pos 2 monitor MSV (214 ft Screens) - 3 Production Sleeves at 25,527', 25,567' & 25,646' 25,691 ft **

25,703 ft 2.371 in 3.750 in 30' - 3.750" Slick Joint 2-7/8" 6.5#/ft PTS-8 Super 13Cr 110ksi ☼ 25,710 ft 8.310" x 3.785" ID MST ISO Packer

25,746 ft 1.710 in 3.668 in 3.22" x 1.71" Top No-Go Seating Nipple (Lock OD: 1.765") 2-7/8" 6.5#/ft PTS-8 25,944 ft ** ☼ Premium Screens Assy w/ 2ea. pos A44 prod MSVs and 1ea. Pos 2 monitor MSV (154 ft Screens) - 2 Production Sleeves at 25,980' & 26,040' 26,080 ft **

26,092 ft Sump Packer

26,120 ft End of MST Assembly ☼ 10-1/8" 79.2# HCQ-125 production liner 27,014' MD/26,800' TVD11.6PPGNaBr Walker Ridge Cascade #4 - East Block (WALKER RIDGE 250 OCS G-16970 WELL NO. 3)

COMPLETION WELLBORE SCHEMATIC - As-Built

(FOR ILLUSTRATION PURPOSE ONLY)**UPPERCOMPLETION

14600 psi c

15900 psiLOWERCOMPLETION(FRAC-PACK)ISOASSEMBLY 40 ft PBR 10 ft Seal nipple

20' long 2-7/8" 6.5#/ft PTS-8 Perf Joint across each production sleeve 20' long 2-7/8" 6.5#/ft PTS-8 Perf Joint across each production sleeve 20' long 2-7/8" 6.5#/ft PTS-8 Perf Joint across each production sleeve

Pos A22 Shifting Collet

Pos A33 Shifting Collet

Pos A44 Shifting Collet

Pos 1 Shifting Collet (close only) ☼ R A T a g s i n 1 0

- 1 / 8 " P r o d L i n e r
- 23,985' MD - 25,206' MD - 25,703' MD - 25,974' MD - 26,336' MD

☼ R A T a g s i n M S T A s s y
- 25,084' MD - 25,241' MD - 25,454' MD - 25,907' MD5. Mineral Resource Conservation Information

Page 5-6 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Flow Assurance The key flow assurance issues for the Cascade and Chinook Fields are driven by unique fluid properties (low bubble point and high viscosity). Flow assurance analysis has established that subsea equipment design, operating, and maintenance procedures would have to include a number of mitigation measures to maximize productivity and reserve recovery. These measures include:

 Subsea boosting of the production stream to provide a significant benefit in terms of recoverable reserves

 Hydrate inhibition through subsea flowline insulation, chemical injection, and operating procedures

 Dual, piggable flowlines will be utilized

 Chemical injection, both downhole and at the wellhead, will be used to mitigate the precipitation of wax and asphaltenes

 Formation of emulsion is anticipated with increased water production in later field life (i.e. post Phase 1); provision is planned for injecting demulsifier at the subsea trees

 Utilize appropriate materials for erosion/corrosion management

 Provision for downhole sand control utilizing frac-pack techniques

 For planned FPSO disconnection scenarios (i.e. named storms which originate outside of the GoM), the FSHRs and flowlines will be depressurized and displaced with diesel for flow assurance mitigation prior to disconnection; methanol will be injected into selected components (e.g. trees, pumps, manifolds) to prevent hydrate formation

 For unplanned FPSO disconnection scenarios (i.e. named storms which originate in the GoM), the FSHRs and flowlines will only be depressurized prior to disconnection with the consequences of hydrate formation being addressed at FPSO re-connection

Reservoir Information [PROPRIETARY] Conservation Information Documents (CID) have been developed, submitted and approved for the Cascade Field and for the Chinook Field. The Cascade CID was approved by BOEM, formerly BOEMRE, on 17 November 2008 and the Chinook CID was approved on 8 May 2009.Petrobras America Inc. Page 6-1

Development Operations Coordination Document Cascade / Chinook Development Project 

## 6 Biological, Physical, and Socioeconomic Information

In accordance with 30 CFR 250.247, information on site-specific conditions relating to the biological, physical, and socioeconomic conditions must accompany the DOCD and therefore is provided herein. The biological information addresses chemosynthetic communities, federally listed threatened and endangered species, critical habitat designated under the ESA, marine mammals protected under the MMPA, sensitive underwater features, marine sanctuaries, and other areas of biological concern. Physical information addresses site-specific meteorological, physical oceanographic, geotechnical, and archaeological conditions. Socioeconomic information addresses affected states and human conditions of population, employment, and commercial and recreational industries upon which they depend. 

### 6(a) High Density Deepwater Benthic Communities Information A primary concern in the development of any field is the avoidance by the field’s architecture of biologically sensitive areas. In the deepwater GoM, the primary concern is the protection of chemosynthetic organisms and fragile benthic habitats. As required under 30 CFR 250.247(a), site-specific information regarding sensitive underwater features, including high-density deepwater benthic communities is to be provided in accordance with NTL 2009 G 40, effective January 27, 2010, and is provided herein and in the associated Appendix 2a. According to the list of Known High-density Deepwater Benthic Communities in the Gulf of Mexico, the closest known community would be in Walker Ridge Block 269 at Lat.(N) 26 o 41.07’ and Long. (W) 91 o , 40.28’ at water depth 1,862 m ( http://www.gomr.mms.gov/homepg/regulate/environ/knowndwb enthic.pdf

). In 2006 and 2007, BOEM and NOAA funded deep submersible vehicle (the Alvin in 2006) and remote operated vehicle (the Jason in 2007) to document the seafloor geology and biological conditions associated with the continental slope, including Walker Ridge lease block (Roberts et al 2008). These surveys documented an active hydrocarbon seep site that supports a thriving chemosynthetic mussel and tubeworm community

. Cascade East Development Wells WR 206 No. 6 and 7 and associated jumper connectors are not located within any of the areas of known communities: Alaminos Canyon, East Breaks, Garden Banks, or Green Canyon, particularly the community identified in Walker Ridge Block 269 which would be located over 117.7 km (73 miles) east of the proposed project site and approximately 620m (2,034 feet) higher in elevation. Nonetheless, PAI, in conjunction with Geoscience Earth and Marine Services, Inc. (GEMS), designed and implemented both geophysical and geotechnical data acquisition programs for Chinook, Cascade, and the Chinook Gas Export Routes during two studies: Summary of Environmental Conditions for the Petrobras America Inc. Cascade and Chinook Fields Development (2007) (see Appendix 2-B for full report) and Seafloor and6 Biological, Physical, and Socioeconomic Information

Page 6-2 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Geologic Assessment (Shallow Hazards) Report for Facilities (2007) (see Appendix 2-B for full report). The Cascade data acquisition area includes the location for Cascade East Development Wells WR 206 No. 6 and 7 and associated jumper connectors. Additionally, PAI, initiated an environmental monitoring program of water, sediments, and marine organisms within the Walker Ridge Cascade and Chinook Development Units to provide environmental characterization after initial exploration and development wells installation in order to evaluate results of these activities. Analytical results from monitoring are compared to “benchmarks” developed by the U.S. Environmental Protection Agency (EPA). These benchmarks provide interested parties a tool to evaluate potential risks to aquatic life and humans coming into contact with impacted water and sediments. Initial findings from an initial monitoring campaign undertaken in September 2010 indicate no exceedances of EPA acute and chronic benchmarks for any of the petroleum hydrocarbon analytes, including polyaromatic hydrocarbons, in sediment and water samples. This initial monitoring campaign provided a “snapshot” in time of water and sediment conditions in Walker Ridge Cascade and Chinook Oil Production blocks in September 2010. The absence of detectable concentrations of polyaromatic hydrocarbons and reportable total petroleum hydrocarbons in the sediment samples suggests that no petroleum hydrocarbon contamination was detected in the study area bottom surface sediments during the time of the Characterization Campaign. This information may be utilized as a benchmark and becomes especially important in light of the ‘Macondo’ tragedy in early 2010. Summaries of the findings of these three studies are provided below. Environmental survey protocol included 3D seismic data and 2D High-resolution Hugin AUV survey data and groundtruthing to identify and avoid biologically sensitive areas defined and protected by BOEM. There is precedent to employ the use of 3D seabed peak seismic amplitude data to infer the presence of conditions that may be conducive to high-density deepwater benthic communities, including chemosynthetic communities and sensitive benthic habitats (Roberts et al 2008). GEMS has reviewed the 3D seismic coverage provide by PAI. However, GEMS defers to the available 2D High-Resolution data. The 2D High-Resolution geophysical data consists of multibeam bathymetry (3m bins), side-scan sonar, and chirp sub bottom profiler data. These data provide information on seabed reflectance character which is inferred to be seabed soil type or hardness. This is excellent for identifying areas of potential harder substrate that may be an indication of the presence of chemosynthetic organisms or sensitive habitat. The sub bottom profiler provides further evidence for harder substrate, or, hydrocarbon indicators necessary as the source for chemosynthetic communities. The multibeam bathymetry also provides indirect evidence for hydrocarbon mounds or organic mounds from the topography of the seafloor. Used in combination, these data provide the best geophysical means to identify and define areas where there is potential for chemosynthetic communities to occur and forms the basis for the assessment of the seabed and shallow conditions with respect to the protection of these sensitive benthic communities.6 Biological, Physical, and Socioeconomic Information

Petrobras America Inc. Page 6-3 Development Operations Coordination Document Cascade / Chinook Development Project The Seafloor and Geologic Assessment Report of Cascade and Chinook Development Areas (June 2007 DOCD, Appendix 2-B) provides in detail information on the geologic structure, stratigraphy, slopes and topographic features, and potential for chemosynthetic communities. No active faults, gas venting, or hard bottom conditions were identified within the Cascade Development Area. There is no potential for encountering chemosynthetic communities in the area planned for Cascade East Development Wells WR 206 No. 6 and 7. The initial assessment of PAI’s environmental monitoring program indicates that an abundance and diversity of infauna in the seafloor sediments was low. The soft bottom benthic community was dominated by polychaetes. Discharges and Moorings Related to Drilling Cascade East Wells NTL 2009-G40 increased the separation distance from muds and cuttings discharge locations to 2,000 feet 9609.6m) from any high-density deepwater benthic community. Features or areas that could support high-density chemosynthetic communities are not located within 2,000 feet of the proposed muds and cuttings discharge locations for the Cascade East Development Wells WR 206 No. 6 and 7 located in WR Block 206. PAI proposes to utilize one vessel to drill and complete the Cascade wells: the “Deep Ocean Mendocino”. The vessel, as defined by 46 USC 2101(45), is a dynamic position drilling ship (provided in MMS Form 137 in Section 1) thus; the seafloor will not be disturbed by an anchoring or mooring system. Discharges related to drilling would involve drilling fluids which were identified along with amounts per well in Section 2, Table 2-1, Section 7, and Appendix 7-A. A majority of these fluids are recycled or reused. Relatively small amount of soft seafloor sediments would be temporarily disturbed, put into suspension, and settled out again a short distance from the area of disturbance by the local currents. Discharges are further addressed in Section 19 (c) 3. The proposed action would have localized impact on water quality from the FPSO, shuttle vessels, drilling rig, and support vessels produced water discharges and waste water discharges and deck drainage. However, these impacts would not be significant because produced water and waste water are treated onboard prior to discharge according to NPDES General Permit requirements to a sufficient quality for discharging overboard as indicated in Section 7 and as addressed in Section 19 (c) 3, the previous Deepwater Operations and Activities Environmental Assessment (DOI 2000), and the Proposed Use of Floating Production, Storage, and Offloading Systems on the Gulf of Mexico Outer Continental Shelf Final Environmental Impact Statement (DOI 2001).
Subsea Facilities Subsea facilities associated with Cascade East Development Wells WR 206 No. 6 and 7 will involve jumpers to be installed to connect the wells to a common four slot manifold which has already been installed. Later Phase II development will include an additional drill center with trees, jumpers and an additional manifold tied into the existing subsea architecture. The Cascade East seafloor wells will be tied back to the Cascade6 Biological, Physical, and Socioeconomic Information

Page 6-4 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project development via tie-back flow lines that then connected to the FPSO through floatingflow lines/production risers and umbilicals. Features or areas that could support highdensity chemosynthetic communities were not located within 2,000 feet (609.6m) of any seafloor disturbances resulting from installation of the subsea facilities located in WR Block 206 included in the monitoring area. In accordance with 30 CFR 250.221 (a) and 30 CFR 250.252 (a), a description of monitoring of the proposed activities is provided in 6(g) and Section 10. 

### 6(b) Topographic Features MapAs per NTL 2009-G40, a map depicting seafloor/bathymetry conditions using highresolution seismic information at a scale of 1 inch = 1,000 feet is provided in Figure 6-1. Analysis of seafloor conditions was undertaken and results are provided in Appendix 2- A, confirming no high-density deepwater benthic communities or underwater sensitive features are within 2,000 feet (609.6m) of each proposed well discharge location. Per 30 CFR 250, subpart B and NTL 2008-G04, information requirements for EPs and DOCDs, the information required in this section pertains to activities occurring near protective zones and within 1,000 feet (305 meters) of a “No Activity Zone” of an identified topographic feature. The facilities associated with Phase II, specifically Cascade East Development Wells WR 206 No. 6 and 7, of the development plan are located in a water depth of over 8,000 feet (2,446.5m) and are not located near a “Protective Zone” or “No Activity Zone”. Shuttle Vessels and marine support vessels could cross over “No Activity Zones”, however no bottom disturbances to these features are anticipated. Cascade Development Area consists of three geomorphic provinces: the Lower Continental Slope, the Sigsbee Escarpment, and the Upper Continental Rise. The Cascade East oil development facilities, including Cascade East Development Wells WR 206 No. 6 and 7 are, and will be placed on the Upper Continental Rise. The location for the Cascade East development was found to have low gradient with furrows and flukes caused by periodic strong seabed currents resulting in local topographic highs. There are no indications of mounds, expulsion features, or stronger reflectance suggestive of more granular or hard substrate. Topographic features / bathymetry within 2,000 feet (609.6m) of the proposed well locations are shown in Figure 6-1. 

### 6(c) Topographic Features Statement (Shunting) Per NTL 2008 G04, this information is not required for DOCDs. 

### 6(d) Live Bottoms (Pinnacle Trend) Map Per NTL 2008-G04, the information required in this section pertains to activities occurring within 200 feet (61 meters) of a Live Bottom (Pinnacle Trend). The facilities associated with Phase II, specifically Cascade East Development Wells WR 206 No. 6 and 7 of the development plan are not located near a Live Bottom (Pinnacle Trend).6 Biological, Physical, and Socioeconomic Information

Petrobras America Inc. Page 6-5 Development Operations Coordination Document Cascade / Chinook Development Project 

### 6(e) Live Bottoms (Low Relief) Map Per NTL 2008-G04, the information required in this section pertains to activities occurring within 100 feet (30.5 meters) of a Live Bottom (Low Relief). The facilities associated with Phase II, specifically Cascade East Development Wells WR 206 No. 6 and 7, of the development plan are not located near a Live Bottom (Low Relief). 

### 6(f) Potentially Sensitive Biological Features Per NTL 2008-G04, the information required in this section pertains to activities occurring within 200 feet (61 meters) of a Sensitive Biological Feature. Sensitive biological features include topographic features, pinnacles, live bottoms typically found in water depths less than 984 feet (300 meters) in the Gulf of Mexico. The Cascade East Development Area, including Cascade East Development Wells WR 206 No. 6 and 7, are located in over 8,000 feet (2,446.5 meters) of water depth. The facilities associated with Phase II of the development plan are not located near a Sensitive Biological Feature. Further, Cascade East Development Area, which includes Cascade East DevelopmentWells WR 206 No. 6 and 7, has seafloor currents that have and continue to erode and redeposit seabed sediments. The 2010-2011 site-specific environmental monitoring found the Area to have soft bottom sediments and confirmed the absence of chemosynthetic communities within 2,000 feet (609.6m) of the drill center as indicated in Figure 6-1. It is unlikely that organisms requiring hard bottom substrate would find suitable colonization locations within the proposed project area. 

### 6(g) Remotely Operated Vehicle (ROV) Monitoring Survey Plan PAI is familiar with the ROV survey and the reporting provisions described in NTL 2008-G06, Remotely Operated Vehicle Surveys in Deepwater . As per NTL 2008-G06, ROV survey plans are required for Exploration Plans. ROV monitoring was undertaken before and after initial installation activities using guidance from NTL No 2008-G06 and the ROV survey plan results were submitted as required on MMS Form 141 by Devon. A ROV survey plan is not required for this supplemental DOCD. 

### 6(h) Threatened and Endangered Species Information Florida and Alabama are not Affected States for Phase II, including Cascade East Development Wells WR 206 No. 6 and 7, of the development plan. As per NTL 2008- G04, site-specific information on the presence of federally-listed threatened and endangered species and critical habitat as designated under ESA, along with information on marine mammals as protected under the MMPA for the Affected States of Texas, Louisiana, and Mississippi, is provided in the Environmental Impact Analysis located in Section 19. 

### 6(i) Archeological Report BOEM GOMR has not identified a potential for containing historic or prehistoric archeological resources within the Cascade East Development Area containing the6 Biological, Physical, and Socioeconomic Information

Page 6-6 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project location of Cascade East Development Wells WR 206 No. 6 and 7. The proposed project location is not located within specific areas defined as “Archeological Survey Blocks”. Archeological considerations are included in the GEMS Summary of Environmental Conditions for Cascade and Chinook and the GEMS Shallow Hazards Report for Facilities in Appendix 2. 

### 6(j) Air and Water Quality Information Florida and Alabama are not Affected States for Phase II, specifically Cascade East Development Wells WR 206 No. 6 and 7 of the development plan. As a result, the information for Florida and Alabama is not provided per NTL 2008-G04. However, air and water quality information for the Affected States (Texas, Louisiana, and Mississippi) is provided in the Environmental Impact Analysis located in Section 19. See also information in Section 8 on air emissions. PAI initiated a water and sediment analysis study in 2010 with sampling within the Walker Ridge Cascade and Chinook Development Units to provide an environmental characterization after exploration and development wells installation. Sampling was done on a grid using 37 sampling stations. Sampling points were located in water depths ranging from 6,650-9,180 feet (2,000-2,800 meters) with water samples collected at 5 depths: surface, start and end of thermocline, mid-depth, and near-bottom depth. This study addressed obtaining hydrographic and seawater data and among other things, toxicity testing. Twenty-nine water and sediment parameters were addressed in the 2010 environmental monitoring. No petroleum hydrocarbon contamination was detected. Low concentrations of metals on the seafloor sediments indicate lack of significant concentrations in the water column. Water quality was found not acutely toxic to Americamysis bahia

. 

### 6(k) Socioeconomic Information Although the Gulf of Mexico is bounded by five coastal states, Florida and Alabama are not Affected States for Phase II, specifically Cascade East Development Wells WR 206 No. 6 and 7 of the development plan. As a result, information is provided per NTL 2008- G04 on socioeconomic information for the Affected States of Texas, Louisiana, and Mississippi in the Environmental Impact Analysis located in Section 19.6 Biological, Physical, and Socioeconomic Information

Petrobras America Inc. Page 6-7 Development Operations Coordination Document Cascade / Chinook Development Project Figure 6-1 Bathymetry Map6 Biological, Physical, and Socioeconomic Information

Page 6-8 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project This page intentionally left blank.Petrobras America Inc. Page 7-1

Development Operations Coordination Document Cascade / Chinook Development Project 

## 7 Waste and Discharge Information
7(a) Projected Generated Wastes Appendix 7 indicates projected solid and liquid wastes likely to be generated per well by drilling and completion operations during Phase II (including Cascade WR 206 Wells No. 6 and 7) of the development plan. Appendix 7-A addresses wastes generated by the drilling rig while Appendix 7-B addresses separately wastes generated by the FPSO. Appendix 7-C and Appendix 7-D provide information on transportation and on shore disposal of the wastes generated by the drilling rig and FPSO, respectively. Waste generated by the FPSO and Drilling Rigs operations include both solid and liquid wastes and will be covered under the NPDES General Permit. Plans for treating, storing, and disposal of solid and liquid wastes generated by the FPSO and Drilling Rigs will be temporarily stored onboard these respective vessels until transported to onshore facilities by supply boats for disposal (approximately weekly). The FPSO and Drilling Rigs will be contracted to PAI and are covered under PAI waste management plans. Their respective solid and liquid wastes that they generate will be transported onshore for proper disposal in authorized facilities. Support vessels (supply and service vessels) will be used for the FPSO and Drilling Rigs. Any wastes generated by these support vessels are the responsibility of the support vessel and covered under their respective waste management plans. PAI anticipates that those support vessel owners will utilize existing onshore disposal facilities (with no need for expansions) that are consistent with those onshore disposal facilities that PAI currently utilizes. Section 15 provides information on support vessels and Section 15(d) provides further information on the transportation of solid and liquid wastes to shore via the support vessels. Section 16 provides information on onshore support facilities and 16(d) provides additional information on solid and liquid waste disposal. Sanitary wastes associated with the FPSO, and Drilling Rigs, would be treated by an approved USCG Marine Sanitation Device and discharged overboard with no floating solids. All other wastes generated on the FPSO and Drilling Rigs will be treated (as required) and discharged per Region 6 NPDES General Permit requirements. 

### 7(b) Projected Ocean Discharges Appendix 7-A indicates discharge method of various types of waste with indication of expected ocean discharges of solid and liquid wastes associated with drilling and completion operations for Phase II (including Cascade WR 206 Wells No. 6 and 7) of the development plan. Appendix 7-B indicates discharge methods by waste type generated by the FPSO with an indication of the wastes expected for overboard ocean discharges of solid and liquid wastes associated with FPSO production operations for Phase II of the development plan.7 Waste and Discharge Information

Page 7-2 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Waste discharged by the FPSO and Drilling Rigs operations will be covered under the NPDES General Permit. 

### 7(c) Modeling Report PAI sent to the Environmental Protection Agency (EPA) a Notice of Intent on May 03, 2009 requesting coverage under EPA Region 6 NPDES General Permit (GMG 290000) for discharges associated with Phase II which includes Cascade WR 206 Wells No. 6 and 7 of the development plan. As a result, modeling is not required per NTL 2008-G04. 

### 7(d) NPDES Permits Per NTL 2008-G04, information regarding NPDES permits is not required for DOCDs submitted in the BOEM GoM region. 

### 7(e) Cooling Water Intakes Per NTL 2008-G04, information regarding cooling water intake structures is not required to accompany DOCDs submitted in the BOEM GoM region.Petrobras America Inc. Page 8-1

Development Operations Coordination Document Cascade / Chinook Development Project 

## 8 Air Emissions Information

8(a) Complex and Plan Emissions The Complex Total Emissions information includes a second drilling rig for Cascade during Phase II of the development plan beyond the first rig that will be working at Chinook. The Complex Total Emissions evaluation also includes the FPSO, supportvessels, shuttle vessels, and aircraft. There are no other existing facilities or activities colocated with our currently proposed activities. Drilling rigs are not subject to the Greenhouse Gas Reporting Rule. The stationary sources and fugitive emissions (engines, flares, pipe valves, flanges, and vents) on the FPSO are subject to the Greenhouse Gas Reporting Rule, however, the FPSO has not yet started production. Greenhouse gas emissions from the FPSO in 2011 must be reported by March 21, 2012. 

### 8(b) Screening Questions

Is any calculated Complex Total (CT) Emission amount (tons) associated with your proposed development and production activities more than 90% of the amounts calculated using the following formulas: CT = 34002/3 for CO, and CT = 33.3D for the other air pollutants (where D = distance to shore in miles)? Yes No
X

Do your emission calculations include any emission reduction measures or modified emission factors? X

Does or will the facility complex associated with your proposed development and production activities process production from eight or more wells? X
Do you expect to encounter H2S at concentrations greater than 20 parts per million (ppm)? X
Do you propose to flare or vent natural gas in excess of the criteria set forth under § 250.1105(a)(2) and (3)? X
Do you propose to burn produced hydrocarbon liquids? X Are your proposed development and production activities located within 25 miles (40 kilometers) from shore? X
Are your proposed development and production activities located within 124 miles (200 kilometers) of the Breton Wilderness Area? X



### 8(c) Worksheets Air emissions worksheets for Phase II of the development plan are in Appendix 3.8. Air Emissions Information

Page 8-2 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project 

### 8(d) Contact Information For questions regarding calculations of the projected Plan Emissions, contact: Gregory D. Roland Regulatory Compliance Area Manager Petrobras America Inc. 10350 Richmond Ave, Suite 1400 Houston, Texas 77042 Office: 713-808-2881 

### 8(e) Emissions Reduction Measures

The Plan Emissions do include emissions reductions measures as the Plan Emissions are below the Exemption threshold. Petrobras used different fuel use factors based on data from actual fuel use in Phase I. Emission factors are from the original BOEM spreadsheet, updated AP42 factors, manufacturer’s guarantee, and helicopter emission factors from Swiss Confederate emissions data. All changes are documented in the “Factors” noted in the spreadsheet in Appendix 3. 

### 8(f) Verification of Non-Default Emissions Factors The air emissions worksheets in Appendix 3 include descriptions of the rationale for operating assumptions (i.e. fuel consumption) related to certain facilities and marine equipment used for Phase II of the development plan in the notes of each worksheet. 

### 8(g) Non Exempt Activities The Plan Emissions are below the Exemption threshold. 

### 8(h) Modeling Report Modeling will not be required as the Plan Emissions are below the Exemption threshold.Petrobras America Inc. Page 9-1

Development Operations Coordination Document Cascade / Chinook Development Project 

## 9 Oil Spill Information
9(a) Oil Spill Response Planning Regional Oil Spill Response Information Proposed activities in this Supplemental DOCD cover drilling, completion and production of two additional Cascade wells, WR 206 Well No. 6 and Well No. 7. The activities are covered under PAIs (BOEM operator #1207) Regional Oil Spill Response Plan (OSRP) filed in accordance with 30 CFR 254. PAI’s WCD planning volume is 18,135 bopd reflecting the calculations of the Resource Evaluation Section (RE) of BOEM. PAI’s latest OSRP biennial filing was submitted on 27 July 2011 and is pending approval. Information provided in herein has been updated and is current to the best of PAI knowledge at the time of this SDOCD submittal. In light of the Macondo tragedy PAI recognizes that industry as a whole continues to experience new regulatory requirements, challenges and changes. Many of the OSROs are bolstering resources, especially equipment and personnel and as fast as these changes are occurring, some information in this section could become obsolete shortly after submittal of this document. The numbers reflected herein should be considered minimum capacities and could be much more substantial by the time this SDOCD is approved. PAI confirms our commitment to revise and update these capabilities and inventories as appropriate and as information is received and confirmed by our OSROs. Changes will be reflected in any OSRP update / modification as soon as the information becomes available or regulatory requirements mandate changes.

Spill Response Sites PAI is currently a member of Clean Gulf Associates (CGA) who acts as PAI’s primary equipment provider. CGA is an industry cooperative, owning an inventory of oil spill clean-up equipment which is located throughout the gulf coast. CGA is supported by the Marine Spill Response Corporation (MSRC), which is responsible for storing, inspecting, maintaining and dispatching CGA’s equipment. CGA also has access to equipment provided by the National Response Corporation (NRC) and the Teppco Marine Services LLC Barges. The MSRC STARS network provides the closest available personnel, as well as an MSRC supervisor to operate the equipment. PAI’s primary spill response equipment is provided by CGA as described in the current OSRP. Table 9-1 indicates the locations of PAI’s primary spill response equipment and the locations of the planned staging areas.9. Oil Spill Information

Page 9-2 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Table 9-1 – Location of CGA Oil Spill Response Equipment & Staging Areas

Primary Response Equipment Locations (CGA) Preplanned Staging Locations (CGA) CGA/Galveston, TX Galveston, TX CGA/Harvey, LA Houma, LA/Venice, LA CGA/Houma, LA Houma, LA CGA/Lake Charles, LA Cameron, LA CGA/Ingleside, TX Ingleside, TX CGA/Intracoastal City, LA Intracoastal City, LA CGA/Pascagoula, MS Pascagoula, MS CGA/Venice, LA Venice, LA PAI also has access to spill response equipment provided by CCA. Table 9-2 indicates the locations of CCA’s spill response equipment and the locations of the planned staging

areas. Table 9-2 – Location of CCA Oil Spill Response Equipment & Staging Areas

Response Equipment Locations (MSRC GoM) Preplanned Staging Locations (MSRC GoM) Fort Lauderdale, FL Fourchon, LA Venice, LA Houma, LA OSRO Information PAI is currently a member of Clean Gulf Associates (CGA). The de-rated (i.e. 20% of equipment name plate per manufacturer specification) daily mechanical recovery capabilities for each OSRO is described in Table 9-3. Table 9-3 – OSRO Mechanical Recovery and Storage Capabilities

OSRO De-Rated Daily Recovery Capability (bar rels per day) Storage Capacity (bbls)
Clean Gulf Associates (CGA) 139,796 7,396

CGA Access T&T Marine Services LLC Koseq Skimming Arms 196,119 22,000

CGA Access T&T Marine Services LLC Aqua Guard Triton RBS Skimmers 45,560 4,000

CGA Access Enterprise Marine Services LLC Storage B arges -- 201,000

CGA Access K-Sea operating Partnership Storage B arges -- 1,478,222

TOTAL 381,475 1,712,6189. Oil Spill Information

Petrobras America Inc. Page 9-3 Development Operations Coordination Document Cascade / Chinook Development Project PAI will also utilize dispersants as an alternative response strategy in certain circumstances when approved by regulatory authorities. The available dispersant inventories are described in Table 9-4. Table 9-4 – Dispersant Inventories

OSRO Dispersant Inventory (gallons) Clean Gulf Associates 33,300 CGA ASI Access 49,155 TOTAL 82,455 PAI also utilizes other complimentary specialist OSROs as appropriate, including but not limited to AMPOL, Garner Environmental Services, Industrial Cleanup, Oil Mop, and PSC Industrial Services. See the current -OSRP for a complete listing.

