U.S. Department of the Interior

Minerals Management Service 

Gulf of Mexico OCS Region 

OCS EIS/EA 

MMS 2009-053 

Proposed Gulf of Mexico OCS 

Oil and Gas Lease Sale 213 

Central Planning Area 

Environmental Assessment 
U.S. Department of the Interior

Minerals Management Service 

Gulf of Mexico OCS Region 

OCS EIS/EA 

MMS 2009-053 

Proposed Gulf of Mexico OCS 

Oil and Gas Lease Sale 213 

Central Planning Area 

Environmental Assessment 

Author 

Minerals Management Service 

Gulf of Mexico OCS Region 

Published by 

New Orleans

October 2009 

Environmental Assessment iii 

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TABLE OF CONTENTS 

Page 

FIGURES......................................................................................................................................................

TABLES .......................................................................................................................................................

ABBREVIATIONS AND ACRONYMS ...................................................................................................

1. OBJECTIVES OF THE ENVIRONMENTAL ASSESSMENT ............................................................

2. PURPOSE OF AND NEED FOR THE PROPOSED ACTION.............................................................3

3. ALTERNATIVES INCLUDING THE PROPOSED ACTION .............................................................

3.1. Alternative A—Proposed Action ................................................................................................

3.2. Alternatives to the Proposed Action ...........................................................................................

3.3. Mitigation Measures ...................................................................................................................

3.3.1. Summary of Stipulations Discussed in the Multisale EIS............................................7

3.3.2. Information to Lessees .................................................................................................

3.3.3. Existing Mitigations .....................................................................................................

3.3.4. Notices to Lessees and Operators...............................................................................

3.3.5. Monitoring..................................................................................................................

4. IMPACT ANALYSIS...........................................................................................................................

4.1. Update of Projections of Potential Activity from the Proposed Action....................................

4.1.1. Offshore Impact-Producing Factors and Scenario .....................................................

4.1.2. Coastal Impact-Producing Factors and Scenario........................................................

4.1.3. Hurricanes ..................................................................................................................

4.2. Environmental and Socioeconomic Resources .........................................................................

4.2.1. Air Quality..................................................................................................................

4.2.2. Water Quality .............................................................................................................

4.2.3. Sensitive Coastal Environments.................................................................................

4.2.3.1. Coastal Barrier Beaches and Associated Dunes........................................

4.2.3.2. Wetlands....................................................................................................

4.2.3.3. Seagrass Communities ..............................................................................

4.2.4. Sensitive Offshore Benthic Resources .......................................................................

4.2.4.1. Continental Shelf Benthic Resources........................................................

4.2.4.1.1. Live Bottoms (Pinnacle Trend) ..............................................

4.2.4.1.2. Topographic Features.............................................................

4.2.4.2. Continental Slope and Deepwater Resources............................................

4.2.4.2.1. Chemosynthetic Deepwater Benthic Communities................

4.2.4.2.2. Nonchemosynthetic Deepwater Benthic Communities..........

4.2.5. Marine Mammals .......................................................................................................

4.2.6. Sea Turtles..................................................................................................................

4.2.7. Alabama, Choctawhatchee, St. Andrew, and Perdido Key Beach Mice ....................

4.2.8. Coastal and Marine Birds...........................................................................................

4.2.9. Endangered and Threatened Fish ...............................................................................

4.2.9.1. Gulf Sturgeon............................................................................................

4.2.10. Fish Resources and Essential Fish Habitat.................................................................
iv Table of Contents

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4.2.11. Commercial Fishing ...................................................................................................

4.2.12. Recreational Fishing...................................................................................................

4.2.13. Recreational Resources ..............................................................................................

4.2.14. Archaeological Resources ..........................................................................................

4.2.15. Human Resources and Land Use................................................................................

4.2.15.1. Land Use and Coastal Infrastructure.........................................................

4.2.15.2. Demographics ...........................................................................................

4.2.15.3. Economic Factors......................................................................................

4.2.15.4. Environmental Justice ...............................................................................

5. CONSULTATION AND COORDINATION ......................................................................................

5.1. Scoping for the Environmental Assessment for the Central Planning Area’s Proposed 

Lease Sale 213 ..........................................................................................................................