Worst Case Scenario Determination WCD Scenario for MMS Areas of Interest: Table 9-5 provides a comparison of the Worst Case Discharge (WCD) scenarios from PAI’s OSRP with the WCD scenario from the proposed activities covered by this supplemental DOCD. As shown, the calculated WCD for this Supplemental DOCD is 18,135 bopd. This is explained in Appendix 6 by the fact that the calculated WCD for these proposed wells is less than the amount calculated by BOEM RE section tusy PAI has chosen to utilize the higher number for simplification and minimum response planning and containment resources. BOEM RE section has authorized PAI to utilize the greater WCD volume (18,135 bopd) calculated for Walker Ridge (206) for WCD planning volumes in PAI’s OSRP and previous SDOCD and confirmed that it is not necessary to make changes to the PAI calculations in Appendix 6. Pursuant to guidance from BOEM, PAI agreement to utilize the BOEM-RE calculated WCD volume of 18,135 bopd WCD, and in accordance with NTL 2008 G 04, PAI provides the following compliance statement:9. Oil Spill Information

Page 9-4 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Table 9-5 – Worst Case Discharge Scenario

Category R-OSRP
WCDS DOCD WCDS

Drilling DOCD WCDS
Production

Type of Activity Drilling Drilling Subsea Production Produced to FPSO

Facility Location(s) WR 206
OCS-G 16965 WR 469
OCS-G 16997 WR Block 249
OCS-G 16969

Facility Designation Subsea Wells
Cascade No. 6 and 7 Subsea Well

Chinook
WR425-W FPSO

Distance to Nearest Shoreline (Miles) 165 165 134

Volume (barrels) : Storage Tanks (total) 0 0 6,010 (1) On-facility Flowlines 0 0 2,000 (2) Lease Term Pipelines 0 0 2,110
Uncontrolled Blowout (volume per day) 18,135 15,477 (3)

-
Total Volume 18,135 15,477 10,120
Type of Oil (e.g. Crude, Condensate, Diesel) Crude Crude Crude

API Gravity 23 26 23 Notes: (1) Includes FPSO Topsides Tanks only; does not include FPSO Cargo or Fuel Tanks; see 1(d) for storage tank details and 9© below for additional discussion (2) On-facility Flowlines includes Processing Piping (including Turret systems) (3) See Appendix 6 for details
Additional notes for BOEM WCD Scenario:

 PAI is proposing to perform well testing for the Cascade Wells (WR 206 Well No. 6 and 7) proposed by this Supplemental DOCD. PAI is proposing to discharge the well completion fluids (which will not include EPA defined “priority pollutants”) per NPDES requirements.

 PAI is not proposing to use oil-based drilling fluids. PAI is proposing to use water-based and synthetic-based drilling fluids for the drilling of the proposed Cascade wells covered by this Supplemental DOCD.

 A site –specific worst case scenario is included in PAI’s Regional OSRP for the FPSO (which will receive production from the Cascade / Chinook subsea well[s]) Production rates from the wells does not affect the FPSO WCD.9. Oil Spill Information

Petrobras America Inc. Page 9-5 Development Operations Coordination Document Cascade / Chinook Development Project 

### 9(b) Oil Spill Response Discussion – BSEE Areas of Interest For the purpose of NEPA and Coastal Zone Management Act analysis, the largest spill volume originating from the proposed activity would be a well blowout during drilling operations, estimated to be 18,135 barrels of crude oil with an API gravity of 23°. 9(b).1 Land Segment and Resource Identification Trajectories of a spill and the probability of it impacting a land segment have been projected utilizing information in the BSEE Oil Spill Risk Analysis Model (OSRAM) for the Central and Western Gulf of Mexico available on the BSEE website. The results are shown in Table 9-6. The BSEE OSRAM identifies a 2% probability of impact to the shorelines of Galveston County, Texas; Cameron Parish, Louisiana; and/or Plaquemines Parish, Louisiana within 30 days.

Table 9-6 – Trajectory by Land Segment

Galveston County includes the Gulf Beach from the west end of Galveston Island at Texas Highway 3005 to the east coast of High Island at the Jefferson County line. Habitats include marshes at the west end of Seawall Boulevard and on the east end of the island and open beaches and avian feeding areas all along the coastline, including a National Audubon Society Sanctuary. The waters of Galveston Bay are classified as an EPA National Estuary.
Cameron Parish includes the east side of Sabine Lake, Sabine National Wildlife Refuge, Calcasieu Lake, Lacassine National Wildlife Refuge (inland) and Grand Lake. Cameron Parish also includes the area along the coastline from Sabine Pass to Big Constance Lake in Rockefeller Wildlife Refuge. This region is composed of open public beaches, Trajectory of a spill and the probability of it impacting a land segment have been projected utilizing Petrobras America Inc.’s WCD and information in the BSEE Oil Spill Risk Analysis Model (OSRAM) for the Central and Western Gulf of Mexico available on the BSEE website using 30 day impact. The results are tabulated below.

Area/Block OCS-G Launch Area Land Segment and/or

Resource Conditional Probability (%) within 30 days

Drilling Operations WR 206 165 miles from shore G16965 C48 Matagorda County, TX Brazoria County, TX Galveston County, TX Jefferson County, TX Cameron Parish, LA Vermilion Parish, LA Terrebonne Parish, LA LaFourche Parish, LA Plaquemines Parish, LA 1 1 2 1 2 1 1 1 29. Oil Spill Information

Page 9-6 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project marshlands and swamps. It serves as a habitat for numerous birds, finfish and other animals, including several rare, threatened and endangered species. Plaquemines Parish includes Barataria Bay, the Mississippi River Delta, Breton Sound and the affiliated islands and bays. This region is an extremely sensitive habitat and serves as a migratory, breeding, feeding and nursery habitat for numerous species of wildlife. Beaches in this area vary in grain particle size and can be classified as fine sand, shell or perched shell beaches. Sandy and muddy tidal flats are also abundant. 9(b).2 Response Petrobras America Inc. will make every effort to respond to the Worst Case Discharge as effectively as practicable. A description of the response equipment available to contain and recover the Worst Case Discharge is shown in Appendix 4 with estimated response times. Using the estimated chemical and physical characteristics of crude oil, an ADIOS weathering model was run on a similar product from the ADIOS oil database. As shown in Table 9-7, the results indicate 18% or approximately 3,264 barrels of crude oil would be evaporated/dispersed within 24 hours, with approximately 14,871 barrels remaining.

Table 9-7 – Oil Spill Response Results
Spill Response WR 206 Barrels of Oil

WCD Volume 18,135
Less 18% natural evaporation/dispersion 3,264

Remaining volume 14,871
Oil addressed by aerial dispersants 7,540
Oil addressed by in-situ burning 744

Appendix 4 outlines equipment, personnel, materials and support vessels as well as temporary storage equipment available to respond to a spill of 18,135 barrels. The list estimates individual times needed for procurement, load out, travel time to the site and deployment. Appendix 4 also indicates how operations will be supported. Petrobras America Inc.’s Oil Spill Response Plan includes alternative response technologies such as dispersants and in-situ burn. Strategies will be decided by Unified Command based on size of the spill, weather and potential impacts. If aerial dispersants are utilized, 8 sorties (9,600 gallons) from two of the DC-3 aircrafts and 4 sorties (8,000 gallons) from the Basler aircraft totaling 419 bbls of dispersants should disperse approximately 7,540 barrels of oil. If the conditions are favorable for in-situ burning, the9. Oil Spill Information

Petrobras America Inc. Page 9-7 Development Operations Coordination Document Cascade / Chinook Development Project proper approvals have been obtained and the proper planning is in place, in-situ burning of oil may be attempted. Using estimates based on the Deepwater Horizon spill of 2010, up to 5% or approximately 744 barrels of the total daily Worst Case Discharge remaining volume could be burned. Slick containment boom would be immediately called out and on-scene as soon as possible. Offshore response strategies may include attempting to skim utilizing the HOSS Barge and seven Fast Response Units (FRUs), with a total derated skimming capacity of 69,390 barrels. Temporary storage associated with skimming equipment equals 5,300 barrels. If additional storage is needed, a 20,000 barrel storage barge and a 47,000 barrel storage barge may be mobilized and centrally located to provide temporary storage allowing the skimmers to stay in the area of operations as much as possible. Safety is first priority. Air monitoring will be accomplished and operations deemed safe prior to any containment/skimming attempts. If the spill went unabated, shoreline impact in Galveston County, Texas; Cameron Parish, Louisiana; and/or Plaquemines Parish, Louisiana would depend upon existing environmental conditions. Shoreline protection would include the use of CGA’s near shore and shallow water skimmers with a totaled derated skimming capacity of 18,253 barrels. Temporary storage associated with skimming equipment equals 1,317 barrels. If additional storage is needed, a 20,000 barrel storage barge may be mobilized and centrally located to provide temporary storage allowing the skimmers to stay in the area of operations as much as possible. Onshore response may include the deployment of shoreline boom on beach areas, or protection and sorbent boom on vegetated areas. Letters of Intent from AMPOL, Miller, Oil Mop and USES will ensure access to approximately 263,000 feet of 18” shoreline protection boom. Appendix 4 outlines individual times needed for procurement, load out, travel time to the site and deployment. Strategies would be based upon surveillance and real time trajectories that depict areas of potential impact given actual sea and weather conditions. The One-Gulf Plan (Area Contingency Plan) and Unified Command would be consulted to ensure that environmental and special economic resources would be correctly identified and prioritized to ensure optimal protection. The State of Louisiana Initial Oil Spill Response Plan for Cameron Parish/Plaquemines Parish and Unified Command would be consulted to ensure that environmental and special economic resources would be correctly identified and prioritized to ensure optimal protection. Shoreline protection strategies depict the protection response modes applicable for oil spill clean-up operations. The State of Louisiana Initial Oil Spill Response Plan provides detailed shoreline protection strategies for this area, and it describes necessary action to keep the oil spill from entering Louisiana’s coastal wetlands, based on the assumption that removal of the released oil will be much easier and less damaging to fragile coastal ecosystems if done in the open waters of the Gulf of Mexico. Supervisory personnel have the option to modify thedeployment and operation of equipment allowing a more effective response to sitespecific circumstances. Petrobras Americas Inc.’s contract Spill Management Team holds copies of the State of Louisiana Initial Oil Spill Response Plan and the One-Gulf Plan.9. Oil Spill Information

Page 9-8 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project 9(b)2.1 Initial Response Considerations Actual actions taken during an oil spill response will be based on many factors to include but not be limited to:
• Weather • Equipment and materials availability
• Ocean currents and tides • Location of the spill • Product spilled • Amount spilled
• Environmental risk assessments • Trajectory and product analysis • Well status, i.e., shut in or continual release Petrobras America Inc. will take action to provide a safe, aggressive response to contain and recover as much of the spilled oil as quickly as it is safe to do so. In an effort to protect the environment, response actions will be designed to provide an “in-depth” protection strategy meant to recover as much oil as possible as far from environmentally sensitive areas as possible. Safety will take precedence over all other considerations during these operations.
Upon notification of a spill, the following actions will be taken:
• Information will be confirmed • An assessment will be made and initial objectives set • OSROs and appropriate agencies will be notified • ICS 201, Initial Report Form completed • Initial Safety plan will be written and published
• Unified Command will be established

o Overall safety plan developed to reflect the operational situation and coordinated objectives

o Areas of responsibility established for Source Control and each surface operational site

o On-site command and control established9. Oil Spill Information

Petrobras America Inc. Page 9-9 Development Operations Coordination Document Cascade / Chinook Development Project 9(b)2.2 Offshore Response Actions 9(b)2.2.1 Equipment Deployment Surveillance • Surveillance Aircraft: within two hours of QI notification, or at first light • Provide trained observer to provide on site status reports • Provide command and control platform at the site if needed • Continual surveillance of oil movement by remote sensing systems, aerial photography and visual confirmation • Continual monitoring of vessel assets using vessel monitoring systems 9(b)2.2.2 Dispersant application assets • Put ASI on standby • With the FOSC, conduct analysis to determine appropriateness of dispersant application • Gain FOSC approval for use of dispersants on the surface • Deploy aircraft in accordance with a plan developed for the actual situation • Coordinate movement of dispersants, aircraft, and support equipment and personnel • Confirm dispersant availability for current and long range operations • Start ordering dispersant stocks required for expected operations 9(b)2.2.3 Containment boom • Call out early and expedite deployment to be on scene ASAP • Ensure boom handling and mooring equipment is deployed with boom • Provide continuing reports to vessels to expedite their arrival at sites that will provide for their most effective containment • Use Vessels of Opportunity (VOO) to deploy and maintain boom 9(b)2.2.4 Dedicated off-shore skimming systems General • Deployed to the highest concentration of oil • Assets deployed at safe distance from aerial dispersant and in-situ burn operations CGA9. Oil Spill Information

Page 9-10 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project HOSS Barge
• Use in areas with heaviest oil concentrations • Consider for use in areas of known debris (seaweed, and other floating materials)

CGA FRUs
• To the area of the thickest oil
• Use as far off-shore as allowed

Storage Vessels • Establish availability of CGA contracted assets • Early call out (to allow for tug boat acquisition and deployment speeds) • Phase mobilization to allow storage vessels to arrive at the same time as skimming systems • Position as closely as possible to skimming assets to minimize offloading time

Vessels of Opportunity (VOO) • Use Petrobras America Inc.’s contracted resources as applicable • Industry vessels are usually best for deployment of Vessel of Opportunity Skimming Systems (VOSS) • Acquire additional resources as needed • Consider use of local assets, i.e. fishing and pleasure craft • Expect mission specific and safety training to be required • Plan with the US Coast Guard for vessel inspections
In-situ Burn Assets • Determine appropriateness of in-situ burn operation in coordination with the FOSC and affected SOSC • Determine availability of fire boom and selected ignition systems • Start ordering fire boom stocks required for expected operations • Contact boom manufacturer to provide training if required • Determine assets to perform on water operation • Build operations into safety plan • Conduct operations in accordance with an approved plan9. Oil Spill Information

Petrobras America Inc. Page 9-11 Development Operations Coordination Document Cascade / Chinook Development Project 9(b)2.3 Near Shore Response Actions 9(b)2.3.1 Timing • Put near shore assets on standby and deployment in accordance with planning based on the actual situation, actual trajectories and oil budgets • VOO identification and training in advance of spill nearing shoreline if possible • Outfitting of VOOs for specific missions • Deployment of assets based on actual movement of oil Considerations • Water depth, vessel draft • Shoreline gradient
• State of the oil
• Use of VOOs
• Distance of surf zone from shoreline 9(b)2.3.2 Equipment Deployment Surveillance • Provide trained observer to direct skimming operations • Continual surveillance of oil movement by remote sensing systems, aerial photography and visual confirmation • Continual monitoring of vessel assets 9(b)2.3.3 Dispersant Use

• Generally will not be approved within 3 miles of shore or with less than 10 meters of water depth

• Approval would be at Regional Response Team level (Region 6) 9(b)2.3.4 Vessel Deployment Dedicated Near Shore Skimming Systems
• FRVs • Egmopol and Marco SWS • Operate with aerial spotter directing systems to observed oil slicks VOO • Use Petrobras America Inc.’s contracted resources as applicable • Industry vessel are usually best for deployment of Vessel of Opportunity Skimming Systems (VOSS) • Acquire additional resources as needed • Consider use of local assets, i.e. fishing and pleasure craft9. Oil Spill Information

Page 9-12 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project • Expect mission specific and safety training to be required • Plan with the US Coast Guard for vessel inspections • Operate with aerial spotter directing systems to oil patches 9(b)2.4 Shoreline Protection Operations 9(b)2.4.1 Response Planning Considerations

• Environmental risk assessments (ERA) to determine priorities for area protection

• Time to acquire personnel and equipment and their availability

• Previous contingency planning contained in the appropriate Area Contingency Plan, and currently for Louisiana, The State of Louisiana Initial Oil Spill Response Plan, Deep Water Horizon, dated 2 May 2010 (La. OSRP) 9(b)2.4.2 Actions Placement of Boom

• Position boom in accordance with the ERA based on the actual situation or the appropriate ACP

• Assess timing of booming operations to ensure it is where it needs to be at time of impact. Consider:

o Trajectories

o Weather forecast

o Oil Impact forecast

o Verified spill movement

o Boom, manpower and vessel (shallow draft) availability

o Near shore boom and support material, (stakes, anchors, line)
Beach Preparation: Considerations and Actions • Use of a 10-mile go/no go line to determine timing of beach cleaning • Shoreline Cleanup and Assessment Team Reports and recommendations • Determination of Archeological sites and gaining authority to enter • Monitoring of tide tables and weather to determine extent of high tides • Pre cleaning of beaches by moving waste above high time lines to minimize waste • Staging of equipment and housing of response personnel as close to the job site as possible to maximize on-site work time • Boom tending, repair, replacement and security (use of local assets may be advantageous) • Constant awareness of weather and oil movement for resource redeployment as necessary9. Oil Spill Information

Petrobras America Inc. Page 9-13 Development Operations Coordination Document Cascade / Chinook Development Project • In-situ burn may be considered when marshes have been impacted • Passive clean up of marshes should considered and appropriate stocks of sorbent boom and/or sweep obtained • Earthen berms and shoreline protection boom may be considered to protect sensitive inland areas 9(b).3Decanting Strategy Recovered oil and water mixtures will typically separate into distinct phases when left in a quiescent state. When separation occurs, the relatively clean water phase can be siphoned or decanted back to the recovery point with minimal, if any, impact. Decanting therefore increases the effective on-site oil storage capacity and equipment operating time. FOSC/SOSC approval will be requested prior to decanting operations. This practice is routinely used for oil spill recovery. 9(b).4 CGA Equipment Limitations The capability for any spill response equipment, whether a dedicated or portable system, to operate in differing weather conditions will be directly in relation to the capabilities of the vessel the system in placed on. Most importantly, however, the decision to operate will be based on the judgment of the Unified Command and/or the Captain of the vessel, who will ultimately have the final say in terminating operations. Skimming equipment listed in Table 9-8 may have operational limits which exceed those safety thresholds. As was seen in the Deepwater Horizon (DWH) oil spill response, vessel skimming operations ceased when seas reached 5-6 feet and vessels were often recalled to port when those conditions were exceeded. Systems below are some of the most up-to-date systems available and were employed during the DWH spill.

Table 9-8 – Oil Spill Response Equipment Limitations Boom 3 foot seas, 20 knot winds Dispersants Winds more than 25 knots Visibility less than 3 nautical miles Ceiling less than 1,000 feet. FRU 8 foot seas HOSS Barge/OSRB 8 foot seas Koseq Arms 8 foot seas OSRV 4 foot seas
9(b).5 Environmental Conditions in the GOM Prevailing winds, waves and currents along the Texas coast are from the southeast and northeast quadrants. Ten to 20 foot waves may occur during hurricanes. The combined effect of the winds, surface currents, and waves refracting shoreward produce the prevailing westerly longshore currents.9. Oil Spill Information

Page 9-14 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Tides are semi-diurnal and diurnal, and range in height from less than 1 foot to 2.5 feet. The direction, force, and duration of the wind has a considerable effect on the tides and currents. Fifteen foot tides may be expected during severe hurricanes and very low tides may accompany strong northerlies of long duration. Surface water temperature averages slightly less than 90° F and ranges between 80 and 100° F during the late summer. During the winter the average is slightly less than 60° F and the range is between 35 and 80° F. Louisiana is situated between the easterly and westerly wind belts, and therefore, experiences westerly winds during the winter and easterly winds in the summer. Average wind speed is generally 14-15 mph along the coast. Wave heights average 4 and 5 feet. However, during hurricane season, Louisiana has recorded wave heights ranging from 40 to 50 feet high and winds reaching speeds of 100 mph. Because much of southern Louisiana lies below sea level, flooding is prominent. Surface water temperature ranges between 70 and 80°F during the summer months. During the winter, the average temperature will range from 50 and 60°F. The Atlantic and Gulf of Mexico hurricane season is officially from 1 June to 30 November. 97% of all tropical activity occurs within this window. The Atlantic basin shows a very peaked season from August through October, with 78% of the tropical storm days, 87% of the minor (Saffir-Simpson Scale categories 1 and 2) hurricane days, and 96% of the major (Saffir-Simpson categories 3, 4 and 5) hurricane days occurring then. Maximum activity is in early to mid September. Once in a few years there may be a hurricane occurring "out of season" - primarily in May or December. Globally, September is the most active month and May is the least active month. 

### 9(c) Oil Spill Response Discussion – USCG Areas of Interest This section is provided to assure a comprehensive NEPA review. PAI is also capable of responding to the Worst Case Discharge, the Maximum Most Probable Discharge, and Average Most Probable Discharge scenarios which are focused on USCG areas of interest related to marine vessels as described in the most recent Memorandum of Agreement between the MMS and the USCG (OCS-03) and 33 CFR Part 155 Subpart D. PAI will utilize existing memberships in Clean Gulf Associates (CGA) and Clean Caribbean & Americas (CCA) to demonstrate oil spill response capability. Although PAI is capable of responding to the various USCG defined discharge scenarios, it should be noted that the owners of the FPSO and the Shuttle Vessels will also be responsible for demonstrating that they have the capability to respond to the USCG defined discharge scenarios prior to USCG approval of their vessel specific oil spill response plans. Although each of the organizations (PAI and vessels owners) will be capable of responding to the USCG defined discharge scenarios, it is anticipated that the vessel owners’ will have the primary responsibility as vessel operators while PAI will have secondary responsibility due to ownership of the produced oil. The details regarding primary and secondary responsibility will be finalized with the USCG after9. Oil Spill Information

Petrobras America Inc. Page 9-15 Development Operations Coordination Document Cascade / Chinook Development Project PAI awards contracts for the provision of the FPSO and Shuttle Vessels (approximately 3Q07). Table 9-9 describes the amounts associated with each USCG discharge scenario for the FPSO. Table 9-10 describes the amounts associated with each USCG discharge scenario for the Shuttle Vessels. PAI and the USCG have required the FPSO owner / provider to implement a vessel specific oil spill response plan (i.e. SOPEP) which is approved by the USCG and which will be bridged to the PAI -OSRP. PAI and the USCG also required the Shuttle Vessel owner / provider to implement a SOPEP which is approved by the USCG and is bridged to the PAI OSRP. Comprehensive drills will / are performed to verify readiness from all involved parties (PAI, FPSO provider, and Shuttle Vessel provider).

Table 9-9 – FPSO Discharge Scenarios (USCG Areas of Interest)
USCG Discharge Scenario for FPSO Estimated Amount (barrels) Comments

Worst Case Discharge 550,000 - 650,000 Equal to discharge of a marine vessel’s entire cargo tanks in adverse weather conditions. See notes (1) and (2) for additional details.

Maximum Most Probable Discharge 2,500 Equal to 2,500 barrels of oil for vessels with a cargo capacity equal to or greater than 25,000 barrels OR 10% of the vessels oil cargo capacity with a capacity of less than 25,000 barrels. See

note (3) for additional details.
Average Most Probable Discharge 50 Equal to the lessor of 50 barrels of oil or 1% of the cargo from the vessel during cargo oil transfer operations to or from the vessel Notes : (1) The USCG Worst Case Discharge would involve a total loss of the FPSO which is an extreme low probability event given the industry proven controls that PAI has in place. (2) The USCG has implemented a geographic (i.e. inland, nearshore, offshore, open ocean) based cap system to identify the amount of planning volumes that must be covered by contract. For offshore work scopes, the planning volume caps are 12,500 barrels per day for Tier 1, 25,000 barrels per day for Tier 2, and 50,000 barrels per day for Tier 3. When the required planning volume exceeds the cap amounts, the vessel owner is only required to have OSRO contracts in place up to the amount of the caps, but the vessel owner is required to identify sources of additional OSRO resources to respond to the required planning volumes over and above the cap. Regarding the USCG Worst Case Discharge planning volumes for the FPSO, PAI currently has the capability to respond to the cap amounts of the required planning volumes for Tiers 1-3 through CGA and CCA. PAI may be required to identify but not contract additional OSRO coverage (e.g. MSRC, NRC) due to the required planning volumes associated with onshore recovery of oil spilled offshore which could reach the shore, depending on the OSRO coverage that the FPSO owner has in place. (3) The USCG Maximum Most Probable Discharge is significantly greater than an oil spill associated with FPSO offloading, which may be the highest exposure regarding oil spills associated with FPSOs. As mentioned in section 1(f), PAI will utilize a number of industry proven safety and pollution prevention measures to mitigate against oil spills during FPSO offloading. If multiple controls mentioned in section 1(f) failed, the amount of oil spilled during FPSO offloading would likely be an order of magnitude lower (i.e. the amount of oil in the offloading hose) than the amount of the USCG Maximum Most Probable Discharge.9. Oil Spill Information

Page 9-16 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Table 9-10 – Shuttle Vessel Discharge Scenarios (USCG Areas of Interest)
USCG Discharge Scenario for Shuttle Vessels Estimated Amount (barrels) Comments

Worst Case Discharge 185,000 - 330,000 Equal to discharge of a marine vessel’s entire cargo tanks in adverse weather conditions. See notes (1) and (2) for additional details.

Maximum Most Probable Discharge 2,500 Equal to 2,500 barrels of oil for vessels with a cargo capacity equal to or greater than 25,000 barrels OR 10% of the vessels oil cargo capacity with a capacity of less than 25,000 barrels. See

note (3) for additional details.
Average Most Probable Discharge 50 Equal to the lessor of 50 barrels of oil or 1% of the cargo from the vessel during cargo oil transfer operations to or from the vessel Notes : (1) The USCG Worst Case Discharge would involve a total loss of the Shuttle Vessel which is an extreme low probability event given the industry proven controls that PAI will put in place. (2) The USCG has implemented a geographic (i.e. inland, nearshore, offshore, open ocean) based cap system to identify the amount of planning volumes that must be covered by contract. For offshore work scopes, the planning volume caps are 12,500 barrels per day for Tier 1, 25,000 barrels per day for Tier 2, and 50,000 barrels per day for Tier 3. When the required planning volume exceeds the cap amounts, the vessel owner is only required to have OSRO contracts in place up to the amount of the caps, but the vessel owner is required to identify sources of additional OSRO resources to respond to the required planning volumes over and above the cap. PAI may be required to identify but not contract additional OSRO coverage (e.g. MSRC, NRC) due to the required planning volumes associated with onshore recovery of oil spilled offshore or nearshore which could reach the shore, depending on the OSRO coverage that the Shuttle Vessel owner has in place. (3) The USCG Maximum Most Probable Discharge is significantly greater than an oil spill associated with Shuttle Vessel loading at the FPSO or Shuttle Vessel offloading at terminals, which may be the highest exposures regarding oil spills associated with Shuttle Vessels. As described in section 1(f), PAI will utilize a number of industry proven safety and pollution prevention measures to mitigate against oil spills during Shuttle Vessel loading at the FPSO while terminal operators will utilize a number of industry proven safety and pollution prevention measures to mitigate against oil spills during Shuttle Vessel offloading at terminals. If multiple controls described in section 1(f) failed, the amount of oil spilled would likely be an order of magnitude lower (i.e. the amount of oil in the offloading hose) than the amount of the USCG Maximum Most Probable Discharge. 

### 9(d) Modeling Report At PAI’s request, MMS conducted a site specific Oil Spill Risk Analysis (OSRA) in February 2007 to estimate the risk of impacts to coastal resources resulting from oil spills in the Walker Ridge area. A summary of the results follow. See Appendix 5 to review the details of PAI’s Oil Spill Risk Analysis Report. This model calculates the trajectories of oil spills from hypothetical spill locations to various environmental resources using realistic data fields of winds and ocean currents in the GoM. The ocean currents used are computed from an ocean circulation model of the GoM driven by “analyzed meteorological forces,” such as near-surface winds and total heat fluxes, and observed river inflow. The models used are versions of the Princeton9. Oil Spill Information

Petrobras America Inc. Page 9-17 Development Operations Coordination Document Cascade / Chinook Development Project Ocean Model (POM), which allows a realistic coastline and bottom topography to be represented in the model. In addition, the OSRA model incorporates the Mellor-Yamada turbulence closure model to represent the vertical mixing process in the water column. In the trajectory simulation portion of the OSRA model, hypothetical oil spills are initiated at regular intervals in space and time within the study area. The other portion of the model records the number of times the simulated oil spills come into contact with the shoreline and other environmental resources. The OSRA model periodically divides the total number of contacts to shoreline segments by the total number of simulated oil spills in the study area to arrive at estimated probabilities of oil-spill contact (Ji et al ., 2007). For this analysis at Walker Ridge, MMS analyzed the trajectories of a typical offshore oil spill of 1,000 bbls or greater occurring under the activities described in this DOCD. The simulations did not include factors such as possible cleanup operations, chemical composition, or biological weathering of oil spills, or the spreading and splitting of oil spills, which could affect the transport of spilled oil as well as the dimensions, volume, and nature of the oil spills. The model takes a more environmentally conservative approach by presuming persistence of spilled oil over the selected duration of time of the trajectories. However, an implicit analysis of the likely weathering and cleanup of a typical offshore oil spill of 1,000 bbl or greater occurring under the proposed action scenarios shows that the slick would not persist on the water surface beyond 10 days (MMS 2002). The trajectories run for Walker Ridge were followed for at least 30 days in the model. This allowed more hypothetical spills to reach the environmental resources and the shoreline from more distant spill locations. With increased travel time, the complex patterns of wind and ocean currents produce eddy-like motions of the oil spills and results in multiple opportunities for a spill to make contact with any given environmental resource or shoreline segment (Ji et al ., 2007). The OSRA results were that, due to the study area’s distance of 140 to 160 nautical miles from the shoreline, there were no probabilities of contact greater than 0.5% for oil spills persisting from 3 to 10 days and an annual average maximum probability of contact of 2%. Oil spills in transit for 30 days were more likely to come into contact with environmental resources and the shoreline. However, it is contemplated that active response activities and weathering factors would likely mean that oil would not persist long enough to reach the U.S. shoreline. The study area is approximately 40 to 55 nautical miles from the limits of the Exclusive Economic Zone; therefore, the international boundary segments included in the model have annual average contact probabilities of up to 16% within 10 days (Ji et al ., 2007).9. Oil Spill Information

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Development Operations Coordination Document Cascade / Chinook Development Project 

## 10 Environmental Monitoring Information

10(a) Monitoring Systems As per CFR 250.252, PAI will utilize numerous monitoring systems to measure environmental conditions and to identify conditions which may impact the environment or asset integrity of the facilities. PAI, has initiated an environmental monitoring program of water, sediments, and marine organisms within the Walker Ridge Cascade East Development Unit to provide environmental characterization after initial exploration and development wells installation in order to evaluate results of these activities. The monitoring plan results are discussed in more detail in Section 6 of this Supplemental DOCD. The Environmental Monitoring Plan (EMP) utilized by PAI is based on environmental understanding and an initial bio-physical-chemical parameters evaluation developed during a field baseline study, performed in September 2010. The combination of the baseline study and the EMP will provide PAI with a planned strategy to monitor the marine environment within the leased blocks as a proactive measure toward regulatory compliance and unforeseen litigation in the event of a release of oil in or near the Walker Ridge Cascade production area (Walker Ridge Area). The EMP will be carried out by scientific and technical crews with extensive experience in collecting oceanographic data, including deep-sea sediments, water and biological samples, for a thorough understanding of the deep–sea ecosystems of Walker Ridge. The overall objectives for the EMP are: 1) to better understand the environmental characteristics of the area; and, 2) to evaluate the evolution and trends that may result from future exploration and production of oil in the area and nearby. The implementation of a well designed EMP will provide many tangible benefits, such

as:

 A good understanding of the ecosystems of the area where PAI is conducting exploration and production activities.

 Early detection of inadvertent releases of petroleum from deep-sea wellheads, piping, the FPSO and off-loading operations and an understanding of resulting environmental effects.

 A proactive approach for the collection and analysis of scientifically creditable data that may be used to address regulatory or legal concerns.

 Credibility with regulatory agencies, stakeholders, and the community for taking a socially responsible approach that always meets or exceeds mandated requirements.10. Environmental Monitoring Information

Page 10-2 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Proper execution of this monitoring plan requires, at a minimum, the use of shipboard methodologies, equipment, instrumentation and protocols that are standard in the industry today. This ensures results that fulfill regulatory requirements while providing scientifically credible data for improved ecosystem understanding for scientific, conservation, and policy purposes. The accuracy and standardization of the data is particularly important in that it may be extremely useful to agencies and activities interested in developing and enhancing process models for the Gulf of Mexico. It is anticipated that PAI representatives will actively take part in future environmental monitoring activities in Walker Ridge. The scope of work of the EMP, for instance, will include the collection and analysis of water, sediment, plankton, benthos and nekton fauna in the natural structures of the Gulf of Mexico deep water ecosystem. The Media and data for the Environmental Monitoring Plan will consist of:

 Sea water physical-chemical parameters, including conductivity, temperature and density;

 Ocean sediment physical-chemical parameters, including drilling muds and cutting discharges;

 Biological parameters, including any incidental takes;

 Meteorological parameters, including air emissions;

 Ocean current measurements;

 Aqueous discharges; and

 Solid waste discharges. PAI affirms that an effective monitoring and assessment program should be adaptive and supported by effective communication plans and response plans. As an understanding of the local ecosystems improves over time, monitoring locations, approaches, and methodologies may need to change to reflect this knowledge. A list of additional important monitoring systems is included below.

 Fully outfitted Central Control Room on the FPSO providing the capability of monitoring topsides / subsea production systems and FPSO marine systems;

 Monitoring and testing per Region 6 NPDES General Permit requirements;

 Monitoring and testing of surface and subsurface safety systems per 30 CFR 250 Subpart H ;

 Inert Gas Monitoring System to be used on FPSO;

 Air Emissions monitoring to collect and report facility, equipment, fuel usage, and other activity information during the period January 1, 2011, to December 31, 2011 as per NTL 2010-G06 on emissions data for NAAQS criteria pollutants carbon monoxide (CO), sulfur dioxide (SO 2 ), nitrogen oxides (NO x ), particulate10. Environmental Monitoring Information

Petrobras America Inc. Page 10-3 Development Operations Coordination Document Cascade / Chinook Development Project matter-10 (PM10), particulate matter-2.5 (PM2.5), all volatile organic compounds (VOC), including exempted compounds (40 CFR 51.100), as well as greenhouse gases CO 2 , CH 4 , and N 2 O.;

 Ballast Monitoring System to be used on FPSO ;

 In-Service Inspection Plan (utilizing CCTV and ROV inspections) to be used on the FPSO in lieu of dry-docking;

 Leak detection and recovery system for the swivel located in the FPSO turret;

 Leak testing of critical connections performed after FPSO re-connection prior to introduction of pressurized fluids;

 CCTV to be utilized in the FPSO turret for critical connection systems;

 Life cycle management of polyester components of mooring system managed through IMRR Plan (if polyester mooring is used);

 ROV surveys performed after installation of polyester mooring system; performed annually thereafter (if polyester mooring is used);

 Watchkeeping performed by FPSO and Shuttle Vessel crews during offloading operations;

 Offloading Telemetry System with OESD1 and OESD2 capabilities;

 Hawser (i.e. mooring line between FPSO and Shuttle Vessel) tension monitoring system;

 CCTV for spill detection during offloading operations;

 Infrared leak detection system during offloading operations;

 Flexible jumpers outfitted with a leak detection system;

 FSHRs outfitted with a tension monitoring system;

 FSHRs outfitted with VIV monitoring system (if needed);

 Monitoring of turret motions in FPSO-connected and FPSO-disconnected conditions;

 Downhole monitoring system for wells;

 Ocean current monitoring performed using ADCP arrays (during drilling and production operations) as required by NTL 2009-G02; and

 Monitoring and reporting applicable statistics to the BOEM Gulf of Mexico OCS Region (GOMR) regarding evacuation of personnel and curtailment of production because of hurricanes and tropical storms as required by NTL 2011-G01.10. Environmental Monitoring Information

Page 10-4 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project 

### 10(b) Flower Garden Banks National Marine Sanctuary Phase II of the development plan is located approximately 170 miles (273.5 km) from the Flower Garden Banks and approximately 225 miles (362.1 km) from the Stetson Banks and will not include activities within either the protective zones of the Flower Garden Banks or the Stetson Banks.Petrobras America Inc. Page 11-1

Development Operations Coordination Document Cascade / Chinook Development Project 

## 11 Lease Stipulations Information

11(a) Topographic Features Stipulation The proposed Cascade East Development WR 206 Wells No. 6 and 7 associated with Phase II of the development plan is located in a water depth of over 8000 feet and is not located near a “No Activity Zone”. Shuttle Vessels and marine support vessels could cross over “No Activity Zones” but disturbances to these features are not anticipated.



### 11(b) Live Bottoms (Pinnacle Trend) Stipulation Neither the drilling locations nor facilities associated with Phase II of the development plan are located near a Live Bottom (Pinnacle Trend).



### 11(c) Military Warning Area Stipulation The FPSO will be located in WR Block 249 which is approximately 15 miles south of Military Warning Area W92. PAI has and will continue to notify the designated military contact prior to engaging in operations which may cross the W92 Military Warning Area (Shuttle Vessels, marine support vessels, and helicopters).11 Lease Stipulations Information

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Development Operations Coordination Document Cascade / Chinook Development Project 

## 12 Environmental Mitigation Measures Information

Major issues associated with the FPSO and three wells have been addressed in the Initial DOCD and the site-specific Environmental Assessment for a FPSO Facility (USDOI 2008). Impact producing factors associated with two additional wells (Cascade East Development Wells WR 206 No. 6 and 7) in the Cascade Field and their associated jumper connectors would include seafloor disturbances, including physical disturbances to benthic communities from well jumper installation, ocean waste discharges during drilling activities and from shuttle vessels, air emissions, onshore waste disposal, noise from drilling activities, shuttle vessel operations, vessel and helicopter collisions with coastal and marine mammals and birds, respectively and accidental blowout and oil spill. These impact producing factors were considered in the Multiscale EIS (USDOI 2007) and the Deepwater EA (USDOI 2000a). Therefore, site specific analysis of applicable mitigation measures is provided below. As per 30 CFR 250.223 and CFR 250.254 and the information requirements specified in NTL No. 2008-G04, the following applies: a) Florida is not an Affected State. Therefore, information regarding the measures PAI will take to avoid, minimize, and mitigate impacts to marine and coastal resources in the state of Florida is not applicable. b) Incidental takes are not likely with the installation of the two wells and their associated jump connectors in the Cascade Field. No impacts to marine and coastal environments and habitats, biota, and threatened and endangered species occurred during installation of the initial subsea infrastructure or the initial wells. Nonetheless, mitigation measures to avoid and minimize incidental take of threatened and endangered species listed under the ESA and marine mammals under MMPA, as applicable to the proposed work area associated with the two additional wells include: 1) having a good understanding of the ecosystem through site-specific investigations; 2) having knowledge of potential hazards and project activity effects on the ecosystem; 3) early detection through monitoring (see Section 10) of inadvertent releases from either drilling, production, off-loading operations with an understanding of the environmental consequences; and 4) taking a proactive approach to avoid impact.12 Environmental Mitigation Measures Information

Page 12-2 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project c) Site-Specific mitigation measures are as follows: c1. Air Quality Fugitive emissions from equipment/vessels are controlled at potential source using BMPs. Other specific mitigation measures would include use of low-sulfur polluting fuels (diesel or bunker fuel) to reduce SO 2 impacts. If ozone is an issue, undertake NOx control. Consider timing of source emissions to occur during non-peak ozone periods. Consider use of offset or emission credits. Two additional wells in the Cascade Field would be far removed from human population areas. Results of air emission modeling show no significant impact to localized air quality and no mitigation measures are required.
c2. Sea Floor Habitat The results of recent (September 2010) baseline monitoring of the Cascade Field project area show soft bottom in which burrowing infauna are the most abundant. The monitoring summary confirms no impacts or exceedances of EPA thresholds. There is no known hard-bottom in project area of the proposed wells, Cascade East Wells WR 206 No. 6 and 7 or their jumper connector locations. No high density deepwater benthic communities, including chemosynthetic communities, were observed. Impact producing factors to the seafloor habitat would involve drilling activities and installing jumper connector with resuspension of the soft sediments likely. However, impacts from installation of the wells and jumpers will not likely have significant impact due to short duration of construction activities and small aerial footprint and natural distribution of sediments by seafloor currents. Proposed use of a DP vessel to install the wells further reduces the anticipated impact associated with the actions. Rapid burial by sediment accumulation of greater than one foot (30 cm) in thickness would be lethal to those organisms that do inhabit the proposed project area (MMS2008). Accidental spill from a well blowout might rapidly smother infauna. Recolonization is expected however. Dispersal from strong ocean currents could have an effect increasing an impact area should an inadvertent spill occur. The primary concern is habitat alteration during construction/drilling activities and inadvertent spills. Site-specific mitigation measures include:

 Conduct pre-drilling ROV surveys;

 Monitor during and post-drilling (additional ROV surveys); and

 No explosives or anchoring are part of this supplemental activity, therefore no significant impact would occur and no mitigation measure required. PAI completed seafloor mapping of the project area in advance of project installation, ensuring appropriate siting to avoid and minimize potential impacts and hazards associated with the seafloor. As per NTL 2008-G06, PAI will be conducting ROV surveys to assist with site-specific mitigation, as required. Monitoring results conducted12. Environmental Mitigation Measures Information

Petrobras America Inc. Page 12-3 Development Operations Coordination Document Cascade / Chinook Development Project following the successful installation of initial project activities showed no impacts to the seafloor.
c3. Ocean Currents and Movements Installation of the two wells would have no measurable impact on ocean currents and movements. Conversely, PAI has developed hurricane avoidance plans for the FPSO, and for the drilling rigs. No mitigation measure would be required. c4. Water Quality Project: drilling, completing and producing associated with Cascade East Wells WR 206 No. 6 and 7, is located approximately 165 miles (265.5 km) offshore, GoM, in over 8,200 feet (2,446.5 meters) of water depth. Oil Spill Emergency Plans were developed for the FPSO and for the drilling rigs including procedures such as the use of radar, watch standing, and other communication efforts that will minimize the chance of collisions, all of which contribute to water quality protection measures. In coastal waters, the water quality issues identified by Gulf of Mexico Alliance are bacteria-related beach and shellfish bed closures, estuarine hypoxia, harmful algae blooms, and seafood contamination. Existing pollutant sources along the coast include petrochemical plants and refineries. The National Research Council (NRC 2003) estimated that 942 metric tons of oil per year (about 6,600 barrels/year) enter the Gulf from these plants and refineries in Texas and Louisiana. The Mississippi River brings in and additional 525, 60 metric tons (about 3.7 million barrels /year) (NRC 2003). Water quality in the Gulf is further affected by shipping and fishing vessels as well as recreational boaters from bilge water, liquid and solid and leached chemicals from anti-fouling paints (USDOI 2008). Site-specific water quality has been assessed and based on completed sampling to date, no issues were identified. In offshore waters, a zone of hypoxia on the Texas-Louisiana shelf is one of the largest areas of low oxygen in the world (Murray 1998). Phosphorus is the primary source of hypoxia and the proposed project will not contribute additional phosphorus to Gulf water. No significant water quality impacts have been identified in conjunction with the installation of the previous wells. During drilling, limiting drilling fluids use, and /or use of environmentally friendly (biodegradable, non-toxic) fluids would be site-specific mitigation measures. Minimal resuspension of soft bottom sediments associated with drilling activities and installation of the jumper cable should have negligible effect since 1) the existing sediments are not contaminated as per the results of the baseline environmental monitoring report and 2) seafloor currents naturally redistribute these sediments. Other site-specific mitigation measures that PAI will be implementing include the following:

 During operation, PAI will undertake routine monitoring and update spill prevention, control and countermeasures plans, including pre-staging of response vessels and equipment, as applicable.12 Environmental Mitigation Measures Information

Page 12-4 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project  Shuttle vessels, double-hulled and compartmentalized, shall follow good maintenance and housekeeping to avoid oil and other chemical releases offshore, near shore and dockside.

 Adherence to USCG circular NVIC 07-02 guidelines. c5. Hazardous Materials and Waste Management

 PAI has developed hazardous materials and waste management plans addressing transport, use, and storage. These plans incorporate emergency response procedures, including notification requirements.

 PAI minimizes waste with reduction procedures and pollution prevention goals.

 PAI develops and routinely trains staff on spill prevention and response plan.

 Secondary containment will be provided, as applicable.
c6. Acoustic Environment No seismic surveys are a part of activities associated with drilling, completing and producing additional wells in the Cascade East Field development. Therefore, no mitigation measures are required.
c7. Marine Mammals Potential impacts to marine mammals include noise, water quality degradation, vessel collisions, inadvertent oil spills, spill-response activities, trash and debris. These potential impacts would be the same for non T&E species of concern. PAI will implement the following measures to minimize impacts to marine mammals.

 Avoid shuttle vessel strikes by adhering to guidance in NTL 2003-G10 “Vessel Strike Avoidance and Injured/Dead Protected Species Reporting”;

 Avoid known important cetacean congregation areas, mating and/or feeding areas;

 Reduce speeds when marine mammals are present and maintain safe distance;

 Coordinate w/NMFS and USFWS and follow NMFS Regional Viewing Guidelines; and

 Consider having at least one qualified marine mammal observer present during construction activities.
c8. Marine and Coastal Birds Proposed activities are located over 180 miles (290 km) offshore in the GoM. Other than transient individuals, the project area is not expected to be in a high use area. Shuttle vessels from the FPSO to existing ports will use existing shipping lanes. Based on the minimal impact expected, no mitigation measures are required.12. Environmental Mitigation Measures Information

Petrobras America Inc. Page 12-5 Development Operations Coordination Document Cascade / Chinook Development Project c9. Fish Resources and Essential Fish Habitat The description of Essential Fish Habitat (EFH) has been revised as per Generic Amendment #3 to the Gulf of Mexico Fishery Management Plan. The habitats most important for managed fish species are those in shallow, less than 100 fathoms of water. The proposed project is in over 8,200 feet (2,500 meters) of water depth and is no longer in a blanket designation of EFH. The project area does retain EFH designation for some specific species: shark, tuna, swordfish, and sailfish. The benthic fish population within the project site is very low in density and restricted to species that live below 8,200 feet (2,508 meters), primarily oceanic bathypelagics. In the water column above the seafloor of the project site, fish species may include oceanic pelagic and mesopelagics (see Section 19(b)8). Shuttle vessels will utilize existing commercial shipping lanes in shallower water areas. Principal impacts would be temporary disturbance during construction /well drilling of any bottom foraging and inadvertent oil spills. To minimize impacts to fish resources and EFH, PAI will:

 Conduct surveys and monitoring during the installation of the proposed Cascade wells and associated jumpers; and

 Adhere to NMFS accepted EFH Conservation Recommendations including the recent six additional recommendations.
c10. Sea Turtles Sea turtles are found throughout the GoM. Based on the depth of water that the Cascade East Field is located in, only sea turtles in the project area would be considered transient, either migrating through the area, or foraging. Shuttle vessels will be using existing shipping lanes into existing port facilities, which will minimize potential impacts in the richer shallow water habitats of the GoM. To minimize impacts to sea turtles, PIA is implementing the following measures:

 No facilities are located in known nesting/hatching locations;

 Shuttle vessels will use existing commercial shipping lanes near shore;

 Floating Sargassum out at sea will be avoided;

 No explosives are part of proposed project activities;

 Because spilled oil, chemical dispersants, and spill-response activities may adversely affect sea turtles or their reproductive success, PAI will conduct visual surveys and contain spilled oil;

 Shuttle vessels will adhere to NMFS Regional Viewing guidelines while in transit and vessel operators will undergo training on applicable guidelines to avoid strike impacts; and

 PAI prohibits discharging trash and other debris at sea as it could ensnare or be consumed by sea turtles thus injuring or killing them.12 Environmental Mitigation Measures Information

Page 12-6 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project c11. Coastal Habitats The project is located over 180 miles (290 km) from the nearest coastline, which is Louisiana. Lengthy spill travel times and large dilution factor into the significant dispersion of an accidental spill prior to reaching a coastline from the proposed Cascade East wells. As required under NTL 2010 N-06, PAI has completed worst case oil spill discharge evaluation. (see Appendix 6). No new navigation channels would be required for this project. Primary potential impacts to coastal habitats would be from shuttle vessel traffic and inadvertent spills since onshore facilities are existing facilities. No onshore, or near shore, construction activities are part of the proposed Cascade East Field drilling, completion and production, therefore no impacts or mitigation measures are required. Based on the worst case scenario modeling, an accidental spill could make landfall along the coastline. As indicated in this section, PAI implements a series of mitigation measures to minimize potential impacts to both onshore and offshore environments. In addition to field development, discharges from shuttle vessels en route to Texas, Louisiana, and Mississippi could also potentially impact coastal habitat. Shuttle traffic associated with the project would not significantly increase the volume of traffic into existing ports and anticipated impacts would be similar to existing commercial tanker and other vessel traffic. Sensitive coastal habitats include beaches and dunes and barrier islands. A large scale inadvertent oil release at the well site would take 30 days to travel to beaches and islands as per oil spill risk analysis undertaken for the FPSO (USDOI 2008). These areas of natural resources and the protection of them are extremely important to PAI and mitigation measures would include monitoring and installation of containment booms. As per MMS 2008, a study in Texas showed oil spilled on sand and vegetated dunes had little deleterious effects on existing vegetation (Webb 1988). Spilled oil beyond 0.025 gallon/ft 2 (1.0liter/m 2 ) of marsh was found to cause vegetation death and therefore land loss. Additionally, impacts from oil spill clean-up activities could result in short-term (up to two years) adjustments to beach profiles and configurations (USDOI 2008). In light of the tragic events surrounding the Deepwater Horizon incident, spill and clean up activities, it is suspected that the potential long term effects will be studied for years to

come. Coastal wetlands, particularly in Louisiana, already are greatly impacted by sediment deficiencies, sea level rise, and subsidence and are further damaged by recent hurricanes. Deterioration of coastal wetlands is a serious concern at local, state and federal levels. Distance from the well site to the closest Louisiana coastal marshes is 180 miles (290 km), thus providing significant time and opportunity for response, adequate control of an inadvertent spill, and implementation of suitable mitigation measures. Seagrass beds, another sensitive coastal habitat are located behind barrier islands. Therefore, likelihood of impact from an inadvertent oil spill is low. Nonetheless, as demonstrated during the Deepwater Horizon accident, these sensitive resources are12. Environmental Mitigation Measures Information

Petrobras America Inc. Page 12-7 Development Operations Coordination Document Cascade / Chinook Development Project susceptible to impacts. Specific mitigation measures that PAI would implement include avoidance through use of containment booms and dispersants before oil reaches shore and any seagrass beds. The following mitigation measures would be implemented to minimize potential impacts from shuttle vessel traffic or inadvertent spills:

 Constant monitoring of site activities to identify a potential problem so that it can be addressed early;

 To reduce shuttle vessel traffic effects, recommend of reduced speeds in vicinity of barrier islands; and

 In the case of an inadvertent spill, minimize spill clean-up impacts with low impact response technologies, i.e. low-pressure flushing, containment booms, bioremediation, burning, open water dispersants as applicable (Mendelssohn and Lin 2003, Hoff 1995, Proffitt 1998) and specified in PAI’s Oil Spill Response Plan. c12. Areas of Special Concern Areas of Special Concern include marine protected areas. The proposed project is not located in or near a marine protected area. However, the GoM is considered an area of special concern. As such, a principal impacting factor would be a significant inadvertent spill. Fate of hydrocarbons in the GoM is largely uncertain (Ramseur 2010) following BP’s Deepwater Horizon oil spill of 200 million gallons (4.9 million barrels) of crude oil. According to a Congressional Research study, the fate of spilled oil was as follows: human intervention (direct recovery 17%; in-situ burning 5%; skimming 3%; chemical dispersal 16%), natural processes (natural dispersal 13%; evaporated or dissolved 24%), and other 22% remaining in the water column, settling to the seafloor, mixing with sediments, ingested by microbes, or collected during shore clean-up activities. Oiled shorelines (classified as light, moderate, or heavily oiled) were estimated to extent approximately 700 miles in Louisiana, Mississippi, Alabama, and Florida. According to studies following the 1979 Ixtoc oil spill, approximately 25% of that oil settled on the bottom of the GoM. This is consistent with the preliminary information developed following the Deepwater Horizon oil spill (Ramseur 2010). The primary mitigation measure that PAI will implement will be avoidance of situations that could lead to inadvertent spills. In the event that a spill does occur, PAI will use the following industry wide recognized site-specific mitigation measures, as appropriate, to address inadvertent spills:

 Monitoring;

 Response teams and equipment in place prior to an incident;

 Rapid response of OSROs;

 Direct recovery;

 In-situ burning;12 Environmental Mitigation Measures Information

Page 12-8 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project  Dispersants; and

 Drilling a relief well. Based on the successful completion of other wells within the nearby Cascade and Chinook Fields, PAI would maintain that the risk of a significant oil spill is low.
c13. Tourism and Recreation The GoM supports diverse and valuable commercial and recreational fisheries; beaches, wetlands and barrier island natural resources that support local and state-wide tourism economics and recreational opportunities for the public. Primary concern to tourism and recreation is effects from inadvertent spill that could cause 1) change in fish distribution and abundance; 2) reduced catches of finfish and shellfish; 3) inability to access fishing areas; 4) loss/damage to fishing equipment; 5) reduced market value of a fishery, i.e. public perception of contamination; and 6) beach damage (real or perceived). Mitigation would include measures indicated in c12 above and public education program. c14. Shipping and Transportation No port modifications are required as part of the proposed project. PAI will be using existing ports that currently accommodate commercial traffic and no additional facilities or facility expansions are required for this project. Shuttle vessels would use existing shipping lanes and no modifications to shipping would be required. Therefore, no mitigation is required.Petrobras America Inc. Page 13-1

Development Operations Coordination Document Cascade / Chinook Development Project 

## 13 Decomissioning Information

Per NTL 2008-G04, decommissioning information is not required for DOCDs in the BOEM GoM region.13 Decommissioning Information

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## 14 Related Facilities and Operations Information
14(a) Related OCS Facilities and Operations This section provides an overview of the drilling unit, topside, subsea facilities, and pipelines. Section 2(e) describes any applicable technologies that would be used during Phase II which are considered new or unusual to the GoM in more detail. Section 1(f) describes the most important safety and pollution prevention features of the facilities covered by this supplemental DOCD. No new technology is proposed in this supplement however; the Conceptual Plan and the Initial DOCD, both previously approved by the BOEM identified six components of the Phase I development plan that are considered technologies new to the GoM. These six components were addressed extensively in the Initial DOCD as well as the DWOP. BOEM Technical Assessment and Operations Support (TAOS) Section reviewed and approved the safety and reliability of the technologies new to the GoM in the approved DWOP (ref. Appendix 1a). There are no significant changes to the information previously submitted regarding new or unusual technologies and the information remains accurate and consistent. The most important safety and pollution prevention features that will be used to mitigate hazards related to technologies new to the GoM are described in Section 1(f).