5.2. Consultation and Coordination Calendar..................................................................................

6. REFERENCES .....................................................................................................................................

7. PREPARERS ........................................................................................................................................
Environmental Assessment v 

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FIGURES 

Page 

Figure 1. Gulf of Mexico Outer Continental Shelf Planning Areas, and Proposed Lease Sale Area.....3

Figure 2. Location of Proposed Stipulations and Deferrals....................................................................

Figure 3. Offshore Subareas in the Proposed Sale Area.......................................................................

Figure 4. Status of Ozone Attainment in the Coastal Counties and Parishes of the Central and 

Western Gulf of Mexico (USEPA, 2009b). ..........................................................................

Figure 5. Economic Impact Areas in the Gulf of Mexico. ...................................................................

TABLES 

Page 

Table 1. Offshore Scenario Information Related to Proposed Lease Sale 213 ...................................

Table 2. Aggregate Average Lag in Months from Sales to First Spud for Leases Issued from 

1983 to 1999 .........................................................................................................................

Table 3. Aggregate Average Lag in Months from Sales to First Production for Leases Issued 

from 1983 to 1999.................................................................................................................

Table 4. U.S. Domestic Landings for the Gulf of Mexico and Gulf States, 2007 and 2008...............

Table 5. Projected Employment Associated with Proposed Lease Sale 213 by Economic Impact 

Area.......................................................................................................................................
Environmental Assessment vii 

ABBREVIATIONS AND ACRONYMS 

5-Year Program Outer Continental Shelf Oil and Gas Leasing Program: 2007-2012

ac acre 

APD Application for Permit to Drill 

API American Petroleum Institute 

bbl barrel 

BBO billion barrels of oil 

BO Biological Opinion 

CAAA Clean Air Act Amendments of 1990 

Call Call for Information and Nominations 

CD Consistency Determination 

CFR Code of Federal Regulations 

CIAP Coastal Impact Assistance Program 

COE Corps of Engineers 

CPA Central Planning Area 

CSA Continental Shelf Associates 

CWPPRA Coastal Wetlands Planning, Protection, and Restoration Act 

CZM coastal zone management 

DOD Department of Defense 

EA environmental assessment 

EDP exploration, development, and production 

EFH essential fish habitat 

EIA economic impact area 

EIS environmental impact statement 

EPA Eastern Planning Area 

ESA Endangered Species Act of 1973 

FDEP Florida Dept. of Environmental Protection 

FEMA Federal Emergency Management Agency 

FONNSI Finding of No New Significant Impact 

FR Federal Register

ft feet 

FWS Fish and Wildlife Service 

GMAQS Gulf of Mexico Air Quality Standards 

GNOCDC Greater New Orleans Community Data Center 

GOM Gulf of Mexico 

GOMR Gulf of Mexico Region 

GPS global positioning system 

GS Geological Survey (also USGS) 

ha hectare 

km kilometer 

LCA Louisiana Coastal Area 

LDNR Louisiana Dept. of Natural Resources 

LED Louisiana Economic Development 

LMA labor market areas 

LUMCON Louisiana Universities Marine Consortium 

m meter 

mi mile 

MMPA Marine Mammal Protection Act of 1972 

MMS Minerals Management Service 

MODU mobile offshore drilling unit 

MRFSS Marine Recreational Fisheries Statistics Survey 

Multisale EIS Gulf of Mexico OCS Oil and Gas Lease Sales: 2003-2007; Central Planning Area 

Sales 185, 190, 194, 198, and 201; Western Planning Area Sales 187, 192, 196, 

and 200; Final Environmental Impact Statement; Volumes I and II
viii Abbreviations and Acronyms 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act 

NMFS National Marine Fisheries Service (also known as NOAA Fisheries Service) 

nmi nautical mile 

NO2 nitrogen dioxide 

NOx nitrogen oxide 

NOAA National Oceanic and Atmospheric Administration 

NOAA Fisheries 

 Service Department of Commerce agency also known as NMFS 

NOAA-OE National Oceanic and Atmospheric Administration, Office of Ocean Exploration 