Drilling Rigs Phase I included the drilling and completion of three new wells. Two of these Phase I wells have been drilled and completed, one in the Cascade Field and one in the Chinook Field. The second well in the Cascade Field is currently being drilled as part of Phase I. Phase II includes drilling and completion of the remaining wells in Cascade being the subject of this SDOCD. Cascade WR 206 Wells No. 6 and 7 will be directionally drilled from Drill Center 1, cased, and completed with multi-zone frac-pacs. PAI and its vendors have successfully run a Single Trip, Multi-Zone (STMZ) Frac Pack assembly in the first two wells, and this is also new technology in the DW GoM. Although there are some well engineering challenges due to reservoir characteristics, the majority of the well engineering utilizes proven practices. Primary Rig The “Deep Ocean Mendocino” (Mendocino) is scheduled to drill the next two Cascade wells WR 206 Well No. 6 and 7 upon completion of Cascade Well No. 5. It is a new build (2011) drill ship from Samsung in Korea, and is equipped with lifesaving equipment to accommodate 200 personnel and has gas, fire, and smoke detection systems, which are monitored on a 24-hour manned basis. The rig has fixed fire fighting equipment including carbon dioxide foam flooding. The rig has a sump system to catch14 Related Facilities and Operations Information

Page 14-2 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project all deck drainage. Rig personnel will follow PAI and Mendocino (Contractor) offshore HSE policies. Safety features include well control, pollution prevention, welding procedures, and blowout prevention equipment as described in 30 CFR 250, including NTL-06, as incorporated in the CFR’s. The drilling rig will comply with all BOEM, USCG, and EPA requirements for operating in the GoM. See Figure 14-1 to see an artist rendition of the “Mendocino”.

Figure 14-1 – Deep Ocean “Mendocino”

Optional Rig The Vantage “Dragon Quest” (Dragon Quest) could potentially drill the Cascade WR 206 Wells No. 6 and 7, if the operations window and exact timing does not permit the Mendocino to begin first. The Dragon Quest, which will be on site at the Chinook Field, is a Daewoo new build (2011) drill ship, capable of operating in 12,000’ of water depth, and up to 40,000’. PAI has made a long term commitment to the GoM projects by contracting one the largest capacity drillships in the world. The Dragon Quest is equipped with lifesaving equipment to accommodate up to 180 personnel and has gas, fire and smoke detection systems, which are monitored on a 24-hour manned basis. The rig has fixed fire fighting equipment including a CO 2 foam flooding

. The rig has a sump14 Related Facilities and Operations Information

Petrobras America Inc. Page 14-3 Development Operations Coordination Document Cascade / Chinook Development Project system to catch all deck drainage. Rig personnel will follow PAI and Vantage (Contractor) HSE policies, and a bridging document will be written for the rig. Safety features include well control, pollution prevention, welding procedures, and blowout prevention equipment as described in 30 CFR 250, including NTL-06 as incorporated in the CFR’s. The drilling rig will comply with all BOEM, USCG, and EPA requirements for operating in the GoM. See Figure 14-2 to see the Vantage “Dragon Quest”.

Figure 14-2 – Vantage “Dragon Quest”

Subsea Facilities and Pipelines / Risers Subsea facilities were installed during Phase I of the development plan including drill centers at Cascade and Chinook. With the exception of the FSHRs and subsea booster pumps, the Cascade and Chinook subsea facilities use field proven designs that have been extensively used in deepwater projects in the GoM. The FSHRs and subsea booster pumps are discussed in greater detail in Section 2(e) as they were considered technology new to the GoM by BOEM. See Figure 1-2 to review a conceptual representation of the subsea facilities and associated pipelines and risers. Figure 14-3 provides an illustration which summarizes the subsea facilities and associated pipelines and risers. See Figure 1- 3 to review the Field Layout.14 Related Facilities and Operations Information

Page 14-4 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Figure 14-3 – Illustration of Subsea Facilities Layout

Cascade consists of one drill center in Cascade East located in WR Block 249. The Cascade drill center is in approximately 8,200 feet of water. The Chinook drill center is in approximately 8,800 feet of water. Production from all Cascade wells will be gathered into a 4 slot manifold and transported via 7” flowlines and two production FSHRs. Production from Cascade is enhanced by 2 skid mounted booster pumps which are located downstream of the Cascade gathering manifold. Each pump is capable of boosting 20,000 bpd for a total of 40,000 bpd. Dual flowlines will allow for round trip pigging. The Cascade production flowlines are wet insulated for flow assurance considerations. Cascade will utilize PLETs and jumpers for subsea connectivity. Cascade will be powered and controlled by one power umbilical and one control umbilical (with flying leads) originating from the FPSO. See Figure 14-4 Cascade Drill Center. FPSO

Boosting Station

4

- Slot Manifold

Produc tion Well Production FSHR Gas Export FSHR Approx 11.5 Mi.

Approx 2 Mi. Approx 1.3 Mi. Gas Export Line

Cascade East DC WR Block 206 X = 2,458,390.33’ Y = 9,712,448.4’ WD approx. 8,160’ FPSO WR Block 249 X = 2,453,797.74’ Y = 9,695,007.17’ WD approx. 8,200’ Chinook DC WR Block 425 X = 2,447,000.00’ Y = 9,632,800.00’ WD approx. 8,800’

Infield Flowlines14 Related Facilities and Operations Information

Petrobras America Inc. Page 14-5 Development Operations Coordination Document Cascade / Chinook Development Project Figure 14-4 – Cascade Drill Center14 Related Facilities and Operations Information

Page 14-6 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project The FPSO is double hulled with segregated cargo and ballast tanks. The FPSO has a cargo tank capacity of 600,000 – 850,000 barrels. The FPSO has a single point mooring (SPM) system which allows for full passive weathervaning. The SPM has a disconnectable feature which allows her to disconnect and motor away from named storms and hurricanes under her own power, returning for re-connection when it is safe to do so. The FPSO was designed to remain on station for 1.) a 100 year return winter storm with a 1 year return loop current or 2.) a 100 year return loop current with a 1 year return winter storm. The FPSO will disconnect for named storms and hurricanes, with no hydrocarbon release to the environment. After disconnection, the turret buoy (which is attached to the mooring lines and FSHRs) will be left behind in a submerged condition out of harms way of the environment conditions at the surface. See Figure 1-2 for a conceptual representation of the FPSO connected to the seafloor facilities. Table 14-1 describes the design capacities of that the FPSO will be able to accommodate:

Table 14-1 – FPSO Topsides Design Parameters

Capacity Minimum Maximum Oil 3,000 bpd 80,000 bpd Produced Water 0 bpd 16,000 bpd Total Fluids 3,000 bpd 80,000 bpd
Gas 16 MMscfd 16 MMscfd

In accordance with 30 CFR 250 Subparts H and J and the approved DWOP, the flowline / pipeline boarding shut down valve(s) (BSDV) will close within 45 seconds of the activation of any sensor due to any undesirable event or emergency shut-down (ESD). The FPSO complies with all requirements for continuous operation throughout Phase II without the need to be dry-docked in a shipyard. The FPSO is discussed in greater detail in the Initial DOCD and DWOP as it was considered technology new to the GoM by BOEM at that time. 

### 14(b) Transportation System The development plan utilizes a 6-inch gas export pipeline to transport gas (maximum of 16 MMscfd) which is not consumed on the FPSO to the existing Discovery gas pipeline system, Operations System 34.5/DSO, which in turn terminates onshore in Larose, Louisiana.14 Related Facilities and Operations Information

Petrobras America Inc. Page 14-7 Development Operations Coordination Document Cascade / Chinook Development Project 

### 14(c) Produced Liquid Hydrocarbon Transportation Vessels The development plan calls for utilization of dedicated Shuttle Vessels to transport produced oil to market. Shuttle Vessels will Jones Act and OPA90 compliant tankers. The capacity of each Shuttle Vessel is approximately 330,000 bbls. PAI will likely utilize one Shuttle Vessel to perform one offloading every two weeks in the first year of production operations (i.e. during production ramp-up). PAI will likely utilize two Shuttle Vessels (on a staggered schedule) to perform one offloading every week in subsequent years of production operations for Phase II. The frequency of offloading will evolve over time as the frequency is driven by the size / speed / number of the Shuttle Vessels relative to the production profile of the reservoirs. Offloading from the FPSO to the Shuttle Vessel will take approximately 24 hours. See Table 14-2.

Table 14-2 – Shuttle Vessel Transportation Information

Transport Method Shuttle Vessel Capacity (barrels) Average Volume to be Loaded (barrels per offloading) Anticipated FPSO Offloading per Year

One Shuttle Vessel (Year 1) 185,000 - 330,000 185,000 – 330,000 26

Two Shuttle Vessels (Years 2 through end of Phase II) 185,000 - 330,000 185,000 – 330,000 52

During offloading, Shuttle Vessels will be connected to the FPSO via a hawser system (i.e. mooring line) and offloading hose between the bow of the Shuttle Vessel and the stern of the FPSO in a tandem offloading configuration. The Shuttle Tanker will weathervane in a similar manner as the FPSO (i.e. both vessels will react to the environmental conditions as one “system”). A dedicated field support tug will be utilized to support offloading. Shuttle Vessels will transport produced oil to the terminals of choice along the GoM coast, potentially including terminals in Texas, Louisiana, and Mississippi. PAI has not yet determined which specific terminals will be used. PAI is currently evaluating which terminals may be used based on the following considerations:

 quality of produced oil relative to the processing capability of terminals (1)

 vessel size limitations (1)

 terminal capacities (2)

 commercial (2)14 Related Facilities and Operations Information

Page 14-8 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Notes: (1) assessment made by PAI during the planning phase (2) assessment made by PAI just prior to each offloading There will not be a need to expand or modify any terminals to accommodate transportation of oil to market via Shuttle Vessels. Figure 14-5 provides the locations of the terminals that PAI is considering.14 Related Facilities and Operations Information

Petrobras America Inc. Page 14-9 Development Operations Coordination Document Cascade / Chinook Development Project Figure 14- 5 Potential Terminals under ConsiderationPetrobras America Inc. Page 15-1

Development Operations Coordination Document Cascade / Chinook Development Project 

## 15 Support Vessels and Aircraft Information
15(a) General Table 15-1 provides an overview of the equipment that PAI anticipates using for drilling and completion operations during Phase II of the development plan. PAI anticipates approximately 18 months of drilling and completion operations during Phase II. Support vessels include crew boats and service vessels. Table 15-1 – Support Equipment (Drilling and Completions Operations)

Type Maximum Fuel Tank Storage Capacity (barrels) Maximum Number

in Area at Any Time Trip Frequency
or Duration Drilling Rig (DP) 34,500 1 18 months Crew Boat / Fast Supply Vessel (FSV) 800 2 3 round trips per week

Offshore Service Vessel (PSV) 8,900 3 2 round trips per week

Helicopter 22 1 1 round trip per day
Table 15-2 provides an overview of the equipment that PAI anticipates using for FPSO production operations during Phase II of the development plan. PAI anticipates 6- 8 years of production operations during Phase II.

Table 15-2 - Support Equipment (FPSO Production Operations)

Type Maximum Fuel Tank Storage Capacity (barrels) Maximum Number

in Area at Any Time Trip Frequency
or Duration
Crew Boat / Fast Supply Vessel (2) 550 2 3 round trips/week (2)

Offshore Service Vessel (2) 8,900 3 2 round trips/week (2) Field Service Tug (1) 8,900 1 100% in field (1) Helicopter (3) 22 1 2 round trips per day (3)

(1) Offloading and general marine support (2) PSV’s and FSV’s will be shared between the FPSO and drilling (3) Helicopter will be shared between the FPSO and drilling. However, the FPSO will have 2 round trips per day 

### 15(b) Diesel Oil Supply Vessels Table 15-3 provides an overview of the diesel oil supply vessels PAI anticipates using for drilling / completion operations and FPSO production operations.15 Support Vessels and Aircraft Information

Page 15-2 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Table 15-3 – Diesel Oil Supply Vessels

Size of Fuel Supply Vessel Capacity of Fuel Supply Vessel (barrels) Frequency of Fuel Transfers Route Fuel Supply Vessel Would Take

280’ Class Offshore Service Vessel (1, 2, 3) 8,900 2 round trips per week Port Fourchon to
Cascade / Chinook Units and return
280’ Class Offshore Service Vessel (1, 2, 3) 8,900 2 round trips per week Port Fourchon to
Cascade / Chinook Units and return
280’ Class Offshore Service Vessel (1, 2, 3) 8,900 2 round trips per week Port Fourchon to
Cascade / Chinook Units and return (1) Supports Drilling and Completion operations for approximately 18 months (2) Supports FPSO Production Operations for 6-8 years (3) Supports diesel oil supply. Also brings other supplies to the drilling and FPSO operations area. 

### 15(c) Drilling Fluids Transportation Florida is not an Affected State for Phase II of the development plan. Per NTL 2008- G04, information regarding drilling fluids transportation is not required in this DOCD. 

### 15(d) Solid and Liquid Wastes Transportation Appendix 7-C provides an overview of the projected generated waste types, their composition, and transportation methods PAI anticipates will be used for anticipated amounts of solid and liquid wastes associated with drilling and completions operations. Applicable onshore facilities per waste type for disposal is also provided in Appendix 7- C. PAI anticipates approximately eighteen months of drilling and completion operations during Phase II. Appendix 7-D provides an overview of the projected generated waste types, their composition, and transportation methods PAI anticipates will be used to transport the anticipated amounts of solid and liquid wastes associated with FPSO production operations to onshore facilities for disposal. Applicable onshore disposal facilities are also identified for FPSO wastes in Appendix 7-D. PAI anticipates approximately 6-8 years of FPSO production operations during Phase II. 

### 15(e) Vicinity Map Figure 15-1 shows the location of the Phase II facilities at the Cascade and Chinook Fields, the distance of the proposed Cascade activities from the shoreline, and the primary transportation route(s) of the support vessels and aircraft that would be used when traveling between the primary and secondary onshore service bases and the FPSO.Petrobras America Inc. Page 15-3

Development Operations Coordination Document Cascade / Chinook Development Project Figure 15-1 – Vicinity Map15 Support Vessels and Aircraft Information

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Development Operations Coordination Document Cascade / Chinook Development Project 

## 16 Onshore Support Facilities Information
16(a) General PAI proposes to use onshore support facilities located in Port Fourchon, Louisiana to support Phase II of the development plan. The name of the facilities are identified in Table 16-1. These are existing facilities.

Table 16-1 – Onshore Support Facilities

Name Location Existing, New, or Modified C-Port 2, Slips 5 & 6 Port Fourchon, LA Existing ERA Port Fourchon, LA Existing

The marine shorebase is equipped with facilities related to warehouse and outside storage spaces, material handling equipment, marine vessel dock space, fuel storage and bunkering, water storage and bunkering, drilling fluids storage and bunkering, communications, security, offices, and vehicle parking lot. The aviation facilities are equipped with a helipad, office space, waiting room, and vehicle parking lot. PAI anticipates that secondary onshore support facilities in Texas and Louisiana may be used on occasion due to specific conditions such as weather, market availability of marine vessels or helicopters, security, and / or safety. 

### 16(b) Support Base Construction or Expansion PAI will utilize an existing onshore support base with adequate facilities to support operational needs for Phase II of the development plan. No base construction or expansions will be required. 

### 16(c) Support Base Construction or Expansion Timetable Per 16(b), no construction or expansion activities will be performed for Phase II of the development plan. 

### 16(d) Waste Disposal Appendix 7-C depicts the onshore facilities that PAI anticipates using to dispose of solid and liquid wastes associated with drilling and completion operations during Phase II of the development plan. Appendix 7-D also depicts the onshore facilities that PAI anticipates utilizing to dispose of solid and liquid wastes associated with FPSO production operations during Phase II of the development plan.16 Onshore Support Facilities Information

Page 16-2 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project 

### 16(e) Air Emissions Per NTL 2008-G04, information regarding air emissions generated by onshore support facilities is not required for DOCDs submitted in the BOEM GoM region. 

### 16(f) Unusual Solid and Liquid Wastes Per NTL 2008-G04, information regarding unusual solid and liquid wastes generated by onshore support facilities is not required for DOCDs submitted in the BOEM GoM region.Petrobras America Inc. Page 17-1

Development Operations Coordination Document Cascade / Chinook Development Project 

## 17 Sulfur Operations Information

No sulfur operations are proposed as part of the Phase II (or future phases) of the development plan.17 Sulfur Operations Information

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Petrobras America Inc. Page 18-3 Development Operations Coordination Document Cascade / Chinook Development Project 

## Louisiana Coastal Resources Program

In 1978, the Coastal Management Division (CMD) of the Louisiana Department of Natural Resources implemented the Louisiana Coastal Resources Program (LCRP) under authority of the State and Local Coastal Resources Management Act, as amended (Act 361, Louisiana Revised Statute Title 49 Section 214). The law provides for the review of federally permitted actions that could potentially impact Louisiana’s coastal resources. The intent of the LCRP is to protect, develop, and where feasible, restore or enhance the resources of the state’s coastal zone. The LCRP encourages multiple uses of resources and adequate economic growth in order to reduce adverse effects of one resource upon another. Program regulations can be found in Louisiana Administrative Code, Title 43 Part I Chapter 7. As described more fully in this supplemental DOCD, Petrobras America Inc. (PAI) proposes to develop two wells, WR 206 No.6 and 7 with one jumper connector per well in the Cascade deep water field. The Cascade Field and the associated Chinook Field developments were previously addressed in a common DOCD submittal with an accompanying coastal consistency certificate in June 2007. At that time, the Floating Production, Storage and Offloading (FPSO) facility was addressed. Specific details related to the proposed offshore development activities associated now with two additional wells and jumper connectors can be found in Section 1. This supplemental DOCD specifically addresses project activities in the Cascade East Development. The project is located in the Central Planning Area of the Gulf of Mexico in Walker Ridge Block 206 approximately 165 miles from the coast of Louisiana as shown in Figure 1-1. Because of its location in the Central Planning Area, Louisiana is considered to be an “affected state” and the state’s review and concurrence is required to ensure that the proposed activities are consistent with the enforceable policies of the LCRP. The Cascade / Chinook Development, including the drilling, completion and production of the proposed WR 206 Wells No.6 and 7 will include the use of existing onshore support facilities at Port Fourchon for marine vessel support and disposal of wastes (see Figure 15-8). Port Fourchon will serve as the port of debarkation for equipment, supplies, and crews for drilling / completion operations, development activities, and production operations. No new construction or expansion of Port Fourchon’s facilities will be necessary. No new dredging or changes to Louisiana’s coastal areas or shipping channels would be needed. Refer to Section 16 for additional details. The following is a list of shore-based facilities in Louisiana that would be used for the projected wastes associated with the Cascade East Development WR 206 Wells No. 6 and 7:

 US Liquids of Louisiana, Newpark Services, and / or CCT located in Fourchon. These contractors will accept environmental wastes such as cutting boxes, solid wastes from the marine portable tanks, and tank clearing fluids.18 Coastal Zone Management Act (CZMA) Information

Page 18-4 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project  Solid Waste Disposal or Galiano Waste located in Fourchon. These contractors will accept the disposal of domestic wastes.

 L&L located in Fourchon. This contractor will accept waste oils. As described in Section 14(c), PAI will charter Shuttle Vessels to deliver the produced oil to market to terminals along the coast of the GoM. After the initial production ramp-up in thefirst year of operations, PAI anticipates an offloading frequency of once per week during sixeight years of production operations for Phase II of the development plan. PAI has not yet determined which specific terminals will be used. However, PAI anticipates using several refineries located in Louisiana (see Figure 14-8). The specific refineries to be utilized will depend on several factors including market conditions and available terminal capacities. The Louisiana refineries that could potentially be used are shown below. This list includes the ranking of each refinery in Louisiana compared to all US refineries relative to their daily crude operating capacity as of January 2008 (Energy Information Administration 2011).

Lake Charles

 Citgo Petroleum, Lake Charles (#4)

 ConocoPhillips, Westlake (#22)

 Calcasieu Refining, Lake Charles (#110)

Baton Rouge

 ExxonMobil, Baton Rouge (#2)

 Motiva Enterprises, Convent (#25)

 Placid Refining, Port Allen (#94)

Lower Mississippi River

 ConocoPhillips, Belle Chasse (#18)

 Marathon Petroleum, Garyville (#20)

 Motiva Enterprises, Norco (#27)

 Chalmette Refining, Chalmette (#34)

 Valero Refining, Norco (#35)

 Murphy Oil, Meraux (#56)

 Shell, Saint Rose (#96) Louisiana Offshore Oil Port (LOOP)

 The LOOP eventually connects to pipelines that can transport crude oil to 35% of the total US refining capacity.18 Coastal Zone Management Act (CZMA) Information

Petrobras America Inc. Page 18-5 Development Operations Coordination Document Cascade / Chinook Development Project No new construction or expansion of these terminals will be necessary. No new dredging or changes to Louisiana’s shipping channels will be needed. PAI has evaluated the anticipated activities related to the proposed wells and their associated jumper connectors to determine if there would be any reasonably foreseeable coastal effects on the land, water uses, or natural resources of the coastal zone of Louisiana, pursuant to the enforceable policies of the state’s LCRP. Specific policies that address the potential environmental impacts to coastal uses, such as waste disposal, accidental spills, and nearshore water quality, are briefly described in Table 18-1 with relevant cross references to this supplemental DOCD where further details are provided. The analysis upon which this effects determination has been made is provided in Section 19.

Table 18-1 – Consistency Review Summary
Policy Effects Analysis Cross References Guidelines Applicable to All Uses

Policy 1.2 – Conformance with applicable air and water quality laws  The project site will be located at least 165 miles from the Louisiana coast.

 The air emissions analysis shows that the project will not exceed emission thresholds established by BOEM. The project will not affect air resources in Louisiana.

 No air or water quality impacts will occur because of the use of existing support base and refineries that are located at established ports. Wastes will be properly contained, transported, and disposed in designated waste facilities.

 The project will comply with all requirements including the US Environmental Protection Agency (EPA) National Pollutant Discharge Elimination System (NPDES) general permit for offshore discharges and US Coast Guard (USCG) regulations for vessels operating in state waters. The project would not affect water quality in Louisiana.

 The use of a gas export pipeline at the beginning of production would provide a positive environmental effect because no flaring would occur during normal production operations. Short term flaring (several days per well) would likely occur during the well testing phase but this would not affect near shore resources. Section 7, Appendix 7_A, B, C and D Projected Generated Discharged and Trasported Wastes

Section 8, Air Emissions

Appendix 3, Air Emission Worksheets

Sections 19(b), Existing Resource Conditions and 19(c), Project Impacts18 Coastal Zone Management Act (CZMA) Information

Page 18-6 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Policy Effects Analysis Cross References

Policy 1.6 - General factors that will be utilized by the permitting authority  No state permits are required for the project.

 The FPSO will be able to disconnect from its mooring and motor away from a hurricane or named storm, which will prevent storm related damages or accidents and reduce the potential for impacts to coastal resources.

 The direct and indirect expenditures of the project will have a minor and temporary positive impact on the economic activities around the support facilities at Port Fourchon, which would provide direct private benefits.

 The project area is not located in or near nor would have any impacts on historical or recreational sites, or protected / sensitive areas.

 No impacts to state fisheries are likely due to the distance from shore and the use of existing transportation and shore based infrastructure. Sections 1(a), Introduction; 1(c), Safety and Pollution Prevention Features; and 1(f), Additional Safety and Pollution Prevention Features

Section 2(e), New or Unusual Technology

Sections 19(b), Existing Resource Conditions and 19(c), Project Impacts

Policy 1.7 - Adverse effects from land and water uses in the coastal areas  All of the wastes generated from the proposed development will be either (1) discharged overboard in compliance with NPDES requirements or (2) transported to shore for disposal in permitted or licensed commercial facilities or for recycling. All wastes brought to shore will be properly disposed so there would be no effects to the coastal area.

 Minor, localized impacts to federal OCS waters near the project site will occur during the life of the project as a result of the proposed discharges from drilling and production activities but the effects are expected to be minimal because the project will comply with NPDES requirements. There will be no effects to the coastal area.

 Insignificant impacts related to the burial of soft-bottom benthic communities are expected from the discharge of drill cuttings. There will be no effects to the nearshore coastal areas.

 Short term turbidity will result from bottom disturbances caused by placement of two wells and two jumper connectors. There will be no effects to land and water uses in the coastal
area.

 No impacts on chemosynthetic fauna are expected because chemosynthetic communities or hard-ground substrates are not present.

 No federal or state listed species are known to occur in proximity to the proposed well sites.

 This project would have no effects on minority or low income populations in Louisiana. Section 6(a), Chemosynthetic Communities Section 7, Projected Wastes

Section 9(a), Oil Spill Response Planning

Section 16(a) Onshore Support Facilities

Section 19(c), Project Impacts18 Coastal Zone Management Act (CZMA) Information

Petrobras America Inc. Page 18-7 Development Operations Coordination Document Cascade / Chinook Development Project Policy Effects Analysis Cross References Policy 1.9 – Permitting multiple uses to avoid conflicts There will be no conflicts with other users because existing shore based and transportation infrastructure will be used. Section 15, Support Vessels and Aircraft Information

Section 16(a), Onshore Support Facilities Guidelines for Linear Facilities (Policies 3.1 through 3.16) – The project does not involve the construction of linear facilities in or near the coastal zone. The gas export pipeline will tie into an existing facility located on either Green Canyon Block 829 (Option 1) or Green Canyon Block 606 (Option 2; See Section 6(a), Chemosynthetic Communities Report). Guidelines for Dredged Spoil Deposition (Policies 4.1 through 4.7) - This project does not involve any expansion of facilities or new dredging (See Section 16, Onshore Support Facilities Information). Guidelines for Surface Alterations (Policy 6.1) – The project will use only existing shore based support and waste disposal facilities and will not involve any surface alterations (See Section 15(d), Solid and Liquid Wastes Transportation and Section 16, Onshore Support Facilities Information). Guidelines for Hydrologic and Sediment Transport Modifications (Policies 7.1, sediment diversions; 7.3, deposition of sediments; and 7.9, water withdrawal) – The project will use desalination units to generate the needed freshwater at the project site (See Section 7, Waste and Discharge Information). Guidelines for Disposal of Waste Policy Effects Analysis Cross References

Policy 8.1 - Location and operation of waste storage, treatment, and disposal facilities  Solid waste generated by the development activities will be bagged and kept onboard the FPSO and drilling rig, then transported via supply boat to a designated contractor in Louisiana for proper disposal in Port Fourchon.

 Sanitary wastes on each of the vessels will be treated by a Marine Sanitation Device and discharged overboard in accordance with USCG regulations.

 Other waste streams from the FPSO and drilling rig will be discharged overboard in accordance with the NPDES general permit.

 Trash and debris and other waste products will be brought to a designated contractor in Louisiana for proper disposal.

 Other wastes consisting of waste oil will be stored in barrels, transported to shore, and then disposed of by a designated contractor in Louisiana. Section 7(a), Appendix 7- A-D Projected Wastes

Section 15(d), Solid and Liquid Wastes Transportation

Section 16, Onshore Support Facilities Information

Policy 8.1 – Generation, transportation, treatment, storage, and disposal of hazardous waste Only oil field wastes would be generated as a result of this project and these would be disposed in an authorized waste facility. Section 7, Appendix 7- A-D Waste and Discharge Information Section 15, Support Vessels and Aircraft Information Section 16(d), Waste Disposal Facilities18 Coastal Zone Management Act (CZMA) Information

Page 18-8 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Policy Effects Analysis Cross References Policy 8.8 - Approved disposal sites No unusual solid or liquid wastes will be generated or disposed. Only existing and approved onshore waste disposal facilities would be used. No air or water quality impacts would occur as a result. Section 7(a), Appendix 7- A-D

Projected Generated Wastes

Section 15, Support Vessels and Aircraft Information

Section 16, Onshore Support Facilities Information Policy 8.9 – Radioactive Wastes Only oil field wastes will be generated as a result of this project and these will be disposed in an authorized waste facility. Section 7, Appendix 7- A-D

Waste and Discharge Information

Section 16(d), Waste Disposal Facilities Guidelines for Uses that Result in the Alteration of Waters Draining into Coastal Waters (Policy 9.2) - The project will not result in any increase in developed area runoff (See Section 16, Onshore Support Facilities Information). Guidelines for Oil, Gas and other Mineral Activities Policy Effects Analysis Cross References Policy 10.3 - Siting of exploration, production and refining activities Production or refining activities will not be located in areas containing critical wildlife or vegetation. Sections 19(b).4, Coastal Environments

Policy 10.5 - Access to site  Access routes to production and refining sites will not affect critical wildlife and vegetation areas.

 Based on surveys conducted, there was no detection of chemosynthetic features or hard substrate at the proposed well locations. Section 14, Related Facilities and Operations Information, and Figure 14-8, Gulf Coast Refineries Considered for Receipt of Crude Oil

Appendix 2b, GEMS Shallow Hazards Report for Facilities Policy 10.6 - Best practical techniques for drilling and production sites The estimated volume of drilling muds and cuttings generated will be discharged according to NPDES permit limitations and will therefore not release pollutants or toxic substances into the environment. Section 2(b), Drilling Fluids18 Coastal Zone Management Act (CZMA) Information

Petrobras America Inc. Page 18-9 Development Operations Coordination Document Cascade / Chinook Development Project Guidelines Applicable to All Uses Policy Effects Analysis Cross References Policy 10.10 - Guidelines for drilling and production equipment for preventing adverse environmental effects  Placement of jumper connectors on the seafloor will cause minor, short term turbidity and will have no effect to coastal resources. The proposed wells would have no effect to coastal resources.

 There is no additional oil spill risk resulting from bringing the crude product to shore. The various terminals will likely operate at capacity whether or not this proposed project is approved. If the shuttle vessels proposed for this development are not used, it is anticipated that some other tanker, likely carrying foreign supplied oil, will be used in its place.

 PAI would use a dedicated field tug, which will enhance safety and pollution response during offloading and other operational activities. Sections 1(a), Safety and Pollution Prevention Measures and 1(f), Additional Safety and Pollution Prevention Measures

Section 2(e), New or Unusual Technology

Section 9(a), Oil Spill Response Planning

Section 19(c), Project Impacts and Section 1(e) Pollution Prevention Measures Policy 10.11 - Effective environmental protection and emergency or contingency plans  A dedicated field tug will help prevent collisions or accidents during offloading operations and other operational activities.

 A hurricane avoidance plan has been developed for the FPSO.

 Oil Spill Emergency Response Plans were developed for the FPSO and Shuttle Vessels.

 Existing procedures such as the use of radar, watch standing, and other communication efforts will minimize the chance of collisions with other vessels.

 The FPSO has an emergency shutdown system that will handle any extreme process conditions or hazardous situations such as fire and gas cloud formation.

 PAI is a member of Clean Gulf Associates (CGA) and Clean Caribbean and Americas (CCA). PAI’s primary spill response equipment is provided by CGA. PAI also has access to secondary spill response equipment from CCA.

 PAI will contract MWCC to provide well blowout response equipment under a non-member well by well basis. Sections 1(e), Pollution Prevention Measures and 1(f), Additional Safety and Pollution Prevention Measures

Section 2(e), New or Unusual Technology

Sections 9(a), Oil Spill Response Planning and 9(b), Oil Spill Response Discussion

Section 10, Environmental Monitoring

The activities proposed in this SDOCD are consistent with the previously approved Cascade / Chinook Development Plan and are supported by sufficient data and information concerning the potential impacts associated with drilling, completing and producing additional wells. The proposed activities would be conducted in accordance with all federal and state regulations, applicable notices to lessees (NTLs), conditions in the approved permits, and lease stipulations. PAI has therefore determined that the proposed activities associated with this project are consistent with the Louisiana LCRP.18 Coastal Zone Management Act (CZMA) Information

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Petrobras America Inc. Page 18-13 Development Operations Coordination Document Cascade / Chinook Development Project 

## Texas Coastal Management Program

The Texas Coastal Management Program (TCMP) is a comprehensive management program for coastal land and water activities that sets policies, standards, and regulations affecting private and public property. These policies are administered under Texas laws. The program protects coastal resources by preventing resource destruction, promoting the benefits of resources, and managing activities that impact resources. The TCMP is based primarily on the Coastal Coordination Act of 1991, as amended by House Bill 3226 in 1995. Program policies are set forth in Texas Administrative Code Title 31 Part 16 Chapters 501 – 506. As described more fully in this supplemental DOCD, Petrobras America Inc. (PAI) proposes to develop two wells: WR 206 No. 6 and 7 and their associated jumper connectors, one per well, within the Cascade deep water field. The Cascade Field and the associated Chinook Field developments were previously addressed in a DOCD submittal and accompanying coastal consistency certificate in June 2007. At that time, the Floating Production, Storage and Offloading (FPSO) facility was addressed. Specific details related to the proposed development activities can be found in Section 1. This supplemental DOCD specifically addresses project activities in the Cascade deep water field. The project is located in the Central Planning Area of the Gulf of Mexico on Walker Ridge Block 206 more than 285 miles from the coast of Texas as shown in Figure 1-1. Texas is considered to be an “affected state” because some aspects of the project may use resources in the state. This would require the state’s review and concurrence with the project to ensure that the proposed activities are consistent with the enforceable policies of the TCMP. PAI may occasionally use existing facilities at the Port of Galveston as a secondary onshore support base for equipment and supplies due to specific conditions such as weather, market availability of marine vessels or helicopters, security, or safety (see Figure 15-8). No new construction or expansion of facilities at the port will be required. No new dredging or changes to coastal areas will occur. The following is a list of shore-based waste disposal facilities in Texas that could be used for the projected wastes associated with the WR 206 No. 6 and 7 wells:

 US Liquids of Louisiana located in Galveston and Newpark Services located in Winnie. These contractors will accept environmental wastes such as cutting boxes, solid wastes from the marine portable tanks, and tank clearing fluids.

 L&L located in Houston. This contractor will accept the disposal of used oil and filters, and oil rags. As described in Section 14(c), PAI will charter Shuttle Vessels to deliver the produced oil to market to terminals along the coast of the GoM. After the initial production ramp-up in the18 Coastal Zone Management Act (CZMA) Information

Page 18-14 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Projectfirst year of operations, PAI anticipates an offloading frequency of once per week during sixeight years of production operations for Phase II of the development plan. PAI has not yet determined which specific terminals will be used. However, PAI anticipates using several refineries located in Texas (see Figure 14-8). The specific refineries to be utilized will depend on several factors including market conditions and available terminal capacities. The Texas refineries that could potentially be used are shown below. This list includes the ranking of each refinery in Texas compared to all US refineries relative to their daily crude operating capacity as of January 2008 (Energy Information Administration 2011).

Corpus Christi

 Flint Hills Resources, Corpus Christi (#11)

 Citgo Refining, Corpus Christi (#45)

 Valero Refining, Corpus Christi (#53)

Freeport

 ConocoPhillips, Sweeny (#19)

Galveston / Houston

 ExxonMobil Refining, Baytown (#1)

 BP Products, Texas City (#3)

 Deer Park Refining, Deer Park (#8)

 Lyondell Citgo Refining, Houston (#14)

 Valero Refining, Texas City (#30)

 Pasadena Refining, Pasadena, TX

 Valero Refining, Houston (#69)

 Marathon Petroleum, Texas City (#78)

Port Arthur / Beaumont

 ExxonMobil Refining, Beaumont (#6)

 Motiva Enterprises, Port Arthur (#12)

 Premcor Refining, Port Arthur (#17)

 Total Petrochemicals, Port Arthur (#26)18 Coastal Zone Management Act (CZMA) Information

Petrobras America Inc. Page 18-15 Development Operations Coordination Document Cascade / Chinook Development Project PAI has evaluated the proposed activities related to the proposed wells to determine if there would be any reasonably foreseeable coastal effects on the land, water uses, or natural resources of the coastal zone of Texas, pursuant to the enforceable policies of the state’s CMP. Specific policies that address the potential environmental impacts to coastal uses from oil and gas exploration and production activities are briefly described in Table 18-2 with relevant cross references to this supplemental DOCD. The analysis upon which this effects determination has been made is provided in Section 19.

Table 18-2 – Consistency Review Summary

Policies Information Required Cross References Category 2 - Construction, Operation and Maintenance of Oil and Gas Exploration and Production Facilities  The project site will be located at least 285 miles offshore the Texas coast and will use existing shore based facilities.

 The use of a gas export pipeline at the beginning of production will provide a positive environmental effect because no flaring would occur during normal production operations. Short term flaring (several days per well) will likely occur during the well testing phase but this would not affect near shore resources. Section 8, Air Emissions

Appendix 3, Air Emission Worksheets

Category 3 - Discharges of Wastewater and Disposal of Waste from Oil and Gas Exploration and Production Activities  No water quality impacts will occur because of the use of existing support base and terminals that are located at established ports. Wastes will be properly contained, transported, and disposed in designated waste facilities.

 The project will comply with all requirements including the EPA NPDES general permit for offshore discharges and USCG regulations for vessels operating in state waters. The project will not affect water quality in Texas.

 Solid waste trash and other waste products generated by the FPSO and the drilling rigs will be bagged and kept onboard until transported via supply boat to a designated contractor (potentially as secondary onshore support facilities in Texas could be used occasionally) for proper disposal.

 Sanitary wastes on each of the vessels will be treated by a Marine Sanitation Device and discharged overboard in accordance with USCG regulations.

 Other waste streams from the FPSO and construction vessels will be discharged overboard in accordance with the NPDES general permit. Section 7, Appendix 7 A_D Waste Discharge Information

Section 14, Related Facilities and Operations Information, and Figure 14-8, Gulf Coast Refineries Considered for Receipt of Crude Oil

Section 16, Waste Disposal Facilities

Sections 19 (c), Project Impacts18 Coastal Zone Management Act (CZMA) Information

Page 18-16 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Policies Information Required Cross References Category 4 – Construction and Operation of Solid Waste Treatment, Storage, and Disposal Facilities The project will have no effect on the construction and operation of solid waste treatment facilities because only existing and approved onshore waste disposal facilities will be used. Furthermore, no unusual solid or liquid wastes would be generated or disposed. Section 16, Onshore Support Facilities Information

Category 5 - Prevention, Response and Remediation of Oil Spills  There is no additional oil spill risk resulting from bringing the crude product to shore. The various refineries will likely operate at capacity whether or not this proposed project is approved. If the shuttle vessels proposed for this development are not used, it is anticipated that some other tanker, likely carrying foreign supplied oil, would be used in its place.

 PAI will use a dedicated field tug, which would enhance safety and pollution response during offloading and other operational activities.

 A hurricane avoidance plan has been developed for the FPSO.

 Vessel Shipboard Oil Pollution Emergency Plans have been developed for the FPSO and Shuttle Vessels.

 Existing procedures such as the use of radar, watch standing, and other communication efforts will minimize the chance of collisions with other vessels.

 The FPSO has an emergency shutdown system that will handle any extreme process conditions or hazardous situations such as fire and gas cloud formation.

 PAI is a member of Clean Gulf Associates (CGA) and Clean Caribbean and Americas (CCA). PAI’s primary spill response equipment is provided by CGA. PAI also has access to secondary spill response equipment from CCA.

 PAI will contract MWCC to provide well blowout response equipment under a non-member well by well basis. Sections 1(c), Safety and Pollution Prevention Features, and 1(f), Additional Safety and Pollution Prevention Features

Section 9, Oil Spill Information

Category 6 – Discharge of Municipal and Industrial Waste Water to Coastal Waters No municipal or industrial waste discharges would occur in coastal waters. Only existing designated wastes facilities in Texas may be used. Section 7(a), Appendix 7- A-D

Projected Generated Wastes

Section 15, Support Vessels and Aircraft Information

Section 16, Onshore Support Facilities Information18 Coastal Zone Management Act (CZMA) Information

Petrobras America Inc. Page 18-17 Development Operations Coordination Document Cascade / Chinook Development Project Policies Information Required Cross References Category 7 – Non Point Source Pollution The project will comply with NPDES permit limitations and will therefore not release pollutants or toxic substances into the environment. There should be no impact to water quality in Texas coastal waters. Section 2(b), Drilling Fluids

Category 8 – Development in Critical Areas No development or dredging and filling will occur in or near state waters; therefore, there will be no impact to critical areas. Section 1, Introduction and Plan Contents Category 9 – Construction of Waterfront Facilities and Other Structures on Submerged Lands Only existing terminal facilities in Texas will be used and no industrial expansion is proposed to occur. Section 1, Introduction and Plan Contents

Section 14, Related Facilities and Operations Information Category 10 – Dredging and Dredged Material Disposal and Placement The project does not involve any new development or dredging and filling in or near state waters; therefore, there will be no effects to coastal waters, submerged lands, critical areas, coastal shore areas, and Gulf beaches. Section 1, Introduction and Plan Contents

Category 11 – Construction in the Beach / Dune System The project does not involve any construction in critical dune areas or on Texas beaches. Section 1, Introduction and Plan Contents Category 12 – Development in Coastal Hazard Areas The project does not involve any new development in Coastal Hazard Areas. Section 1, Introduction and Plan Contents Category 13 – Development Within Coastal Barrier Resource The project does not involve the development of new infrastructure or major repair of existing infrastructure within or supporting development within or near a Coastal Barrier Resource System Unit or any other protected area. Section 1, Introduction and Plan Contents

Category 14 – Development in State Parks, Wildlife Management Areas or Preserves The project does not in involve the use of or the taking of any public land in Texas. Section 1, Introduction and Plan Contents

Category 15- Alteration of Coastal Historic Areas To ensure any shallow hazards and historic sites are identified and avoided, a shallow hazards assessment of the seafloor at the project site was conducted. No coastal areas would be affected by the proposed action. Section 19(b).14

Section 6(i), Archeological Report and Appendix 2b, Shallow Hazards Report for Facilities Category 16 – Transportation Projects The project involves the use of existing shore based facilities and will not require new transportation construction within the coastal zone. Section 1, Introduction and Plan Contents18 Coastal Zone Management Act (CZMA) Information

Page 18-18 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Policies Information Required Cross References Category 17- Emission of Air Pollutants  The air emissions analysis shows that the project will not exceed emission thresholds established by EPA/BOEM. The project would not affect air resources in Texas.

 No increase in air quality effects are expected because there would be no change in refinery capacity or increase in the number of shuttle vessels bringing crude oil to port. Section 8, Air Emissions Information

Section 19(b).1 and 19(c).1, Air Quality

Appendix 3, Air Emission Worksheets Category 18 – Appropriations of Water The project does not involve the use of impoundments or the diversion of state water. Section 1, Introduction and Plan Contents Category 19 – Levee and Control Projects The project does not involve drainage, reclamation, channelization, levee construction or modification, or flood or floodwater-control. Section 1, Introduction and Plan Contents Category 20 – Marine Fishery Management The project will not affect any commercial or recreational fishing activities or management efforts. Section 19(b).8, Commercial and Recreational Fisheries Category 21 – Policies for Major Actions A major action under this policy is considered to be an activity for which an environmental impact statement is required. BOEM has undertaken multiple EISs for OCS lease sales in the GOM and undertook an EIS for use of the FPSO. PAI conducted an analysis of site specific potential impact producing factors and determined that the proposed project falls within the design and operational parameters that were assessed in the programmatic FPSO EIS document and site specific environmental impact analysis undertaken for this SDOCD. No additional EIS is required. Section 19, Environmental Impact Analysis

The activities proposed in this SDOCD are supported by sufficient data and information concerning potential impacts associated with these proposed activities. The proposed activities will be conducted in accordance with all federal and state regulations, applicable NTLs, conditions in the approved permits, and lease stipulations. PAI has therefore determined that the proposed activities associated with this project are consistent with the Texas TCMP.18 Coastal Zone Management Act (CZMA) Information

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Petrobras America Inc. Page 18-21 Development Operations Coordination Document Cascade / Chinook Development Project 

## Mississippi Coastal Program

The Mississippi Coastal Program has been in effect since 1972. The regulations, guidelines, and procedures (Section 57-15-6 of the Mississippi Code of 1972) carry out state policy in the Mississippi coastal area in order to protect coastal resources by preventing resource destruction, promoting the benefits of resources, and managing activities that impact

resources. As described more fully in this supplemental DOCD, Petrobras America Inc. (PAI) proposes to develop two wells: WR 206 No. 6 and 7 and their associated jumper connectors, one per well, within the Cascade deep water field. The Cascade Field and the associated Chinook Field developments were previously addressed in a DOCD submittal and accompanying coastal consistency certificate in June 2007. These Fields are located in the Central GoM and do not involve any construction of facilities within the coastal zone of Mississippi. The only action that could potentially affect the State of Mississippi is the transportation of produced oil to market. As described in Section 14(c), PAI will charter Shuttle Vessels to deliver the produced oil to market to terminals along the coast of the GoM. After the initial production ramp-up in the first year of operations, PAI anticipates an offloading frequency of once per week during six-eight years of production operations for Phase 1 of the development plan. This SDOCD now addresses Phase II of the development plan. PAI has not yet determined which specific terminals will be used. The specific refineries to be utilized will depend on several factors including market conditions and available terminal capacities. PAI could potentially utilize the Chevron USA terminal located in Pascagoula (see Figure 14-8). This terminal ranks number 9 among all US refineries relative to daily crude operating capacity as of January 2008 (Energy Information Administration 2011). PAI has evaluated the proposed activities related to the proposed wells and their associated jumper connectors to determine if there would be any reasonably foreseeable coastal effects on the land, water uses, or natural resources of the coastal zone of Mississippi pursuant to the enforceable policies of the state’s Coastal Zone Management Program. Specific policies that address the potential environmental impacts to coastal uses related to oil and gas exploration and production, are briefly described in Table 18-3 with relevant cross references to this supplemental DOCD where further details are provided. The analysis upon which this effects determination has been made is provided in Section 19.18 Coastal Zone Management Act (CZMA) Information

Page 18-22 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Table 18-3 – Consistency Review Summary

Policies Information Required Cross Reference Goal 1 – To provide for reasonable industrial expansion in the coastal area and to insure the efficient utilization of waterfront industrial sites  Only existing terminal facilities in Pascagoula may be potentially used and no industrial expansion is proposed.

 There is no additional oil spill risk resulting from bringing the crude product to shore. The various refineries will likely operate at capacity whether or not this proposed project is approved. If the shuttle vessels proposed for this development are not used, it is anticipated that some other tanker, likely carrying foreign supplied oil, would be used in its place. Section 14, Related Facilities and Operations Information

Goal 2 – To favor the preservation of coastal wetlands and ecosystems The project site is located 270 miles from Mississippi out into the central Gulf of Mexico and would not directly impact coastal wetlands or ecosystems in Mississippi. Section 1(b), Location

Sections 19(b).4, Coastal Environments and 19(c), Project Impacts Goal 3 – To protect, propagate, and conserve the state’s seafood and aquatic life Environmentally sensitive areas, including oyster reefs, submerged grass beds, and other productive shallow water areas will not be affected by project activities. Sections 19(b), Existing Resource Conditions and 19(c), Project Impacts

Goal 4 – To conserve the air and waters of the state  No air or water quality impacts would occur because of the use of an existing refinery that is located at an established port.

 Wastes from shuttle vessels will be properly treated by a Marine Sanitation Device and discharged overboard in accordance with USCG regulations.

 PAI will use a dedicated field tug to enhance safety and pollution response during offloading and other operational activities, which will minimize the chance of an oil spill affecting state waters. Section 8, Air Emissions Information and Appendix 3, Air Emissions Spreadsheets

Section 9, Oil Spill Information

Goal 5 – The beneficial use of the state’s water resources and to prevent its waste. The project does not involve the use of water resources in Mississippi. Desalination units will be used to generate the needed freshwater at the project site. Section 7, Appendix 7-A-D Waste and Discharge Information
Goal 6 – To preserve the state’s historical and archeological
resources To ensure any shallow hazards and historic sites are identified and avoided, a shallow hazards assessment of the seafloor was conducted at the project site. Project activities will not affect any historical or archeological sites in Mississippi coastal areas. Section 19(b).14

Section 6(i), Archeological Report and Appendix 2-B Shallow Hazards Report for Facilities18 Coastal Zone Management Act (CZMA) Information

Petrobras America Inc. Page 18-23 Development Operations Coordination Document Cascade / Chinook Development Project Policies Information Required Cross Reference Goal 7 – To preserve the natural scenic qualities in the coastal area The project is located 270 miles from Mississippi and areas with natural scenic qualities will not be affected. Section 1(b), Location

Goal 8 – To assist local governments in the provision of public facilities services The project does not involve the use of public facilities. Section 1, Introduction

The activities proposed in this SDOCD are supported by sufficient data and information concerning potential impacts associated with these proposed activities. The proposed activities are not anticipated to result in any direct impacts to the land, water uses, or natural resources of the coastal zone of Mississippi, pursuant to the enforceable policies of the state’s coastal program. PAI has therefore determined that the proposed activities associated with this project are consistent with the Mississippi Coastal Program.18 Coastal Zone Management Act (CZMA) Information

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Development Operations Coordination Document Cascade / Chinook Development Project 

## 19 Environmental Impact Analysis (EIA)

Pursuant to 30 CFR 250.227 and 250.261 and NTL 2008-G04, this section provides project-specific environmental impact analysis that assesses the potential direct and indirect environmental impacts to offshore and onshore resources that could be affected by the proposed activities. The Submerged Lands Act of 1953, the Outer Continental Shelf Lands Act of 1953, and the Oil Pollution Act of 1990 provide the regulatory framework and authority for BOEM to have oversight and management of offshore operations. Seven other Federal laws also mandate compliance with their provisions:

 National Environmental Policy Act of 1970 requires a detailed environmental review before any major Federal action;

 Clean Air Act of 1970, re-authorized in 1990, regulates allowable air pollutant emissions from industrial activities;

 Clean Water Act of 1977 regulates discharges into waters of the U.S. through issuance of National Pollutant Discharge and Elimination System permits;

 Coastal Zone Management Act of 1972, re-authorized in 1990, requires State review of Federal action that affects the land and water uses of their coastal zones;

 Marine Mammal Protection Act of 1972 requires protection and conservation of all marine mammals and their habitats; and

 Endangered Species Act of 1973 requires that all Federal actions not significantly impair or jeopardize protected species or their habitats and requires a permit for the taking of any protected species. An EIA is undertaken herein by 1) identifying impact producing factors from the proposed action, 2) undertaking an inventory of existing resources of concern, and 3) conducting an analysis of potential impacts to these resources for avoidance, minimization, or mitigation of the foreseen impacts. The Notice to Lessees (NTL) 2008-G04, Information Requirements for Exploration Plans and Development Operations Coordination Documents , issued on April 1, 2008, provides guidance on preparing DOCDs required by 30 CFR 250, Subpart B regulations. The NTL requires that the EIA identify impact-producing factors (IPF) associated with the proposed action that could affect environmental, archeological, socioeconomic, or other important resources in the area and provides additional guidance on information requirements regarding compliance with the provisions of the Endangered Species Act (ESA) and the Marine Mammals Protection Act (MMPA). This section describes activities and potential impact producing factors associated with the proposed Cascade Development Wells WR 206 No. 6 and 7 and their associated jumper connectors (one jumper connector per well) that may have the potential to affect environmental,19 Environmental Impact Analysis (EIA)

Page 19-2 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project archeological, and socioeconomic resources. Information on impact producing factors (IPFs) is presented in Section 19(a). Existing resource conditions in or near the proposed project area are presented in Section 19(b). Potential project impacts to these resources are discussed in Section 19(c). Environmental hazards that may affect the project and/or exist in the project area, i.e. the Gulf of Mexico, are addressed in Section 19(d). Alternatives to avoid and minimize potential environmental impacts are addressed in Section 19(e). In the unlikely event of project environmental impacts, mitigation measures are identified in Section 19(f). Applicable consultation and coordination is presented in Section 19(g) while a list of preparers is in Section 19(h). References are listed in Section 19(i). 

### 19(a) Impact Producing Factors (IPFs) from the Proposed Activities The proposed project location is shown in Figure 1-1, which is approximately 290 miles (467 km) southeast from the Port of Galveston, Texas and 180 miles (290 km) south from the Port of Fourchon, Louisiana in the Gulf of Mexico, beyond the continental shelf and continental slope in ultradeep water, approximately 8,200 feet (2,500 m). This location is just off the Sigsbee escarpment on the edge of the Abyssal Plain. The Cascade and Chinook Field locations are shown in Section 1, Figure 1-1 and specific well locations are shown in Section 1(b) and are within the Walker Ridge Area. The Gulf of Mexico is a roughly oval basin covered by a semi-enclosed marginal sea of the Atlantic Ocean bounded by the United States, Mexico, and the island of Cuba. Entry from the Atlantic is gained through the Straits of Florida, north of Cuba, and entry from the Caribbean Sea is gained through the Yucatan Channel, south of Cuba. The Gulf of Mexico has a surface area of 580,000 square miles (1.5 million sq km) and is characterized by a very wide, gently sloping continental shelf (35%) around most of its margin which is generally less than 656 feet (200 m) deep (http://www.gulfbase.org/facts.phb). The only area in the Gulf where water depth reaches 654 feet (200 meters) within (50 km) of the shore is off the Mississippi River Delta. In contrast to the smooth gentle slope of the continental shelf, the Gulf continental slope (40%) is steep and irregular, with canyons and knolls and reaches water depths of between 590-9,842 feet (180-3,000 m). The remaining 25% are the abyssal depths, mainly the Sigsbee Abyssal Plain, greater than 9,842 feet (3,000 m). A summary of the proposed project activities within the Gulf is included in Section 1 of this supplemental DOCD with Section 1(b) showing the location of the wells. Sections 2, 14, 15, and 16 respectively provide general information about offshore and onshore project activities, operations, and support equipment while Sections 7, 8, and 9 provide information on waste generation and discharges, air emissions, and potential inadvertent oil spills associated with the proposed project and taken into consideration for environmental impact analysis. PAI has identified the following project-specific Impact Producing Factors (IPFs) which could potentially impact the environment as a result of proposed development activities:19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-3 Development Operations Coordination Document Cascade / Chinook Development Project  Air emissions;

 Noise;

 Seafloor disturbance;

 Ocean discharges;

 Onshore waste disposal;

 Accidental events such as oil spills or blowouts; and

 New or unusual technology. 

### 19(b) Existing Resource Conditions The Gulf of Mexico, as a relatively large semi-enclosed marginal sea off the Atlantic Ocean and Caribbean Sea, has diverse abiotic and biotic resources. According to the National Biodiversity Information Infrastructure and the Harte Research Institute for Gulf of Mexico Studies, there are 15,419 known species from 40 phyla and divisions (http://www.nbii.gov/portal/server.pt?open=512&objID=1950&mode=2&in_hi_userid=2 &cached=true). The diversity of biotic resources includes corals, jellyfish, sea anemones, crustaceans, diatoms, dinoflagellates, marine vertebrates, birds, marine worms, mollusks, squid, octopus, moss animals (Bryozoans), sea stars and sea urchins, shelled protists, and sponges (Felder and Camp 2009). The following provides descriptions of applicable existing resources to the project. 19(b).1 Air Quality National Ambient Air Quality Standards The Clean Air Act (CAA) of 1970 established national ambient air quality standards (NAAQS). When measured concentrations of regulated pollutants exceed standards established by NAAQS, then an area may be designated as non-attainment area for a regulated pollutant. As mandated by the Clean Air Act (CAA) of 1970, EPA has established ambient air quality standards to protect public health (primary standards) and public welfare (secondary standards). Primary standards are based on observable human health responses, and are set at levels that provide an adequate margin of safety forsensitive segments of the population. Secondary standards are intended to protect nonhealth based public interests such as structures, vegetation, and livestock. The more stringent of the primary or secondary standards are applicable to projects under EPA jurisdiction.