NOI Notice of Intent to Prepare an EIS 

NOP Notice of Preparation 

NPDES National Pollution Discharge Elimination System 

NPS National Park Service 

NRS National Response Center 

NTL Notice to Lessees and Operators 

OCD Offshore and Coastal Dispersion 

OCS Outer Continental Shelf 

PM2.5 particulate matter smaller than 2.5 microns 

PM10 particulate matter smaller than 10 microns 

PSD Prevention of Significant Deterioration 

ROV remotely operated vehicle 

RP Recommended Practice 

RPM reasonable and prudent measure 

SEA site-specific environmental assessment 

SO2 sulphur dioxide 

Supplemental EIS Gulf of Mexico OCS Oil and Gas Lease Sales: 2009-2012; Central Planning Area 

Sales 208, 213, 216, and 222; Western Planning Area Sales 210, 215, and 218—

Final Supplemental Environmental Impact Statement

Tcf trillion cubic feet 

U.S. United States 

U.S.C. United States Code 

USCG U.S. Coast Guard 

USDOC U.S. Department of Commerce 

USDOI U.S. Department of the Interior 

USEPA U.S. Environmental Protection Agency 

USGS U.S. Geological Survey (also GS) 

VGP vessel general permit 

WPA Western Planning Area 
Environmental Assessment 1 

1. OBJECTIVES OF THE ENVIRONMENTAL ASSESSMENT 

This environmental assessment (EA) addresses one proposed Federal action: oil and gas Lease Sale 

213 in the proposed lease sale area of the Central Planning Area (CPA) of the Gulf of Mexico (GOM) 

Outer Continental Shelf (OCS) as scheduled in the Outer Continental Shelf Oil and Gas Leasing Program 

2007-2012 (5-Year Program) (USDOI, MMS, 2007b). This EA incorporates by reference all of the 

relevant material in the Multisale environmental impact statement (EIS) from which it tiers (Gulf of 

Mexico OCS Oil and Gas Lease Sales: 2007-2012; Western Planning Area Sales 204, 207, 210, 215, and 

218; Central Planning Area Sales 205, 206, 208, 213, 216, and 222—Final Environmental Impact 

Statement; Volumes I and II (Multisale EIS) (USDOI, MMS, 2007a). This EA also incorporates by 

reference all of the relevant material in the Supplemental EIS from which it tiers (Gulf of Mexico OCS Oil 

and Gas Lease Sales: 2009-2012; Central Planning Area Sales 208, 213, 216, and 222; Western 

Planning Area Sales 210, 215, and 218—Final Supplemental Environmental Impact Statement 

(Supplemental EIS) (USDOI, MMS, 2008a). This EA has been prepared to aid in the determination of 

whether or not new available information indicates that the proposed lease sale would result in new 

significant impacts not addressed in the Multisale EIS or the Supplemental EIS. The Minerals 

Management Service (MMS) is preparing a Coastal Zone Management Consistency Determination (CD) 

for proposed Lease Sale 213, per the requirements of 15 CFR 930 Subpart C. Analyses in this EA are 

incorporated by reference into the CD, as appropriate, for resources and uses for each of the affected 

States. 

In preparation for this EA, the U.S. Department of the Interior (USDOI), MMS reexamined the 

potential environmental effects of proposed Lease Sale 213 and the alternatives based on any new 

information regarding potential impacts and issues not available at the time MMS published the 

Supplemental EIS in September 2008. New information was reviewed to determine if any resources 

should be reevaluated or if the new information would alter conclusions of the Multisale EIS and the 

Supplemental EIS. No new information was found that would necessitate a reanalysis of the impacts of 

proposed Lease Sale 213 upon any of the environmental or socioeconomic resources. The analyses, 

potential impacts, and conclusions detailed in the Multisale EIS and the Supplemental EIS apply for 

proposed Lease Sale 213. 