The EPA Office of Air Quality Planning and Standards (OAQPS) has set National Ambient Air Quality Standards for six principal pollutants, which are called "criteria" pollutants. Units of measure for the standards are parts per million (ppm) by volume, parts per billion (ppb - 1 part in 1,000,000,000) by volume, milligrams per cubic meter of air (mg/m 3 ), and micrograms per cubic meter of air (μg/m 3 ).19 Environmental Impact Analysis (EIA)

Page 19-4 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project The criteria pollutants are: sulfur dioxide (SO 2 ), particulate matter with aerodynamic diameters less than 10 micrometers or microns (PM 10 ) and 2.5 microns (PM 2.5 ), nitrogen dioxide (NO 2 ), carbon monoxide (CO), photochemical oxidants as ozone (O 3 ), and lead (Pb). Nitrogen oxides (NO x ) and Volatile Organic Compounds (VOCs) are regulated as precursors to ozone. The PM 10 National Ambient Air Quality Standards (NAAQS) was promulgated July 1, 1987 at the federal level to replace the existing standards limiting Total Suspended Particulates (TSP). On July 19, 1997, EPA promulgated a new Fine Particulate (PM 2.5 ) NAAQS. The NAAQS have been developed for various durations of exposure. The short-term (24-hours or less) NAAQS for SO 2 and CO refer to exposure levels not to be exceeded more than once per year. The short-term standard for PM 10 may not be exceeded more than once per year on average over 3 years. For PM 2.5 the 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor within an area must not exceed 35 micrograms per cubic meter (μg/m 3 ; effective December 17, 2006). The 1-hour ozone standard is attained when the expected number of days per calendar year with the maximum hourly average concentrations above 0.12 parts per million (ppm), is less than or equal to 1. As of June 15, 2005, EPA revoked the 1-hour ozone standard in all areas except the fourteen 8-hour ozone non-attainment areas. The 8-hour ozone standard is attained when the 3-year average of the fourth highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year does not exceed 0.08 ppm. A 1-hour NO 2 standard of 100 parts per billion (ppb) was established on January 22, 2010. This new standard is calculated as the 3-year average of the 98 th percentile of the daily 1-hour average concentration of NO 2 . . A 1- hour SO 2 standard of 75 parts per billion (ppb) was established o June 2, 2010. This new standard is calculated as the 3-year average of the 99 th percentile of the daily 1-hour average concentration of SO 2 . Long-term NAAQS for SO 2 , NO 2 , and Pb refer to limits that cannot be exceeded for exposure averaged over three months (Pb) or annually (SO 2 and NO 2 ). To attain this standard, the 3-year average of the weighted annual mean PM 2.5 concentrations from single or multiple community-oriented monitors must not exceed 15.0μg/m 3 . The NAAQS are listed in Table 19-1. Monitored ambient air quality data in coastal areas is depicted in Table 19-2, which shows that there are no exceedances of the NAAQS with the exception of ozone. Ozone non-attainment status occurs in the port areas of Galveston/Houston and Beaumont/Port Arthur, Texas. Further information related to climatology and air quality can be found in MMS (2006a).19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-5 Development Operations Coordination Document Cascade / Chinook Development Project

Table 19-1 - National Ambient Air Quality Standards

Primary Standards Secondary Standards Pollutant Level Averaging Time Level Averaging Time Carbon Monoxide 9 ppm

(10 mg/m 3 ) 8-hour (1) None

35 ppm (40 mg/m 3 ) 1-hour (1)

Lead 0.15 μg/m 3 (2) Rolling 3-Month Average Same as Primary Nitrogen Dioxide 53 ppb (3) Annual (Arithmetic Average) Same as Primary

100 ppb 1-hour (4) None Particulate Matter (PM 10 ) 150 μg/m 3 24-hour (5) Same as Primary

Particulate Matter (PM 2.5 ) 15.0 μg/m 3 Annual (6) (Arithmetic Average) Same as Primary

35 μg/m 3 24-hour (7) Same as Primary Ozone 0.075 ppm

(2008 std) 8-hour (8) Same as Primary

0.08 ppm (1997 std) 8-hour (9) Same as Primary

0.12 ppm 1-hour (10) Same as Primary Sulfur Dioxide 0.03 ppm (11)

(1971 std) Annual

(Arithmetic Average) 0.5 ppm 3-hour (1) 0.14 ppm (11) (1971 std) 24-hour (1)

75 ppb (12) 1-hour None (1 ) Not to be exceeded more than once per year. (2) Final rule signed October 15, 2008. The 1978 lead standard (1.5 μg/m3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved. (3) The official level of the annual NO2 standard is 0.053 ppm, equal to 53 ppb, which is shown here for the purpose of clearer comparison to the 1-hour standard (4) To attain this standard, the 3-year average of the 98th percentile of the daily maximum 1-hour average at each monitor within an area must not exceed 100 ppb (effective January 22, 2010). (5) Not to be exceeded more than once per year on average over 3 years. (6) To attain this standard, the 3-year average of the weighted annual mean PM2.5 concentrations from single or multiple community-oriented monitors must not exceed 15.0 μg/m3. (7) To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor within an area must not exceed 35 μg/m3 (effective December 17, 2006). (8) To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.075 ppm. (effective May 27, 2008) (9) (a) To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.08 ppm. (b) The 1997 standard—and the implementation rules for that standard—will remain in place for implementation purposes as EPA undertakes rulemaking to address the transition from the 1997 ozone standard to the 2008 ozone standard. (c) EPA is in the process of reconsidering these standards (set in March 2008). (10) (a) EPA revoked the 1-hour ozone standard in all areas, although some areas have continuing obligations under that standard ("anti-backsliding").19 Environmental Impact Analysis (EIA)

Page 19-6 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project (b) The standard is attained when the expected number of days per calendar year with maximum hourly average concentrations above 0.12 ppm is < 1. (11) The 1971 sulfur dioxide standards remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved. (12) Final rule signed June 2, 2010. To attain this standard, the 3-year average of the 99th percentile of the daily maximum 1-hour average at each monitor within an area must not exceed 75 ppb.19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-7 Development Operations Coordination Document Cascade / Chinook Development Project

Table 19-2 – Coastal Ambient Air Quality

Year O 3

(ppm) SO 2 (ppm) NO 2 (ppm) PM 2.5 (μg/m 3 ) PM 10 (μg/m 3 ) CO (ppm)

Highest 4 th High 8- hr Highest 2 nd High 3- Hr Highest

2 nd High 24-hr Highest

Annual Mean Highest

Annual Mean Highest

98 th Percentile 24-hour Highest

Annual Mean Highest

2 nd High 24-hour Highest

2 nd High 1-hour Highest

2 nd High 8-hour Baldwin County, Alabama

2008 0.072 - - - - 20.2 9.96 - - -

2006 0.081 - - - - 26.0 11.2 - - -

2005 0.074 - - - - 26.0 11.8 - - -

2004 0.080 - - - - 28.0 11.4 - - -

2003 0.078 - - - - 29.0 12.2 - - - Mobile County, Alabama

2008 0.076 - - - - 22.4 10.3 - - -

2006 0.085 0.014 0.005 0.002 - - - - - -

2005 0.073 0.019 0.008 0.002 - 29.0 17 135 - -

2004 0.077 0.017 0.007 0.002 - 36.0 13.0 116 - -

2003 0.082 0.017 0.009 0.002 - 31.0 12.8 82 - - Jackson County, Mississippi

2008 0.078 - 0.007 0.002 0.006 20.0 9.89 - - -

2006 0.082 0.035 0.008 0.002 0.007 28.0 13.1 40 - -

2005 0.081 0.031 0.012 0.003 0.007 28.0 11.9 40 - -

2004 0.079 0.034 0.008 0.003 0.007 32.0 12.1 51 - -

2003 0.084 0.017 0.007 0.002 - 26.0 12.0 33 - - Breton Aerometric Monitoring Program – Offshore

2001 - 0.017 0.005 0.002 0.003 - - - - - East Baton Rouge Parish, Louisiana

2008 0.074 - 0.017 0.003 0.013 28.4 14.3 - 2.5 1.8

2006 - - - - - - - - 4.4 3.3
Orleans Parish, Louisiana

2008 0.071 - - - - - - - - -

2005 - - - - - - - - 2.7 1.7

2004 - - - - - - - - 5.2 3.4

2003 - - - - - - - - 6.5 3.5 Jefferson County, Texas

2008 0.078 - 0.018 0.003 0.008 32.6 10.41 - 1.7 0.7

2006 0.085 0.150 0.034 0.004 0.009 27.0 11.1 - - -

2005 0.083 0.070 0.019 0.004 0.009 36.0 15.0 - - -

2004 0.091 0.149 0.032 0.004 0.010 27.0 11.6 - - -

2003 0.086 0.236 0.034 0.004 0.010 26.0 11.8 - - -
Sources EPA 2006; Sonoma Technology 2004 (actual period of data collection October 2000-November 2001) and http://www.epa.gov/air/data/geosel.html19 Environmental Impact Analysis (EIA)

Page 19-8 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project The closest Federal Class I area, which prohibits impairment from manmade air pollution, is Breton National Wilderness Area (BNWA) located approximately 40 miles offshore southeastern Louisiana and approximately 30 miles from the Mississippi coast. The Breton Aerometric Monitoring Program measured ambient concentrations of NO 2 and SO 2 at BNWA that were well below the NAAQS and similar or lower than ambient concentrations measured at shore-based monitors in Alabama, Mississippi, Texas, and Louisiana (EPA 2006). For any OCS plan that is located within 63 miles of BNWA, BOEM would consult with the US Fish and Wildlife Service (USFWS), which manages the area. The Cascade wells, WR 206 No. 6 and 7 are located over 200 miles from BNWA as shown in Figure 19-1.19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-9 Development Operations Coordination Document Cascade / Chinook Development Project Figure 19-1 - National Park Lands19 Environmental Impact Analysis (EIA)

Page 19-10 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project The CAA specifies air quality jurisdictional boundaries between the EPA and the Department of the Interior in the GoM OCS. Projects on the OCS east of 87.5 o West longitude (approximately the Eastern Planning Area boundary) are subject to EPA air quality regulations. Projects located west of 87.5 o West longitude, which includes the Cascade / Chinook Development, are regulated by BOEM. Air quality over federal OCS waters is unclassified because no provisions exist under the Clean Air Act for designating such areas outside the boundaries of state waters. Only areas within state boundaries are classified as attainment, non-attainment, or unclassifiable (Minerals Management Service [MMS] 2002). The 1990 CAAAmendments required that BOEM evaluate cumulative, onshore, air quality nonattainment areas, and impacts from OCS petroleum resource development. The Secretary of Interior and the EPA Administrator have determined that no new air quality requirements are necessary for the area under BOEM jurisdiction. No specific air quality data exist for the Walker Ridge area. However, due to the distance from shore based pollution sources, offshore air quality is expected to be better than the NAAQS for all criteria pollutants (MMS 2001). The BOEM uses a two level approach to evaluate a project’s potential impacts to onshore areas. If the proposed activities exceed the criteria at the first (exemption) level, the proposed project must be evaluated to determine if it exceeds the second (significance) level criteria. The influence to onshore air quality is dependent upon meteorological conditions and air pollution emitted from operational activities. The pertinent meteorological conditions affecting air quality are wind speed and direction, atmospheric stability, and mixing height which govern dispersion and transport of potential pollutants. The typical synoptic wind flow for the Walker Ridge area is driven by the clockwise circulation around the Bermuda High (MMS 2008). This circulation direction is conducive to transporting emissions to shore. However, in actuality, the wind blows from all directions in the area of concern because of smaller meso-scale wind flow patterns, such as the land/sea breeze phenomenon, periodic tropical cyclones, and mid-latitude frontal systems. Therefore, winds are predominately from the south-southeast across the area. Refer to Section 8 and Appendix 3, Air Emissions Worksheets, for more specific details on the projected air emissions associated with the proposed activity. 19(b).2 Water and Sediment Quality The continental shelf effectively isolates the deeper waters of the OCS of GoM from the direct influences of many coastal processes. Limited information is available regarding water quality in the deepwater environment. Water depths greater than 4,593 feet (1,400 m) have been found to be relatively homogeneous with respect to temperature, salinity, and oxygen (MMS 2002). In general, the site is expected to have typical ocean salinity and oxygen levels, low levels of nutrients, and low levels of contaminants in water and sediments (Continental Shelf Associates [CSA] and Texas Agriculture and Mechanical [A&M] University 2001 and MMS 2002). Measuring the quantity of dissolved oxygen (DO) in water is one method to determine marine environment water quality and to identify water masses and their sources. DO19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-11 Development Operations Coordination Document Cascade / Chinook Development Project values are described in Boehm et al . (2001) and Gallaway et al. (2001). Water masses, which come into the GoM through the Yucatan Channel, have relatively high DO concentrations and are considered to be the source of replenishment of DO to the deep GoM waters (Jochens et al . 2005). However, there was very little data on DO levels in waters deeper than 6,562 feet. More recently, data has been collected (JAG 2010, Garcia et al 2010). Reduced DO below thresholds that sustain aquatic life results in a condition called hypoxia. Hypoxia occurs when the concentration of dissolved oxygen in the water falls to a level that impedes aquatic life. Hypoxic conditions are generally agreed to occur when DO falls below 1.4 mL/L (also expressed as 2 mg/L) though effects levels are species dependent. Hypoxia is regularly observed in the Northern Gulf of Mexico adjacent to the Mississippi River on the Louisiana and Texas continental shelf (http://www.gulfhypoxia.net/Overview/). Hypoxic conditions do not normally occur in the deep-water layer (JAG 2010). In fact this water layer is relatively rich in DO with a spring climatological mean of 4.8 ± 0.1 mL/L (~6.9 mg/L) at 1500 m depth (Garcia et al 2010). Detailed information related to water and sediment quality in the GoM can be found in MMS (2006a). Following the Deepwater Horizon accident, more recent water and sediment data has also been collected along various shorelines as well as out into the Gulf ( http://www.nodc.noaa.gov/General/DeepwaterHorizon/deepwater_floats_gmap.html ). These data indicate that water temperatures decrease with depth from a water surface temperature near 30° C to less than 5° C below 3,325 feet (1,000 meters). Salinity is shown to also decrease with depth from a general surface salinity of 36.5 ppt to approximately 35 ppt below 2,625 feet (800 meters). PAI undertook a geophysical and geotechnical data acquisition in 2007 (Appendix 2a), an assessment of the seafloor and shallow geology in 2007 (Appendix 2b), and water and sediment analysis study in 2010 with sampling within the Walker Ridge Cascade and Chinook Development Units to provide an environmental characterization before and after exploration and initial development of two wells. The 2010 water and sediment sampling was done on a grid using 37 sampling stations. Sampling points were located in water depths ranging from 6,650-9,180 feet (2,000-2,800 meters) with water samples collected at 5 depths: surface, start and end of thermocline, mid-depth, and near-bottom depth. This study addressed obtaining hydrographic and seawater data and among other things, toxicity testing. Twenty-nine water and sediment parameters were addressed in the 2010 survey. There are likely natural hydrocarbon seeps in the vicinity, which are extensive throughout the Central GoM. However, the area sediments are generally very soft to soft, highly plastic, normally consolidated clays. Shallow gas or active fluid venting to the seafloor was not present and no petroleum hydrocarbon contamination was detected (Appendix 2). The primary factors influencing coastal and marine offshore water quality are temperature, salinity, oxygen, nutrients, potential of hydrogen (pH), oxidation-reduction potential, pathogens, and turbidity or suspended load. Trace constituents such as metals and organic compounds can also affect water quality. Low concentrations of metals on the seafloor sediments indicate lack of significant concentrations in the water column. Water quality was found not acutely toxic to Americamysis bahia

.19 Environmental Impact Analysis (EIA)

Page 19-12 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project 19(b).3 Coastal Environments The Submerged Lands Act of 1953 grants States rights to the natural resources of submerged lands from the coastline to no more than 3 nautical miles (5.6 km) into the Atlantic, Pacific, Artic Oceans, and the Gulf of Mexico with the exception of Texas and the west coast of Florida, where state jurisdiction extends 3 marine leagues, about 9 miles (16.2 km) into the Gulf ( http://www.boemre.gov/AboutBOEMRE/FedOffshoreLands.htm ). Pursuant to 30 CFR 250.226 and 250.260 following information is provided to support coastal consistency determination and EIA. This section summarizes the coastal environments of the affected states of Texas, Louisiana, and Mississippi. Coastal environments are protected under various regulations including the Coastal Zone Management Act, PL 92-583 (16 U.S.C. 1451-1464). There are approximately 808 total miles of coastline along the three affected states: Texas (367 miles), Louisiana (397 miles), and Mississippi (44 miles) (CRS 2006) comprised of barrier islands, beaches, subtidal nearshore areas, shallow water hypersaline lagoons, open water estuaries and embayments, intertidal and supratidal marshes (wetlands), swamps, and other coastal environments. There are four geologic subareas within the affected states that characterize the different types of shoreline: the barrier island complex of southern Texas (and northern Tamaulipas, Mexico); the Chenier Plain of eastern Texas and western Louisiana; the Mississippi River Delta marsh complex of southeastern Louisiana; and the barrier-island and Pleistocene-plain complex of Mississippi (and Alabama) (MMS 2006a). In addition to these coastal environments, various niche habitats are also present such as sand bars, mud flats, seagrass beds, oyster reefs, and coral reefs as other sensitive coastal resource of the nearshore environment of the Gulf of Mexico. Detailed information on the coastal environments of each of these geologic subareas can be found in MMS 2006a.
Coastal Barrier Islands and Beaches The U.S. Gulf of Mexico shoreline along the affected states is characterized by a series of sandy barrier islands, sandy beaches with low to moderate ocean-wave intensities interrupted by the Mississippi River Delta Marsh Complex in southeast Louisiana before returning to sandy beaches and barrier islands along the state of Mississippi. The Gulf coast landmass is relatively low lying, forming broad flat plains with gradually sloping topography. These broad flat plains are punctuated by drowned river mouths which today are a series of large bay complexes where in some areas of Louisiana and Texas, tidal influences can be seen 25 – 40 miles inland due to low flat topography. These embayments, or estuaries, are generally protected behind a series of barrier islands. The barrier islands along in the western Gulf of Mexico shoreline of the United States are primarily the result of former Gulf shoreline migration processes. The barrier islands are transgressive, meaning there is a landward movement of sediment. Transgressive barrier islands typically have low profiles; narrow widths; low, sparsely vegetated, discontinuous sand dunes; and closely spaced with active washover channels (MMS 2006a). Some of the major barrier islands of the affected states of Texas, Louisiana, and Mississippi19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-13 Development Operations Coordination Document Cascade / Chinook Development Project include Brazos Island, Padre Island, Harbor and Mustang Islands, St. Joseph Island, Goose Island, Matagorda Island, Follets Island, and Galveston Island along the Texas Gulf coast; Marsh Island, Round Island, Petit Bois, Ship Island, Horn Island, Cat Island, the Chandeleur Islands chain, Grand Terre, Timbalier Island, and the Isles Dernieres island chain along the Louisiana coast; and the Dog Keys of the Mississippi coast. These barrier islands are characterized by sandy beaches which provide important stopover habitats for migratory birds during spring migration, foraging areas for species such as the endangered Piping Plover ( Charadrius melodus ), and nesting habitat for sea turtles, which are discussed in section 19(b).6.
Coastal Birds Coastal birds are composed of diverse types of shorebirds, marsh birds, colonial waterbirds, and various other types of birds that annually migrate through the Gulf coast between wintering grounds in south and central America and breeding grounds in central and north America, including Canada and Alaska. There are over 300 species that migrate through two major flyways of the central and western Gulf: the Central Flyway along the Texas coast and the Mississippi Flyway through Mississippi ( http://www.birdnature.com/flyways.html ). These species would generally utilize the affected states of Texas, Louisiana, and Mississippi twice a year on spring and fall migrations. The number of species and the number of individual birds migrating has resulted in the State of Texas’ Parks and Wildlife Department to designate a Great Texas Coastal Birding Trail along the coast supporting ecotourism through many coastal communities with an annual international birding event called the Great Texas Birding Classic. Coastal birds that breed and nest along the Gulf coast include species that tend to nest together in relatively large colonies. These species are collectively called colonial waterbirds and include Great Blue Heron ( Ardea herodias ) , Great Egret ( Ardea alba )
, Roseate Spoonbill ( Platalea ajaja ), and numerous other heron and egret species, such as the endangered Reddish Egret ( Egretta rufescens ) and the Brown Pelican ( Pelecanus occidentalis ) . Colonial waterbird sites are protected by the US Fish and Wildlife Service (USFWS). These sites, as well as each species, are counted annually by the USFWS. Other species are more solitary and use a variety of habitat types along the coast nesting on bare ground, shrubs, grasslands, and trees. Bare ground nesting birds include the endangered Piping Plover ( Charadrius melodus ) and American oystercatcher ( Haematopus palliatus ). The USFWS has designated critical habitat along the Gulf beaches (http://www.data.gov/raw/1858). The mottled duck ( Anas fulvigula ) is another Gulf coast bird species of concern in Texas and is also listed on the National Audubon Society’s watchlist because of its very restricted range to the coastal marshes of Texas, Louisiana, and a less extent Florida. ( http://webl.audubon.org/science/species/watchlist/profile.php?speciescode=motduc ).19 Environmental Impact Analysis (EIA)

Page 19-14 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Coastal Wetlands Coastal wetlands are highly productive ecosystems, both environmentally and economically. Together with barrier islands, coastal wetlands provide an important buffer against storm surges. Coastal wetland types along the shores of the affected states include fresh, intermediate, brackish, and saline marshes; mud and sand flats; and forested wetlands including mangrove swamps, cypress-tupelo swamps, and bottomland hardwoods. Detailed descriptions of these various wetland types, processes, functions, and their importance can be found in Chapter 3.1.2.1 of the Multisale EIS (USDOI,MMS, 2007), in Chapter 3.2.1.2 of the FPSO EIS (USDOI, MMS, 2001), and the Sitespecific Environmental Assessment for an FPSO Facility: Site-specific Evaluation ofPetrobras America Inc.’s Initial Development Operations Coordination Document, N9015 (MMS 2008). Gulf coast wetlands within the affected states occur as either relatively narrow bands around the margins of waterways or broad expanses along the lagoons and embayments, such as the Laguna Madre of south Texas, along the bay side of barrier islands associated with Matagorda Bay and Galveston Bay in Texas or as extensive coastal delta wetlands that protrude out into the Gulf associated with the Mississippi River Delta complex and within Atchafalaya Bay, and the Grand Bay Coastal Reserve in Mississippi. Due to proximity to Gulf waters, subtle elevation changes, and freshwater inputs, coastal wetlands support a wide range of types that include saltwort and glasswort flats, intertidal Spartina saltwater marshes, freshwater marshes, cypress swamps, and bottomland hardwood wetlands (MMS 2006a). The general distribution of coastal wetlands relative to the affected states is shown on Figure 19-2. Texas, Louisiana, and Mississippi have experienced a net loss of coastal wetlands due to human development activities and natural processes of erosion and subsidence. Between 1955 and 1992, Texas lost approximately 329.0 square miles of coastal wetlands, with an estimated total of 6,085.6 square miles of coastal wetlands remaining in Texas in 1992 (Moulton et al. 1997, Dahl 2010). Louisiana accounts for 25% of the vegetated wetlands and 40% of the tidal wetlands in the contiguous US, but the Louisiana coastline is eroding faster than any other coastal area of the world, losing up between 24 to 40 square miles each year (USGS 1995) to the severe lack of sediment deficient due to over 100 years of Mississippi River system alterations. The loss of coastland in Louisiana east of the Mississippi River from 2004 to 2005 was 72.9 square miles (MMS 2006b). The US Geological Survey assessed the water-land area within two months after Hurricanes Katrina (August 2005) and Rita (September 2005) and determined that 217 square miles of Louisiana’s coast had been converted to open water compared to images taken in 2004 (Barras 2006) as a result of the storms. Analyses show that coastal Louisiana has undergone a net change in land area of about -1,883 square miles (mi 2 ) from 1932 to 2010 (Couvillion et al 2011). Mississippi contains approximately 112.5 square miles of coastal wetlands, and while coastal wetlands in the state have been lost to human development, Mississippi coastal wetlands are considered to be more stable than those of Louisiana (MMS 2006a) due to their less reliance on Mississippi River sediments.19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-15 Development Operations Coordination Document Cascade / Chinook Development Project Coastal wetlands are important nursery habitats for many commercially and recreationally important species such as crab, shrimp, and finfish. Coastal wetlands also provide resting and foraging habitat for the diversity of wintering waterfowl and coastal birds including the Wood Duck ( Aix sponsa ) , a species of concern in Texas. Due to the location of the Texas, Louisiana, Mississippi coasts to the Central Migratory Flyway, these wetlands provide critical migratory stopover areas, especially fallout areas during spring migration. Louisiana’s coastal wetlands support more than two-thirds of the wintering waterfowl population of the Mississippi Flyway, including 20-25 percent of North America’s puddle or dabbling duck ( Anas sp) population. (MMS 2008).19 Environmental Impact Analysis (EIA)

Page 19-16 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Figure 19-2 – Coastal Wetlands19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-17 Development Operations Coordination Document Cascade / Chinook Development Project Nearshore Environment The nearshore environment is characterized by shallow waters and wave influenced bathymetric conditions including shifting sandbars. In the northern Gulf of Mexico, there are an estimated 11,583.1 square miles of submerged seagrass beds in exposed, shallow coastal waters and another 640.9 square miles located in protected, natural embayments. Seagrass beds are underwater grass meadows dominated by submerged aquatic vegetation (SAV). The characteristic seagrass SAV species are eelgrass ( Zostera marina ), turtle grass ( Thalassia testudinum ), shoal grass ( Halodule wrightii ), manatee grass ( Syringodium filiforme ), and widgeon grass ( Ruppia maritime ). Seagrass beds require shallow, relatively clear, protected or calm waters with predominantly sand bottoms. Johnson’s seagrass ( Halophila johnsonii ) is a federally-listed threatened species, listed since 1998. ( http://www.nbii.gov/portal/server.pt/community/gulf_of_mexico_biodiversity/1950/mari ne_vertebrates/7249 ). Seagrass beds support a high diversity of marine species and provide a food source for wintering waterfowl. Like coastal wetlands, seagrass beds in the GoM have diminished in recent decades (MMS 2006a). Seagrass beds have been shown to provide at least 13 ecological functions including primary producers, habitat for 170 invertebrate species and 100 fish species, and food web support. The majority (98.5%) of the remaining coastal seagrass beds are located off of Florida. The affected states of Texas, Louisiana, and Mississippi account for less than 1.5% of the coastal seagrass beds in the northern Gulf of Mexico. The most extensive seagrass beds off of the affected states occur in the Laguna Madre, a hypersaline lagoon of Texas.
Protected Coastal Areas Protected coastal areas are those marine and coastal habitats protected under national, state, tribal, or local designations and typically open to public use and managed for the preservation of unique coastal and marine resources such as estuaries. Estuaries are semi-enclosed bodies of water, and the surrounding coastal habitat, where saltwater from the ocean meets and mixes with freshwater inflows from streams and rivers. Estuaries are critically important nursery areas with more than 95% of all commercially harvested species and 85% of all recreational species in the GoM spending a portion of their life in estuarine waters (MMS 2006a). The National Estuary Program (NEP) was established in 1987 under the Clean Water Act (CWA) of 1977 and is administered by the EPA. The program is intended to identify nationally important estuaries, to protect and improve their water quality, and enhance their living resources. The Mobile Bay NEP (Alabama), Grand Bay NEP (Mississippi), Barataria-Terrebonne NEP (Louisiana), and Galveston Bay NEP (Texas) are examples of NEPs located along the Gulf coast. Protected coastal areas included specific geographic areas that are designated as critical habitat by the U.S. Fish and Wildlife Service (USFWS) under the Endangered Species Act as essential for the conservation of a threatened or endangered species and that may19 Environmental Impact Analysis (EIA)

Page 19-18 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project require special management and protection such as 18 specified areas containing 139,029 acres (56,263 ha) along the Texas, 7 specified areas containing 24,964 ac (10,103 ha) in Louisiana, and 12 designated areas containing 9,529 ac (3,857 ha) along the Mississippi coasts for piping plover ( Charadrius melodus ) (http:/www.fws.gov/plover/). The USFWS also designates protection under the Coastal Barrier Resources Act of 1982. Relatively long, continuous coastal barriers with small ebb-tidal deltas are produced by longshore currents along wave-dominated coasts as islands along the coast. These barrier islands are typified along the Texas coast in Padre Island and Galveston Island which are long, generally narrow, and cut by widely separated tidal inlets with large sand accumulations in the back-barrier bays, and small or nonexistent seaward shoals. Similar barrier islands are also found along parts of the Louisiana coast and Mississippi and Alabama. National Wildlife Management Areas and National Wildlife Refuges also protect and preserve unique habitats located along the Gulf coast as an interrelated system with state parks, state wildlife management areas, and local protected coastal habitats such as Galveston Island State Park, City of Galveston’s East End Marsh Complex, and Sea Rim State Park in Texas, Grande Isle State Park, Peveto Woods Bird and Butterfly Sanctuary and the Creole Nature Trail in Louisiana, and the Grand Bay National Estuarine Research Reserve in Mississippi. National Wildlife Refuges (NWR), which are managed by the U.S. Fish and Wildlife Service to conserve fish, wildlife, and plants, are located throughout the three affected states. Coastal NWRs of Texas, Louisiana, and Mississippi include: Laguna Atascosa NWR, Aransas NWR, San Bernard NWR, Brazoria NWR, Anahuac NWR, McFadden NWR, and Texas Point NWR in Texas; Sabine NWR, Lacassine NWR, Shell Keys NWR, Bayou Teche NWR, Mandalay NWR, Delta NWR, Breton NWR, Bayou Sauvage NWR, and Big Branch Marsh NWR in Louisiana; and Mississippi Sandhill Crane NWR and Grand Bay NWR (both part of the Gulf Coast Refuge Complex) in Mississippi. The coastal protected areas within the affected states also include parts of the National Park System, specifically Gulf Islands National Seashore (Mississippi) and Padre Island National Seashore (Texas). Some of these protected areas of NEPs, National Parks, and NWRs on the coastlines of the affected states are shown in Figure 19-3.19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-19 Development Operations Coordination Document Cascade / Chinook Development Project Figure 19-3 – Protected Areas19 Environmental Impact Analysis (EIA)

Page 19-20 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project There are topographic features on the continental shelf that are the result of intruding salt domes, particularly on the northwestern shelf and relict carbonate reefs on the south Texas OCS and the pinnacles region offshore of the Mississippi/Alabama coast (Halbouty 1967). These features also include banks offshore that are geologically group to include mid-shelf bedrock banks and outer shelf bedrock banks with carbonate reef caps (Merrill 1983). There are dozens of banks throughout the northern Gulf of Mexico that support coral, though they are not considered true coral reefs (MMS 2006a). Many of these banks, including the East and West Flower Garden Banks, Seven and One Half Fathom Bank, Claypile Bank, Fishnet Bank, Alaminos Bank, Ewing and Diaphus Banks, and Sackett are considered Marine Habitat Areas of Particular Concern (see Section 19(b).11) and some are shown in Figure 19-4. There are seven biotic zones at a bank depending upon depth, salinity, substrate, turbidity, and temperature. Off the coasts of the affected states of Texas, Louisiana, and Mississippi, there are two true coral reefs: the East and West Flower Garden Banks which are protected along with the banks as marine sanctuaries under the National Marine Sanctuaries Act, amended in 2000 (Title 16, Chapter 32, Sections 1431 et seq.) and in furtherance of the purposes of the National Marine Sanctuaries Act (16 U.S.C. 1431 et seq.), National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd-ee), National Park Service Organic Act (16 U.S.C. 1 et seq.), National Historic Preservation Act (16 U.S.C. 470 et seq.), Wilderness Act (16 U.S.C. 1131 et seq.), Magnuson-Stevens Fishery Conservation and Management Act (16 U.S.C. 1801 et seq.), Coastal Zone Management Act (16 U.S.C. 1451 et seq.), Endangered Species Act of 1973 (16 U.S.C. 1531 et seq.), Marine Mammal Protection Act (16 U.S.C. 1362 et seq.), Clean Water Act of 1977 (33 U.S.C. 1251 et seq.), National Environmental Policy Act, as amended (42 U.S.C. 4321 et seq.), Outer Continental Shelf Lands Act (42 U.S.C. 1331 et seq.), and other pertinent statutes and Presidential Executive Order 13158 of May 26, 2000 defining marine protected areas.
The East and West Flower Garden Banks coral reefs are located on the outer shelf on salt domes, approximately 110 miles south of the Texas / Louisiana border (MMS 2006a, TPWD 2007, NOAA 2011). These reefs support over 21 species of coral, 175 species of fish, 250 species of macro-invertebrates, and 80 species of algae (TPWD 2007). The East and West Flower Garden Banks as well as the nearby Stetson Bank (30 miles closer to shore) are part of the Flower Garden National Marine Sanctuary, protected by NOAA’s Office of National Marine Sanctuaries (TPWD 2007, NOAA 2011). Endangered and threatened species in critical marine habitats under the jurisdiction of the NOAA Fisheries Service Southeast Region, which spans from Texas through Florida include the invertebrate coral species, elkhorn coral ( Acropora palmate ) and staghorn coral ( Acropora cervicornis ). Both species were listed in 2006 as threatened.19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-21 Development Operations Coordination Document Cascade / Chinook Development Project Figure 19-4 – Biological Resources19 Environmental Impact Analysis (EIA)

Page 19-22 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Deepwater Chemosynthetic Communities GoM chemosynthetic communities are found in water depths from several hundred meters to more than two thousand meters, generally in association with faults, hydrocarbon seeps, and in lava-like flows of solidified asphalt (MacDonald et al . 2002). They can also referred to as high density benthic communities. The northern GoM has been described as a ‘leaky’ hydrocarbon province characterized by faults that facilitate migration, or seeps, of oil and gas from subterranean reservoirs to the sea floor (MacDonald et al . 2002). A summary is provided below, but further details related to the level of information known about chemosynthetic communities and the conditions where they can be found in the GoM are provided in MMS (2006a). The hydrocarbon seeps alter the physical properties of surface and near-surface sediments, which can be detected using geophysical techniques. Near-surface sediments produce distinct signatures on high-frequency echo-sounder and seismic reflection profiles. Seeps are recognized on echo-sounder records as they cause acoustic “wipeout,” which is the absence of subsurface reflectors. Seepage effects can be identified by seismic reflection, in particular the 2D and 3D multi-channel seismic data, which is used to assess seafloor conditions in the project area. Refer to the GEMS Shallow Hazards Report for Facilities and the Summary of Environmental Conditions for Cascade / Chinook in Appendix 2. Macrofaunal assemblages that are characteristic of GoM chemosynthetic communities are dominated by tubeworms, mussels and clams with adjacent bacterial mat communities (Cordes 2006). There is a dependent symbiosis relationship with bacteria that can utilize chemical energy as opposed to light. The settings for these chemosynthetic communities are characterized by vents and seeps (MMS 2002). These foundation species, which are essentially sessile (attached and not moving from place to place), form a habitat that is utilized by numerous other species. Species commonly associated with this foundation community include limpets, starfish, shrimp, crabs, snails, fish, and numerous species of polychaete worms. While chemosynthetic communities require particular geophysical and geochemical conditions to establish, their existence also results in the development of secondary features. For example, microbial respiration increases dissolved organic carbon concentrations and alkalinity, which generates authigenic carbonates; notable as one of the macroscale geologic features of seep environments (TDI-Brooks International, Inc. 2005). They are also temperature sensitive and influenced by Loop Current eddies and transient deepwater currents. MMS requires that a geophysical assessment of the seafloor be conducted in the project area to indicate whether there is the potential for chemosynthetic communities to be present. Findings of the seafloor and geologic assessment for the Cascade and Chinook Development (GEMS 2007) are provided in the GEMS Shallow Hazards Report for Facilities and the Summary of Environmental Conditions for Cascade / Chinook included in Appendix 2.19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-23 Development Operations Coordination Document Cascade / Chinook Development Project According to a list of known high-density deepwater benthic communities, the proposed drilling, completion and production activities for the Cascade East Wells WR 206 No.6 and 7 and their associated jumper connectors would not be located within any of the areas of known communities: Alaminos Canyon, East Breaks, Garden Banks, or Green Canyon ( http://www.gomr.mms.gov/homepg/regulate/environ/knowndwbenthic.pdf ). Site-specific seafloor conditions were found that the abundance and diversity of infauna in the seafloor sediments was low. The soft bottom benthic community was dominated by polychaetes. No active faults, gas venting, or hard bottom conditions were identified within the Cascade Development Area. There is no potential for encountering chemosynthetic communities in the area planned for Cascade Development Wells. 19(b).4 Offshore Environments The Submerged Lands Act of 1953 and the Outer Continental Shelf Lands Act of 1953 affirms the federal claim to the lands of the Outer Continental Shelf (OCS) which have been addressed in previous section and these Acts outline the Federal responsibility over the submerged lands of the OCS and authorizes the Secretary of the Interior to lease those lands for mineral development ( http://www.boemre.gov/AboutBOEMRE/FedOffshoreLands.htm ). Under a Presidential Proclamation (5030) in 1983 by Ronald Reagan, a U.S. Exclusive Economic Zone was established extending 200 nautical miles (370 km) from the coastline. About 15 percent of the Zone lies on the continental shelf, 10-15 percent lies on the continental slope, and the remaining 70-75% is the Abyssal Plain in deepwater. Sigsbee Escarpment The project area consists of three geomorphologic provinces: the Lower Continental Slope, the Upper Continental Rise, and the Sigsbee Escarpment (GEMS 2007). The Sigsbee Escarpment marks the edge between the continental slope and rise of the GoM and is the seaward limit of the northern Gulf regional salt province. This escarpment extends for more than 370 miles and is formed by the underlying salt tectonics (Lee and George 2004). The escarpment includes large submarine canyons, numerous small submarine canyons and gullies, and large slumps. Relief along the escarpment can range from a few hundred to more than 3,300 feet (Lee and George 2004). Seafloor gradients in the Cascade / Chinook Development range from nearly 0o to approximately 70° along the steeper portions of the Sigsbee Escarpment (GEMS 2007). The water depth of Cascade / Chinook blocks 206, 249, 250, 425, 426, 469, and 470 is between 8,200 and 8,800 feet (2,500 to 2,682 m). The Sigsbee Escarpment runs through a portion of Block 205, resulting in a dramatic change in bathymetry from 8,000 feet to 5,800 feet (2,440 to 1,770 m) in less than two miles (3.22 km) (Petrobras America Inc. 2006). The locations of the proposed Cascade Wells WR 206 No. 6 and 7 are in Walker Ridge Block 206. Details about the seabed of the project site can be found in the seafloor and geologic assessment for the Cascade and Chinook Development (GEMS 2007) in Appendix 2.19 Environmental Impact Analysis (EIA)

Page 19-24 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Furrows The seafloor below the Sigsbee Escarpment in the Cascade / Chinook Development area is irregular due to seabed furrows and erosion by seafloor currents (GEMS 2007). These mega-furrows are aligned parallel to the base of the escarpment, and some have been reported to extend for more than 60 miles (Lee and George 2004). The erosional nature of the furrows indicates the presence of potentially strong bottom currents along the Sigsbee Escarpment indicating that bottom currents may occur up to 3.3 feet per second (100 cm/sec) and higher (Bryant et al. 2004; GEMS 2007). According to the site-specific geophysical and geotechnical data collected by PAI, in conjunction with Geoscience Earth and Marine Services (GEMS) in 2007 (see appendix 2a), the seabed in the Cascade Development Area is comprised of furrows and flukes resulting from seabed currents. Darker areas on the side scan data correspond with outcrops of firmer strata exposed by erosion due to the periodic strong currents in the area. The subbottom data confirms the side-scan revealing generally parallel and continuous clay stratigraphy that is eroded at the seabed. The furrows are irregular seabed undulations of unclear origin with a typical trough to crest spacing on the order of 50-300 feet (15.2-91.44 m), amplitudes on the order of 10-30 feet (3.05-9.14 m), and slopes in the range of 5 o to 20 o from horizontal. These furrows are generally trending northeast to southwest. Approximately 49,000 feet (14,935m) of the Cascade flowline route is within the furrows. Dense seafloor furrows are present in the southeastern portion of the Cascade area. The furrows are evident in the multi-beam data as linear features trending parallel to the escarpment. In general individual furrows average about 100 feet (30.48m) wide and 30 feet (9.14m) deep and have relatively steeply dipping walls. The furrows are tightly spaced, averaging between 75 and 100 feet (22.86 and 30.48 m) apart. These furrows also appear to branch and merge with each other. The exact nature of the seafloor current responsible for the varying appearance of the furrows in this area is not well understood at this time; however, it is possible that the dominant direction and/or intensity of the currents may vary over time. There are no hydrocarbon indicators suggesting hydrocarbon migration or seepage near the planned field development. Further details concerning the geomorphology of this area can be found in the seafloor and geologic assessment for the Cascade and Chinook Development (GEMS 2007) as described in Appendix 2. 19(b).5 Marine Mammals At least 29 species of cetaceans are known to occur in the GoM including five species listed as endangered and protected under the Endangered Species Act and all marine mammals are protected under the marine Mammals Protection Act of 1972 (Mullin, et al 1991). The marine mammals in the GoM comprise seven mysticetes (baleen whales) and 21 odontocetes (toothed whales and dolphins) as identified in Table 19-3. Other marine mammals include one introduced pinniped (California sea lion; Zalophus californianus ) and one sirenian species (West Indian manatee; Trichechus manatus ) (Davis, Evans and Wursig 2000). The West Indian manatee is divided into two subspecies: the Antillean19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-25 Development Operations Coordination Document Cascade / Chinook Development Project manatee ( T. manatus manatus ), which is not known to exist in the northern GoM, and the Florida manatee ( T. manatus latirostris ), which occurs mainly in Florida waters, but will travel to the west coast of Louisiana in extreme cases (US Fish and Wildlife Service [USFWS] 2000).
Table 19-3 – Marine Mammals in GoM

Common Name Scientific Name Status Abundance and Distribution 1 Estimated

Number of Individuals 2 Likelihood of Occurring

Near Site 3
Mysticetes Northern right whale Eubalaena

glacialis E Rare and likely of accidental
occurrence. Extralimital Unlikely

Blue whale Balaenoptera

musculus E Rare and likely of accidental
occurrence. Extralimital Unlikely

Fin whale Balaenoptera

physalus E Rare and likely of accidental
occurrence. Rare Unlikely

Sei whale Balaenoptera

borealis E Rare and likely of accidental
occurrence. Rare Unlikely

Bryde’s whale Balaenoptera

edeni * Common; sightings occurred only near 100- meter (328- foot) isobath 40 Unlikely

Minke whale Balaenoptera

acutorostrata * Although not coastal they rarely venture more than 169 km (105 miles) from shore. Rare Unlikely

Humpback whale Megaptera

novaeangliae E Rare and likely of accidental
occurrence. Rare Unlikely

Sowerby’s Beaked whale Mesoplodon

bidens Rare and likely of accidental
occurrence. Extralimital Unlikely19 Environmental Impact Analysis (EIA)

Page 19-26 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Common Name Scientific Name Status Abundance and Distribution 1 Estimated

Number of Individuals 2 Likelihood of Occurring

Near Site 3

Odontocetes Sperm whale Physeter

macrocephalus E Common; occurs from 900 to 2,000 meters (2,953 to 6,562 feet) and deeper with possible resident population
near Mississippi River delta. 1,349 Likely

Pygmy or dwarf sperm whale Kogia spp. * Widely distributed in deep waters of Gulf. 742 Likely

Beaked whale Ziphiid * Widely distributed from 1,000 meters (3,280 feet) and beyond. 241 Likely

Pygmy killer whale Feresa

attenuata * Uncommon but widely distributed in Northern Gulf. 408 Possibly

Pilot whale Globicephala

sp. * Uncommon on slope. 2,388 Unlikely

Risso’s dolphin Grampus

griseus * Frequently sighted along between 200 and 1,000 meters (656 and 3,280 feet), but concentrated
near Mississippi River delta. 2,169 Possibly

Melon-headed whale Peponocephala

electra * Uncommon in northeastern Gulf but possible in deeper waters. 3,451 Possibly19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-27 Development Operations Coordination Document Cascade / Chinook Development Project Common Name Scientific Name Status Abundance and Distribution 1 Estimated

Number of Individuals 2 Likelihood of Occurring

Near Site 3

Bottlenose dolphin Tursiops

truncates * Common; widely distributed between 100 and 750 meters (328 and 2,460 feet). 27,559 Likely

Rough-toothed dolphin Steno

bredanensis * Common; widely distributed on mid-slope. 2,223 Possibly

Striped dolphin Stenella

coeruleoalba * Most common cetacean; widely distributed on slope. 6,505 Likely

Pantropical spotted dolphin Stenella

attenuata * Common; widely distributed around 1,000- meter (3,280- foot) isobath. 91,321 Likely

Clymene’s dolphin Stenella

clymene * Common; widely distributed in water depths from 250 to 5,000 meters (820 to 16,404 feet). 17,355 Likely

Atlantic spotted dolphin Stenella

frontalis * Common; widely distributed on slope but rarely beyond the shelf edge near 100-meter (328-foot) isobath. 30,947 Possibly

Spinner dolphin Stenella

longirostris * Common; widely distributed on slope. 11,971 Possibly

Fraser’s dolphin Lagenodelphis

hosei * Uncommon but widely distributed. 726 Possibly19 Environmental Impact Analysis (EIA)

Page 19-28 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Common Name Scientific Name Status Abundance and Distribution 1 Estimated

Number of Individuals 2 Likelihood of Occurring

Near Site 3

Killer whale Orcinus orca * Uncommon but mainly found southwest of the Mississippi River delta. 133 Unlikely

False killer whale Pseudorca

crassidens * Uncommon throughout Northern Gulf, but mainly southwest of Mississippi River delta in pelagic waters. 1,038 Unlikely

Source: Davis et al . 2000; MMS 2000; Baumgartner et al. 2001; University of Michigan 2003; and Department of the Navy 2003; http://www.nefsc.noaa.gov/psb/assesspdfs.html. Notes: 1 Accurate depth ranges could not be found in the literature but “deep” is probably 1,000 meters (3,280 feet) and deeper. 2 Extralimital: known on the basis of only a few records that probably resulted from unusual wanderings of animals into the region (Würsig et al . 2000). Rare: present in such small numbers throughout the region that it is seldom seen (Würsig et al . 2000). 3 The likelihood determination was based on a compilation of surveys that indicated the number of individuals and occurrences of cetaceans close to the project site (Department of the Navy 2003), as well as a consideration of the distribution discussed in other literature. Key: > = greater than. * = Protected under the Marine Mammal Protection Act. E = Endangered under the Endangered Species Act. km = kilometers. Six species of whales (northern right [ Eubalaena glacialis ], blue [ Balaenoptera musculus ], fin [ B. physalus ], sei [ B. borealis ], humpback [ Megaptera novaeangliae ]), and sperm whale [ Physeter macrocephalus ]), are listed as endangered. All cetaceans occurring in the GoM, however, are protected under the MMPA of 1972, as presently amended. Except for the sperm whale, the other endangered cetaceans are known from only very few sightings and are considered to be rare or of accidental occurrence (Continental Shelf Associates [CSA] 2000; Table 19-3). While there is no federally designated critical habitat for endangered cetacean species in the Gulf, the deepwater region provides important habitat for these and other marine mammals (CSA 2000). Habitat preference varies with each cetacean type, but seems to be related to water depths, bottom conditions (Table 19-3; Baumgartner et al . 2001; Davis et al . 2000) andpotential prey (Davis et al 2000). Food stocks may be locally concentrated in nutrientrich areas offshore from the Mississippi River delta, within current eddies, and along current eddy interfaces (Davis et al 2000). On the continental shelf, the most frequently19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-29 Development Operations Coordination Document Cascade / Chinook Development Project occurring cetaceans are the bottlenose dolphin ( Tursiops truncatus ), Atlantic spotted dolphin ( Stenella frontalis ), and possibly the Bryde’s whale ( Balaenoptera edeni ; CSA 2000). The majority of cetaceans are typically found in deepwater on the continental shelf edge and slope, but much less frequently in water depths greater than 2,000 meters or in anticyclones (warm core rings). It appears that the deepwater cetaceans spend much of their time resting on the surface and then foraging at great depths (University of Michigan 2003). A marine resources report developed by the Department of the Navy (2003) describes the marine mammals of the Eastern GoM including the area around Warning Area W-92 located in the Central Gulf, north of the Cascade / Chinook Development. The movements of whales and dolphins are typically associated with feeding and breeding behavior, with some species (such as the humpback and northern right whale) making extensive annual migrations for breeding and mating (Department of the Navy 2003). In the GoM, oceanic cetaceans tend to aggregate around areas where the distribution and abundance of prey is the highest such as cyclonic eddies (Department of the Navy 2003). The high slopes and rugged topography of the Sigsbee Escarpment, as well as the occurrence of strong currents, may provide conditions that are conducive to nutrient upwelling. Infrequent but sometimes large groups of cetaceans have been sighted near the project area (Department of the Navy 2003) but the surveys are limited and there is not enough information available to determine if cetaceans regularly use the area for feeding or other purposes. The sperm whale is the only endangered odontocete species considered common and perhaps a resident in certain deepwater areas. Sperm whales have been observed throughout the GoM from the upper continental slope near the 100-meter isobath and beyond the seaward extent of the U.S. Exclusive Economic Zone (NOAA 2002). Based on their distribution, sperm whales show a preference for continental margins, sea mounts, and areas of upwelling where food is abundant (MMS 2001). They are also known to dive for two hours up to depths of 10, 498 feet (3,200 meters) or more to feed on squid (MMS 2000). The most well-known congregations occur along the shelf edge and slope in the vicinity of the Mississippi River Delta trough in water depths of 1,640 to 6,562 feet (500 to 2,000 meters). Data deficiencies remain, however, such as the duration of time spent in an area, their patterns of movement and their preferred feeding areas. The location of cyclonic features (cold core rings) in the GoM produces nutrient-enriched waters, which appears to be an important factor in determining cetacean distribution (MMS 2001). In general, cetaceans are found along the continental slope in areas of cyclonic circulation and confluence zones, which are high in primary productivity. Since cyclones in the GoM are dynamic, cetaceans will likely move in response to the movement of prey associated with these hydrographic features. Pelagic dolphin species (primarily bottlenose and Atlantic spotted) and possibly Bryde’s whale, appear to occur more often in relatively shallow waters north of the influence of these cyclonic features (Baumgartner et al . 2001; Davis et al . 2000).19 Environmental Impact Analysis (EIA)

Page 19-30 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project 19(b).6 Sea Turtles Five sea turtles, all federally protected under the ESA, are known to occur in the GoM. The Kemp’s ridley ( Lepidochelys kempii ), leatherback ( Dermochelys coriacea ), and hawksbill ( Eretmochelys imbricata ) are listed as endangered; the loggerhead is listed as threatened (Davis et al. 2000). The green sea turtle ( Chelonia mydas ) is listed as threatened; except for breeding populations in Florida, which are listed as endangered. See Table 19-4.
Table 19-4 – Sea Turtles in GoM

Common Name Scientific

Name Status Abundance and Distribution in Gulf of Mexico Likelihood of Occurring Near Site Loggerhead Caretta caretta T Common; widely distributed on Eastern Gulf shelf and slope; mostly near 328 ft (100 m) but some in water deeper than 3,280 ft (1,000 m). Possibly

Leatherback Dermochelys

coriacea E Common; widely distributed on shelf and slope. Possibly

Kemp’s ridley Lepidochelys

kempii E Occasional; occurs mainly in coastal areas. Unlikely

Hawksbill Eretmochelys

imbricata E Occasional; occurs mostly in shallow lagoons and coral reefs Unlikely

Green Chelonia mydas T/E Common in coastal areas. Unlikely
Source: Davis et al ., 2000. Key: Common = Estimated abundances above 200 individuals. T = Threatened. E = Endangered. Most sea turtles, with the possible exception of the leatherback, which is the most pelagic of the group, vary in their distributions depending on their life stage. Hatchlings actively swim away from their nesting beaches to zones of water mass convergence and/or floating Sargassum , which provide prey and shelter. Most then drift within prevailing oceanic currents for a number of years. Once juveniles reach a certain age/size range, they leave the pelagic habitat and travel to shallow waters on the continental shelf (CSA 2000). It is not known if adult sea turtles or juveniles in floating Sargassum mats would occur in the vicinity of the proposed project. Based on what is known about the distribution of loggerhead and leatherback sea turtles (Table 19-4) it is possible that adults of these species could be found in the area as transients. Refer to MMS (2006a) and NOAA (2002) for the current status of knowledge and life history information pertaining to marine turtles occurring in the Gulf of Mexico. Sea turtles nest on multiple beaches along the Texas coast, though Padre Island National Seashore is the only area in Texas where all five species that occur in the Gulf of Mexico have been recorded nesting. Kemp’s Ridley is the most common nesting species of sea19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-31 Development Operations Coordination Document Cascade / Chinook Development Project turtle in Texas, and the species’ nests were recorded at Bolivar Peninsula, Galveston Island, Brazoria County – North of Surfside, Surfside Beach, Bryan Beach, Matoagorda Peninsula, Matagorda Island, San Jose Island, Mustang Island, North Padre Island, Padre Island National Seashore, South Padre Island, and Boca Chica Beach in 2010. Loggerhead sea turtle and green sea turtle nests were also documented on Padre Island National Seashore in 2010 (U.S. National Park Service 2010). No significant colonies of nesting sea turtles have been documented in Louisiana or Mississippi (USFWS 2010). However, sea turtles may rarely nest on beaches of these states; for example, a loggerhead sea turtle nest was discovered on a man-made beach in Biloxi, Mississippi in 1990 (Hoggard 1991). 19(b).7 Pelagic Birds Pelagic birds are species adapted to life within marine environments spending much time migrating and foraging offshore at sea; often over deep ocean waters exceeding 656 feet (200 meters) in depth. Pelagic birds include penguins ( Sphenisciformes ), albatross ( Albatrosses ), petrels ( Procellaridae ), and pelicans ( Pelecaniformes ). All pelagic birds are protected by the Migratory Bird Treaty Act (USFWS 2002). Predominate species seen in offshore areas of the GoM include terns ( Sterna ), stormpetrels ( Hydrobatidae ), jaegers ( Stercorarius ), and laughing gulls ( Larus atricilla ). Surveys have determined water depth influences the distribution of species groups and individual species of seabirds, which vary both spatially and seasonally (MMS 1996). They live far from land most of the year, roosting on the water surface, except at breeding time when they return to nesting areas along coastlines. Environmental parameters, such as sea surface productivity, also affect seabird distribution (Davis et al . 2000). The highest species diversity of seabirds has been associated within cyclonic eddies, while the lowest species diversity occurred on the continental shelf (Davis et al . 2000). Other evidence shows that seabird groups tend to concentrate at fronts defined by steep temperature gradients (Ribic et al . 1997). Seabirds, especially migrating birds, are affected by offshore platforms in many ways. For most species, platforms provide a suitable stopover habitat. Birds that are fatigued from long migrations may use platforms and vessels to rest and feed. Many shorter distance migrants that spend the winter along the Gulf coast (such as wrens and sparrows) inadvertently overshoot the coastline during nocturnal migratory flights and end up over GoM waters. These birds, which are evolutionarily ill equipped to deal with the rigors of overwater migration, are among the heaviest users of platforms during certain seasons and the availability of platforms to rest probably enabled many individuals to return to land successfully (Russell 2005). Populations and distributions of these birds inhabiting offshore waters (outer continental shelf and abyssal areas) in the central GoM have not been well studied. Due to the proposed project’s distance offshore, it is not known whether migratory or threatened or endangered bird species occur near the project’s vicinity or would use the area during migration. Presence of these birds appears to be a function of sea surface properties: salinity, plankton, and other prey.19 Environmental Impact Analysis (EIA)

Page 19-32 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project 19(b).8 Marine Fisheries Offshore waters of the GoM support many economically and ecologically important shellfish and finfish fisheries. Marine habitats in the GoM support a varied and abundant fish fauna. Species found in a given area are related to variable ecological factors at the site, including salinity, primary productivity, and bottom substrate. These factors differ widely across the GoM. In addition, the pelagic, floating brown algae, Sargassum , has been found to support a diverse community of marine organisms including more than 100 species of fishes, as well as more than 170 species of invertebrates and four species of sea turtles around the world (Coston-Clements et al . 1991). Fish species associated with Sargassum in the North Atlantic and Gulf of Mexico are listed in Table 19-5. The primary assemblages that could occur near the proposed Cascade well sites include commercial pelagic species and deepwater finfish. The following sections provide general information on these resources, along with information associated with commercial and recreational pelagic fisheries.