Federal regulations allow for an agency to analyze related or similar proposals in one EIS (40 CFR 

1502.4). Since CPA Lease Sales 205, 206, 208, 213, 216, and 222 and their projected activities are very 

similar, MMS prepared a single EIS for the six lease sales. The multisale approach focuses the National 

Environmental Policy Act (NEPA) EIS process on the differences between the proposed lease sales and 

new information and issues. Although the Multisale EIS addressed six proposed CPA lease sale actions 

and the Supplemental EIS addressed four proposed lease sales, the Secretary of the Interior (Secretary) 

makes a separate decision for each lease sale. 

The Multisale EIS and the Supplemental EIS can be obtained from the Minerals Management 

Service, Gulf of Mexico OCS Region, Attention: Public Information Office (MS 5034), 1201 Elmwood 

Park Boulevard, Room 114, New Orleans, Louisiana 70123-2394 (1-800-200-GULF) or viewed on the 

MMS website at http://www.gomr.mms.gov. A list of libraries that have copies of the Multisale EIS and 

the Supplemental EIS and their locations is also available on the MMS Internet website. 
Environmental Assessment 3 

2. PURPOSE OF AND NEED FOR THE PROPOSED ACTION 

Purpose of the Proposed Action 

The purpose of this proposed action (CPA Lease Sale 213) is to offer for lease all unleased blocks in 

the proposed lease sale area (Figure 1) that may contain economically recoverable oil and natural gas 

resources. On July 14, 2008, the President modified an Executive Order, thereby making additional 

acreage available for leasing in the CPA. This sale area includes two new areas, which are identified in 

Figure 1. The additional areas represent less than 1 percent of the total CPA and are greater than 100 

miles (mi) (161 kilometers (km)) from the coast of Florida. These areas were examined in the Outer 

Continental Shelf Oil and Gas Leasing Program: 2007-2012 (5-Year Program; USDOI, MMS, 2007a); 

however, they were not examined in the Multisale EIS or the Supplemental EIS. The reanalysis of the 

scenario data with the additional acreage concluded that the scenario for the proposed CPA lease sale 

presented in the Supplemental EIS would not change. The additional acreage will be examined 

throughout this EA as part of the analysis for the entire CPA sale area. The proposed lease sale would 

provide qualified bidders the opportunity to bid upon and lease acreage in the proposed lease sale area in 

order to explore, develop, and produce oil and natural gas. 

Need for the Proposed Action 

The GOM constitutes one of the world’s major oil- and gas-producing areas and has proved to be a 

steady and reliable source of crude oil and natural gas for more than 50 years. Oil from the GOM would 

help reduce the Nation’s need for oil imports and reduce the environmental risks associated with oil 

tankering. Natural gas is generally considered to be an environmentally preferable alternative to oil in 

terms of both production and consumption. 

Figure 1. Gulf of Mexico Outer Continental Shelf Planning Areas, and Proposed Lease Sale Area. 
Environmental Assessment 5 

3. ALTERNATIVES INCLUDING THE PROPOSED ACTION 

3.1. ALTERNATIVE A—PROPOSED ACTION

Alternative A (Preferred Alternative)—The Proposed Action: This alternative would offer for lease 

all unleased blocks within the CPA for oil and gas operations (Figure 2), with the following exceptions: 

(1) blocks that were previously included within the Eastern Planning Area (EPA) and 

that are within 100 mi of the Florida coast; 

(2) blocks that are beyond the U.S. Exclusive Economic Zone in the area known as the 

northern portion of the Eastern Gap; and 

(3) whole and partial blocks that lie within the 1.4-nautical mile (nmi) buffer zone north 

of the continental shelf boundary between the U.S. and Mexico. 

The CPA sale area encompasses about 63 million acres (ac) of the CPA’s 66.3 million ac. The 

estimated amount of resources projected to be developed as a result of any one proposed CPA lease sale is 

0.807-1.336 billion barrels of oil (BBO) and 3.365-5.405 trillion cubic feet (Tcf) of gas. 