Table 19-5 - Fish Species Associated with Sargassum

Species Common Name
Carcharhinus falciformis Silky shark
Carcharhinus limbatus Blacktip shark Carcharhinus longimanus Oceanic whitetip shark

Sardinella aurita Spanish sardine Cypselurus furcatus Spotfin flyingfish

Exocoetus obtusirostris Oceanic-two-wing flyingfish* Hemiramphus brasiliensis Ballyhoo Hyporhamphus unifasciatus Silverstripe halfbeak Parexocoetus brachypterus Sailfin flyingfish* Epinephelus inermis Marbled grouper* Rachycentron canadum Cobia*

Caranx bartholomaei Yellow jack* Caranx crysos Blue runner* Caranx hippos Crevalle jack*

Caranx latus Horse-eye jack*

Caranx ruber Bar jack* Decapterus macarellus Mackerel scad* Decapterus punctatus Round scad* Decapterus tabl Roughear scad* Elagatis bipinnulata Rainbow runner*

Naucrates ductor Pilotfish19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-33 Development Operations Coordination Document Cascade / Chinook Development Project Species Common Name
Selar crumenophthalmus Bigeye scad*

Seriola dumerili Greater amberjack* Seriola fasciata Lesser amberjack*

Seriola rivoliana Almaco jack*

Seriola zonata Banded rudderfish*

Trachurus lathami Rough scad* Coryphaena hippurus Dolphin* Rhomboplites hippurus Vermilion snapper*

Lobotes surinamensis Tripletail* Mugil cephalus Striped mullet* Mugil curema White mullet* Sphyraena barracuda Great barracuda* Bodianus pulchellus Spotfin hogfish* Thalassoma bifasciatum Bluehead* Unidentified Trichiuridae Snake mackerel* Acanthocybium solandri Wahoo* Euthynnus alleterattus Little tunny Katsuwonus pelamis Skipjack tuna

Thunnus albacares Yellowfin tuna

Thunnus atlanticus Blackfin tuna Xiphias gladius Swordfish* Istiophorus platypterus Sailfish* Makaira nigricans Blue marlin* Tetrapturus albidus White marlin* Source: Coston-Clements et al . 1991. Note: * = early life stage present (i.e. egg, larvae or juvenile). Pelagic Fish Fish species likely to be found in the offshore waters near the project site in the Walker Ridge Protraction Area are characterized as oceanic pelagic. Oceanic pelagic species occur mainly in deep, open ocean waters offshore from the shelf break. Oceanic pelagics occur throughout the GoM, especially at or beyond the shelf edge. They are reportedly associated with mesoscale hydrographic features such as fronts, eddies, and discontinuities. Common oceanic pelagic species include: tunas and wahoo ( Scombridae ), marlins and sailfish ( Istiophoridae ), swordfish ( Xiphias gladius ), dolphins19 Environmental Impact Analysis (EIA)

Page 19-34 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project ( Coryphaenidae ), and mako sharks ( Isurus sp.). Refer to Benfield and Shaw (2005) for detailed information on the presence of pelagic fish. Deepwater Fish In addition to the large pelagic species, predatory species such as halfbeaks, flyingfishes, driftfishes, and lesser known pelagics such as snake mackerels ( Gempylidae ), ribbonfish ( Trachipteridae ) and escolar ( Lepidocybium flavobrunneum ), occur throughout the GoM; especially at or beyond the shelf edge (MMS 2001). Lantern fish (Myctophids) are among the most abundant of oceanic fish. Almost all species of myctophids vertically migrate through the water column to feed in the upper zones (492 feet (150 m)) during the night and deeper zones (984 to 295 feet (300 to 900 m)) during the day. Other fish exist in the mesopelagic zone (656 to 3,281 feet (200 to 1,000 m)) and migrate in the water column, moving each night to correspond with feeding cycles. Their feeding habitat ranges from depths of 1,312 to 2,625 feet (400 to 800 m) into epipelagic waters, sometimes reaching the surface (CSA 2000). Demersal fish are those having either direct contact with the substrate or hovering above it. The most extensive surveys of demersal fish were conducted in the 1980s from two MMS sponsored studies. The data showed a decline in diversity with depth although this was not statistically significant (CSA 2000). Bathypelagic fish inhabit waters greater than 3,280 feet (1,000 meters) and seldom migrate into shallower waters. These fish have developed similar physiological adaptations, similar to the mesopelagic fish, in order to live in the deepwater environment. No studies to date have directly examined the bathypelagic fish in the Gulf (CSA 2000). It is possible that important pelagic species and other deepwater fish occur in or near the Cascade / Chinook development site particularly given the topographic relief provided by the Sigsbee Escarpment. 19(b).9 Commercial and Recreational Fisheries An estimated 2,000 species of fish are known in the GoM (MMS 2001) but only a small fraction of those are commercially harvested. Commercially important pelagic fish in the Gulf include dolphin, sharks, snake mackerels ( Gempylus serpens ), swordfish, tunas, and wahoo ( Acanthocybium solanderi ; CSA 2000). Commercial fishing efforts resulting in the highest economic returns for pelagic species include: (1) upper-ocean trolling for billfish, (2) mixed-depth long-lining for yellowfin tuna, and (3) deep-bottom trawling for royal red shrimp. However, the only type of vessel that would likely fish near the project site is related to the commercial pelagic longline fishery (CSA 2002). The gear associated with this fishery consists of a mainline of 700-pound or greater test monofilament that typically ranges in length from 10 to 45 miles (16 to 72 km). At regular intervals along the mainline, bullet-shaped floats are suspended and long sections of the gear are marked by radio beacons. Long lines of 200 to 400-pound test monofilament that are typically 100 to 200 feet in length are suspended from the mainline and set with baited hooks (Waring et al . 2007).19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-35 Development Operations Coordination Document Cascade / Chinook Development Project Longline sets targeting tunas are typically set at dawn and soak throughout the day with recovery near dusk. Those sets targeting swordfish are generally set at night. The total amount of time the gear remains in the water including set, soak, and haul times is typically 10-14 hours (Waring et al . 2007). The total number of vessels that reported fishing in the longline pelagic fishery in the GoM in 2004 was 69. However, the total fishing effort (i.e., number of hooks set) has increased throughout the 1990s and into this decade. The total number of hooks set in 2004 were 4.08 million, which represented 5,410 longline sets (Waring et al. 2007). The pelagic longline fishery occurs year round, both inside and outside the Exclusive Economic Zone, from Florida to Texas (Waring et al . 2007). Commercial landings of oceanic pelagic species of interest for Louisiana, Texas, and Mississippi are summarized in Table 19-6. The latest data available from NOAA Fisheries is annual landings by species for 2010 (NOAA 2010 http://www.st.nmfs.noaa.gov/st1/commercial/landings/annual_landings.html ). In 2010, more than 2.26 million pounds of yellowfin tuna were caught from the Gulf with 439,904 pounds off Louisiana (worth $1.4 million) accounting for nearly 20% of the total catch in the region down from 95% in 2005. According to the most recent data available from NOAA Fisheries Service, other tunas landed in the region for 2010 included albacore ( Thunnus alalunga ) , little tunny ( Euthynnus alletteratus ), and bigeye ( T. obesus ) ( NOAA 2010 http://www.st.nmfs.noaa.gov/st1/commercial/landings/annual_landings.html ).

Table 19-6 - Commercial Landings of Oceanic Pelagic Species
Species Pounds Value ($)
Louisiana S hark (various species) 1,074,253 706,340 Blackfin tuna NA NA Bluefin tuna 35,787 170,697 Yellowfin tuna 439,904 1,473,663 Swordfish 259,537 486,786 Texas Shark (various species) 4,837 3,112 Blackfin tuna 327 504 Bluefin tuna N/A N/A Yellowfin tuna 815 3,257 Swordfish 2,066 4,845 Mississippi Shark (various species) 3,676 1,103 Source: NOAA 20 10

. Significant fishing pressure has occurred to coastal and pelagic sharks as they are most often part of the bycatch from longline fisheries. A comparison between 2005 and 2010 commercial landings of ocean pelagic species reported in Table 19-6 reveals a decrease in 4 of the 5 species for Louisiana fishing, decrease in the one species reported for19 Environmental Impact Analysis (EIA)

Page 19-36 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Mississippi, and a slight increase in one species, blackfin tuna in Texas fishing with a significant decrease in another species, yellowfin tuna for Texas commercial fishing. Yellowfin tuna commercial landings have decreased by 80% in Louisiana and over 95% in Texas. Pelagic species range widely in the upper ocean zones and often travel over entire ocean basins. Coastal-pelagics are intermediate; occurring both inshore andbeyond the continental shelves, but are not known to move across the oceans. Deepdwelling species of the continental slope and beyond to 1,804 feet (550 m) include most cat sharks ( Scyliorhinidae ), and gulper sharks ( Centrophoridae ), in water depths ranging between 328 to 3,937 feet (100 and 1,200 m). Large commercial shark fisheries have occurred primarily off Louisiana (19.2% of 1998 landings in U.S.; Buck 2000). Of the 42 managed species in the Gulf, fourteen are known to have at least one life history stage occurring in deepwater (MMS 2001) which include sharks. Sharks occurring in deepwater include blacktip ( Carcharhinus limbatus ), bull ( Carcharhinus leucas ), dusky ( Carcharhinus obscurus ), silky ( Carcharhinus falciformis ), tiger ( Galeocerdo cuvier ), Atlantic sharpnose ( Rhizoprionodon terraenovae ), and longfin mako ( Isurus paucus ; MMS 2001). No commercial fishing is known for any deepdwelling shark species except for blacktip sharks, which also occur closer to shore. Other managed pelagic species and their known habitat requirements and spawning areas are provided in Table 19-7.19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-37 Development Operations Coordination Document Cascade / Chinook Development Project Table 19-7 - Pelagic Species and their Known Habitat Requirements and Spawning Areas

Common and Species Names Habitat Preferences Likelihood of Occurring Near Site
Atlantic swordfish ( Xiphias gladius ) Usually found in surface waters, but occasionally diving as deep as 650 meters. Possibly

Blue marlin ( Makaira nigricans ) Found at great distances from the continents as well as coastal regions, near deep waters such as near the Mississippi River. Likely

White marlin ( Tetrapturus albidus ) Usually found in water over 100 meters deep; often associated with upwellings and weed lines, and regions with benthic geographic features such as drop-offs, canyons, and shoals. Likely

Sailfish ( Istiophorus platypterus ) Most densely distributed in waters close to coasts and islands but spawning and larvae are known to occur in 100 meters and deeper. Possibly

Yellowfin tuna ( Thunnus albacares ) Have been found to dive as deep as 1,100 meters though they generally swim at much shallower depths, averaging 75 meters. Possibly

Skipjack tuna ( Katswonus pelamis ) Occur beyond the 200 meter contour. Possibly

Bluefin tuna ( Thunnus thynnus ) Swim at depths of 200 meters while diving to depths of approximately 1,000 meters. Possibly

Sources: NOAA 1999; Florida Museum of Natural History 2007; MMS 2001; Nakamura 1985; Dagorn et al . 2006; Block et al . 2001 19(b).10 Protected Fish Species Protected fish species within the Gulf of Mexico include the smalltooth sawfish ( Pristis pectinata ), which was once common from Texas to Florida and now only found in two critical habitats: sheltered bays north of Fort Meyers, Florida and the southern tip of Florida ( http://www.nmfs.noaa.gov/pr/species/fish/smalltoothsawfish.htm .) No federally listed fish species are predicted to occur in proximity to the proposed Cascade well sites. Table 19-8 lists candidate fish species currently not protected under the ESA but concerns about their status indicate they may warrant listing in the future (NOAA 2007b). Deepwater species are speckled hind ( Epinephelus drummondhayi ) and Warsaw grouper ( Epinephelus nigritus ), which inhabit steep and rocky ledges on the continental slope with depths to approximately 1,800 feet (525 meters); but are not known to occur in the project area (Heemstra and Randall 1993; MMS 2001).19 Environmental Impact Analysis (EIA)

Page 19-38 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Table 19-8 – Protected Fish and Marine Mammals Species
Candidate Species (year added) Scientific Name Dusky shark (1997) Carcharhinus obscurus Sand tiger shark (1997) Odontaspis taurus Night shark (1997) Carcharhinus signatus
Speckled hind (1997) Epinephelus drummondhayi
Warsaw grouper (1997) Epinephelus nigritus Nassau grouper (1991) Epinephelus striatus
Gulf sturgeon (1991) Acipenser oxyrinchus desotoi Shortnose sturgeon (1967) Acipenser brevirostrum
Smalltooth sawfish (2003) Pristis pectinata Blue whale (1970) Balaenoptera musculus Finback whale (1970) Balaenoptera physalus
Humpback whale (1970) Megaptera novaeangliae
North Atlantic right whale (1970) Eubalaena glacialis Sei whale (1970) Balaenoptera borealis
Sperm whale (1970) Physeter macrocephalus

Source: NOAA 2007b and 2011 19(b).11 Essential Fish Habitat Essential Fish Habitat (EFH), defined by National Marine Fisheries Service (NMFS) as waters and substrate necessary for fish to spawn, breed, feed, and grow to maturity, was previously identified throughout the Gulf of Mexico. The Generic Amendment #3 to all Gulf of Mexico Fishery Management Plans reduced the extent of EFH by removing EFH designation from waters between 600 feet (183 meters or 100 fathoms) and the seaward limit of the Exclusive Economic Zone (as deep as 10,499 feet (3,200 meters). Due to the wide variation of habitat requirements for all life history stages of managed fish, essential fish habitat (EFH) for the GoM includes all estuarine and marine waters and substrates from the shoreline to the 100 fathom contour located along the break of the continental shelf (GoM Fishery Management Council 2005). The Department of the Navy (2003) contains a good description of these shelf edge features, which range in water depths from 174 to 427 feet (53 to 130 m), but are located at least 70 miles (112.7 km) north of the project site. The Walker Ridge block, containing the project site, no longer has a blanket designation as EFH but does retain EFH designation for some specific species, including many highly migratory species such as sharks, tunas, swordfish, and sailfish. Because of the broad designations associated with EFH, Habitat Areas of Particular Concern HAPCs) have been designated to help focus EFH conservation priorities.19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-39 Development Operations Coordination Document Cascade / Chinook Development Project NOAA’s web site http://www.habitat.noaa.gov/protection/efh/habitatmapper.html maps EFH for designated species including bluefish, Although generally small areas within the EFH, HAPCs provide extremely important ecological functions and/or are considered to be especially vulnerable to degradation (McKay et al. 2002). HAPC in the Northwestern GoM are identified as: East and West Flower Garden Banks, Stetson Bank, Sonnier Bank, MacNeil Bank, 29 Fathom, Rankin Bright Bank, Geyer Bank, McGrail Bank, Bouma Bank, Rezak Sidner Bank, Alderice Bank, and Jakkula Bank (Federal Register Notice 2005). All of these areas are greater than 100 miles (161 km) from the proposed development. 19(b).12 Social and Economic Conditions This section summarizes the social and economic conditions around the proposed onshore support facilities and other ports potentially used by the Cascade development. The project area would likely include the use of onshore support facilities in two states: Louisiana (primary) and Texas (secondary). Port Fourchon, Louisiana would serve as the primary onshore support base. Shuttle tankers would transport crude from the FPSO to terminals located in Texas, Louisiana, and Mississippi, and it may be more likely that terminals in Louisiana and Texas will be used more frequently than Mississippi because there are more with larger capacities. Wastes would be brought to shore at several existing facilities in Galiano, Louisiana (primary) and Texas (secondary). Refer to Section 16 for additional details on Onshore Support Facilities Information. Population The population near the Gulf Coast has been increasing steadily since the 1970s. From 2000 until 2030, the region is projected to experience a doubling of the population (MMS 2006a). Increased interest in deepwater energy production will continue to influence this trend. For every million dollars invested in offshore projects, 20 jobs are created and for every 10 jobs created offshore, 37 jobs are created onshore (MMS 2001) therefore, every million dollars invested creates 74 jobs onshore. The MMS estimates an average deepwater project would require approximately 400 employees, both on and offshore. These employees are expected to be drawn from the current labor force residing in the GoM coastal region (MMS 2001). In addition, employment demands from outside of the GoM coastal area may also be required, creating in-migration of skilled labor. Port Fourchon has seen a decrease in unemployment since 1990; largely due to the boom in the offshore energy industry during the 1990s (MMS 2001). The region’s coastal economic zone employment projections show an across the board increase, approximately 45%, including employment in the oil and gas industry and related services (MMS 2006a). In general, the FPSO vessel would be staffed with approximately 35-45 personnel during normal production operations. Others would be employed on the shuttle vessels, drilling rigs, and offshore construction vessels. The total number employed offshore on the Cascade / Chinook development would not approach a level posing a significant impact to any particular labor market.19 Environmental Impact Analysis (EIA)

Page 19-40 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project The population numbers and employment by industry for the affected states of Texas, Louisiana, and Mississippi, with emphasis on counties and parishes where onshore support facilities for the project may be located, are described below. Data for this section was obtained from the 2010 U.S. Economic Census, which was the most recent U.S. Economic Census completed at the time of preparing this supplemental DOCD, as well as the most recent (December 2010) Bureau of Labor Statistics unemployment statistics.
Texas As of the 2010 U.S. Economic Census, approximately 24.2% of the total Texas population (25,145,561) lived in coastal counties (6,078,043). In Texas, refineries that are being considered for the receipt of crude oil from the project are located in Corpus Christi (Nueces County), Freeport (Brazoria County), Houston-Galveston (Harris and Galveston counties), and Port Arthur-Beaumont (Jefferson County). The population numbers in these counties from the 2010 U.S. Economic Census are presented in Table 19-9. Table 19-9 Population in Counties Where Onshore Support Facilities may be Located
County Population Nueces County 340,223 Brazoria County 313,166 Harris County 4,092,459 Galveston County 291,309 Jefferson County 252,273
Source: U.S. Census Bureau 2010 Based on the 2010 Bureau of Labor Statistics , the top three industries in Texas, in terms of the number of people employed, are business administration (1,741,210 people), retail trade (1,106,390 people) and food preparation (860,620 people) (U.S. Bureau of Labor Statistics 2011). Construction, including mining, quarrying, and oil and gas extraction employed 519,040 people, and manufacturing, which includes petroleum refining, employed 623,680 people as of 2010 (U.S. Bureau of Labor Statistics 2011). The top three industries by number of paid employees for each five analyzed Texas counties are presented in Table 19-10.19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-41 Development Operations Coordination Document Cascade / Chinook Development Project Table 19-10 Top Three Industries by Number of Paid Employees in Texas Counties

Where Onshore Support Facilities may be Located

County Industry Number of Paid Employees

Nueces County Health care and social assistance 24,413 Retail trade 16,877 Accommodation and food services 15,167

Brazoria County Manufacturing 13,787 Retail trade 11,791 Accommodation and food services 7,330

Harris County Administrative and support and waste

management and remediation services 240,164
Health care and social assistance 205,171

Retail trade 183,618

Galveston County Health care and social assistance 14,414 Accommodation and food services 12,643

Retail trade 10,790

Jefferson County Health care and social assistance 17,840 Manufacturing 15,460 Retail trade 14,764
Source: U.S. Census Bureau 2007 The statewide unemployment in Texas was 8.0% in December of 2010. Brazoria County (8.8%), Harris County (8.3%), Galveston County (9.2%), and Jefferson County (11.5%) all had higher unemployment rates than the state of Texas overall. Only Nueces County had a lower unemployment rate (7.9%) (U.S. Department of Labor 2010).
Louisiana As of the 2010 U.S. Economic Census, approximately 19.7% of the total Louisiana population (4,533,372) lived in coastal counties (892,397). In Louisiana, refineries that are being considered for the receipt of crude oil from the project are located in Lake Charles (Calcasieu Parish), Baton Rouge (West Baton Rouge Parish and East Baton Rouge Parish), the Lower Mississippi River (St. Charles Parish), and Port Fourchon (Lafourche Parish) which would also serve as the project’s primary onshore support base. The population numbers in these five parishes from the 2010 U.S. Economic Census are presented in Table 19-11.19 Environmental Impact Analysis (EIA)

Page 19-42 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Table 19-11 Population Numbers in Louisiana Parishes Where Onshore Support Facilities may be Located
Parish Population Calcasieu Parish 192,768 West Baton Rouge Parish 23,788 East Baton Rouge Parish 440,171 St. Charles Parish 52,780 Lafourche Parish 96,318
Source: U.S. Census Bureau 2010 Based on the 2010 Bureau of Labor Statistics, the top three industries in Louisiana in terms of the number of people employed are business administration (290,970 people), retail trade (198,990 people) and food services (160,260) (U.S. Bureau of Labor Statistics 2011). Mining, quarrying, and oil and gas extraction employed 112,430 people, and manufacturing, which includes petroleum refining, employed 110,730 people as of 2010 (U.S. Bureau of Labor Statistics 2011). The top three industries by number of paid employees for each for the five analyzed parishes are presented in Table 19-12.

Table 19-12 Top Three Industries by Number of Paid Employees in Louisiana Parishes Where Onshore Support Facilities may be Located

Parish Industry Number of Paid Employees

Calcasieu Parish Retail trade 13,413 Health care and social assistance 11,022 Accommodation and food services 8,997

West Baton Rouge Parish Construction 2,422 Manufacturing 1,624 Retail Trade 1,421

East Baton Rouge Parish Retail trade 38,780 Health care and social assistance 38,732 Construction 23,193

St. Charles Parish Manufacturing 5,859 Construction 3,782 Retail trade 2,973

Lafourche Parish Retail trade 6,632 Manufacturing 4,926 Administrative and support and waste management and remediation services 4,340

Source: U.S. Census Bureau 2011 The statewide unemployment in Louisiana was 7.2% in December of 2010. Calcasieu Parish (6.7%), East Baton Rouge Parish (6.8%), St. Charles Parish (6.3%), and Lafourche19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-43 Development Operations Coordination Document Cascade / Chinook Development Project Parish (4.9%) all had lower unemployment rates than the state of Louisiana overall. Only West Baton Rouge Parish had a higher unemployment rate (8.1%) (U.S. Department of Labor 2010).
Mississippi As of the 2010 U.S. Economic Census, approximately 14.4% of the total Mississippi population (2,967,297) lived in coastal counties (426,536). In Mississippi, only one refinery in Pascagoula, Jackson County is being considered for the receipt of crude oil from the project. Jackson County had a population of 139,668 people in 2010 (U.S. Census Bureau 2007). The top three industries in Mississippi in terms of the number of paid employees are business administration (165,670), retail sales (113,710), and manufacturing which includes petroleum refining (101,700 people). Mining, quarrying, and oil and gas extraction employed 5,923 people in Mississippi as of 2007. Similarly, the top three industries in Jackson County in terms of the number of paid employees are manufacturing (10,000 – 24,999 people), retail trade (5,356 people), and health care and social assistance (5,343 people) (U.S. Census Bureau 2007). The statewide unemployment rate in Mississippi was 9.7% in December of 2010. Jackson County had a slightly lower unemployment rate of 9.5% (U.S. Department of Labor 2010). Minority and Lower Income Groups There are areas of low income communities and areas of significant minority populations within the GoM region. Coastal cultures and populations include the Hispanic enclaves of south Texas, the Acadian “French Triangle” of south Louisiana, Amerindian peoples such as the Houma of Louisiana, and the Vietnamese communities of coastal Texas, Louisiana, and Mississippi. The State of Louisiana alone contains numerous cultural groups of Native American, African, European, Asian, Latin American, and Middle Eastern origins (MMS 2006a). Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Population s, mandates that federal agencies identify and address as appropriate, disproportionately high and adverse human health or environmental effects that the programs may have on minority and low income populations. Information on race, ethnicity, and income characteristics of the affected states of Texas, Louisiana, and Mississippi, with emphasis on counties and parishes where refineries may receive crude oil from the project, are described below. At the time of the preparation of this supplemental DOCD to address the proposed Cascade wells the 2010 U.S. Census data was still being processed; therefore, 2000 U.S. Census data was used where 2010 data was not yet available.19 Environmental Impact Analysis (EIA)

Page 19-44 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Texas Census data for 2010 reveals that for Texas, the majority (70.4%) of the Texas population is white, and 37.6% of the population considers itself Hispanic or Latino, regardless of race. Race and ethnicity data from the 2010 U.S Census for the state of Texas and the five analyzed counties in Texas are summarized below in Table 19-13.

Table 19-13 Race and Ethnicity Characteristics of the State of Texas and Texas

Counties Where Onshore Support Facilities may be Located

CategoryNuecesCountyBrazoriaCountyHarrisCountyGalvestonCountyJeffersonCountyStateofTexas

Total Population 340,223 313,116 4,092,459 291,309 252,273 25,145,561RaceandEthnicity White 81.5% 70.1% 56.6% 72.5% 52.5% 70.4% Black or African American 4% 12.1% 18.9% 13.8% 33.8% 11.8%

American Indian and Alaska Native 0.6% 0.6% 0.7% 0.6% 0.5% 0.7%

Asian 1.7% 5.5% 6.2% 3.0% 3.4% 3.8%
Native Hawaiian or Pacific Islander 0.1% - 0.1% 0.1% - 0.1%

Two or More Races 2.4% 2.6% 3.2% 2.7% 2.0% 2.7%

Hispanic or Latino (of any race) 60.6% 27.7% 40.8% 22.4% 17.0% 37.6%

Source: U.S. Census Bureau 2011 As of the 2011 U.S. Census, 17.1% of families in Texas lived below poverty level, the median household income in Texas was $48,286, and 62.0% of the Texas population over 16 years old was in the labor force. Economic characteristics data from the 2010 U.S Census for the state of Texas and the five analyzed Texas counties are summarized below in Table 19-14.19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-45 Development Operations Coordination Document Cascade / Chinook Development Project Table 19-14 Economic Characteristics of the State of Texas and Texas Counties

Where Onshore Support Facilities may be Located

CategoryNuecesCountyBrazoriaCountyHarrisCountyGalvestonCountyJeffersonCountyStateofTexas

Population under 18 Years 26.9% 27.8% 28.9% 26.1% 24.7% 27.8%

Population Over 65 11.6% 9.4% 8.1% 14.0% 13.0% 10.2%

Median Household Income in 2009 (Dollars) 41,009 66,516 50,577 55,883 41,087 48,286

Total Family Households 116,896 100,617 1,358,313 107,133 92,822 8,269,046

Families Below Poverty Level Income 19.9% 10.0% 17.1% 14.7% 19.1% 17.1%

Source: U.S. Census Bureau 2011 and http://quickfacts.census.gov/qfd/states/48000.html

Louisiana Census data on race and ethnicity and economic characteristics in Louisiana from the 2010 U.S. Census was available at the time of preparing this section. The majority of the state of Louisiana is white (62.6%), with black or African American as the next highest racial group (32.0%). Only 4.2% of the population considers themselves Hispanic or Latino regardless of race. West Baton Rouge and East Baton Rouge parishes have a higher percentage of minorities than the state of Louisiana as a whole. West Baton Rouge Parish is 60.0% white (40.0% minority) and East Baton Rouge Parish is 48.8% white (51.2% minority). Like the state of Louisiana as a whole, the highest population minority group in West Baton Rouge and East Baton Rouge parishes is black or African American (37.7% West Baton Rouge Paris; 45.3% East Baton Rouge Parish). All of the five parishes analyzed have a lower percent Hispanic or Latino population than the state as a whole. Race and ethnicity data from the 2010 U.S Census for the state of Louisiana and the five analyzed Louisiana parishes are summarized below in Table 19-15.19 Environmental Impact Analysis (EIA)

Page 19-46 Petrobras America Inc. Development Operations Coordination Document Cascade / Chinook Development Project Table 19-15 Race and Ethnicity Characteristics of the State of Louisiana and Louisiana Parishes Where Onshore Support Facilities may be Located

CategoryCalcasieuParishWestBatonRougeParishEastBatonRougeParishSt.CharlesParishLafourcheParishStateofLouisiana

Total Population 192,768 23,788 440,171 52,780 96,318 4,533,372RaceandEthnicity White 70.8% 60.0% 48.8% 69.2% 79.4% 62.6% Black or African American 24.8% 37.7% 45.3% 26.6% 13.2% 32.0%

American Indian and Alaska Native 0.5% 0.1% 0.2% 0.3% 2.8% 0.7%

Asian 1.1% 0.3% 2.8% 0.8% 0.7% 1.5%
Native Hawaiian or Pacific Islander - - - - - -

Two or More Races 1.9% 1.1% 1.3% 1.6% 1.8% 1.6%

Hispanic or Latino (of any race) 2.6% 2.3% 3.7% 5.0% 3.8% 4.2%

Source: U.S. Census Bureau 2010 As of the 2010 U.S. Census, 17.6% of families in Louisiana lived below poverty level, the median household income in Louisiana was $42,460, and 62.7% of the Louisiana population over 16 years old and was in the labor force. Economic characteristics data from the 2010 U.S Census for the state of Louisiana and the five analyzed Louisiana parishes are summarized in Table 19-16.19 Environmental Impact Analysis (EIA)

Petrobras America Inc. Page 19-47 Development Operations Coordination Document Cascade / Chinook Development Project Table 19-16 Economic Characteristics of the State of Louisiana and Louisiana Parishes Where Onshore Support Facilities may be Located

CategoryCalcasieuParishWestBatonRougeParishEastBatonRougeParishSt.CharlesParishLafourcheParishStateofLouisiana

Population under 18 25.8% 25.1% 25.3% 26.9% 24.5% 25.0%
Population Over 65 12.7% 10.8% 14.0% 9.9% 12.3% 12.3%

Median Household Income in 2009 (Dollars) 43,534 45,167 34,958 56,869 47,909 42,460

Total Families 72,603 8,698 9,790 18,180 33,670 1,644,094

Families Below Poverty Level Income 16.4% 14.4% 19.3% 12.0% 15.5% 17.6%

Source: U.S. Census Bureau 2010 Mississippi Census data on race, ethnicity, and economic characteristics in Mississippi from the 2010 U.S. Census was available at the time of preparing this supplemental DOCD. The majority of the state of Mississippi is white (59.1%), and black or African American individuals account for the next highest percentage of the population (37.0%). Jackson County is also predominantly white (72.1%), and black or African American individuals account for 21.5% of the county’s population. Race and ethnicity data from the 2010 U.S Census for the state of Mississippi and Jackson County are summarized in Table 19-17.