The analyses of impacts summarized below and described in detail in Chapters 4.2.2 and 4.4 of the 

Multisale EIS and Chapter 3 of the Supplemental EIS are based on the development scenario, which is a 

set of assumptions and estimates on the amounts, locations, and timing for OCS exploration, 

development, and production operations and facilities, both offshore and onshore. A detailed discussion 

of the development scenario and major related impact-producing factors is included in Chapters 4.1.1, 

4.1.2, and 4.3 of the Multisale EIS. 

Figure 2. Location of Proposed Stipulations and Deferrals. 
6 Alternatives Including the Proposed Action 

3.2. ALTERNATIVES TO THE PROPOSED ACTION

The following alternatives were included for analysis in the Supplemental EIS. As explained in 

Chapter 2.1.3.2 of the Supplemental EIS, the Use of a Nomination and Tract Selection Leasing System 

Alternative analyzed in the Multisale EIS was not included for analysis due to an ongoing MMS study on 

alternative approaches to leasing (Opaluch et al., in preparation). A detailed analysis of this alternative is 

presented in Chapter 4.2.2.4 of the Multisale EIS. 

Alternative B—The Proposed Action Excluding the Unleased Blocks Near Biologically Sensitive 

Topographic Features: This alternative would offer for lease all unleased blocks in the CPA, as 

described for the proposed action, with the exception of any unleased blocks subject to the Topographic 

Features Stipulation. A detailed analysis of Alternative B is presented in Chapter 4.2.2.2 of the Multisale 

EIS. 

Alternative C—The Proposed Action Excluding the Unleased Blocks Within 15 Miles of the Baldwin 

County, Alabama, Coast: This alternative would offer for lease all unleased blocks in the CPA, as 

described for the proposed action, with the exception of any unleased blocks within 15 mi of the Baldwin 

County, Alabama, coast. A detailed analysis of Alternative C is presented in Chapter 4.2.2.3 of the 

Multisale EIS. 

Alternative D—No Action: This alternative is the cancellation of CPA Lease Sale 213. The 

opportunity for development of the estimated 0.807-1.336 BBO and 3.365-5.405 Tcf of gas that could 

have resulted from a proposed CPA lease sale would be precluded or postponed. Any potential 

environmental impacts resulting from a proposed lease sale would not occur or would be postponed. 

Other sources of energy would substitute for the lost production. Principal substitutes would be 

additional imports, conservation, additional domestic production, and switching to other fuels. These 

alternatives, except conservation, have significant negative environmental impacts of their own, which are 

analyzed in the Final EIS for the 5-Year Program (USDOI, MMS, 2007c). 

The MMS published a report that examined previous exploration and development activity scenarios 

(USDOI, MMS, 2007d). The MMS compared forecasted activity with the actual activity that has resulted 

in 14 WPA and 14 CPA lease sales. The report shows that many lease sales contribute to the present 

level of OCS activity, and any single lease sale accounts for only a small percentage of the total OCS 

activities. In 2006, leases from 92 different sales contributed to GOM production, while an average CPA 

lease sale contributed to 2 percent of oil production and 2 percent of gas production in the CPA. In 2006, 

leases from 15 different sales contributed to the installation of production structures in the GOM, while an 

average CPA lease sale contributed to 6 percent of the installation of production structures in the CPA. In 

2006, leases from 70 different sales contributed to wells drilled in the GOM, while an average CPA lease 

sale contributed to 4 percent of wells drilled in the CPA. 

Like other lease sales, Lease Sale 213 would contribute to maintaining the present level of OCS 

activity in the Gulf of Mexico. Exploration and development activity, including service-vessel trips, 

helicopter trips, and construction, that would result from Lease Sale 213 would replace activity resulting 

from existing leases that have reached or are near the end of their economic life. 

If Lease Sale 213 would be cancelled, the resulting development of oil and gas would most likely be 

postponed to a future sale; therefore, the overall level of OCS activity in the CPA would only be reduced 

by a small percentage, if any. 

3.3. MITIGATION MEASURES

Proposed Lease Sale 213 and all subsequent activities resulting from it are subject to the existing 

regulations and proposed lease stipulations designed to reduce environmental risks. Lease stipulations are 

legally binding restrictions and operating requirements that, if adopted, become part of lease contracts. 

The Multisale EIS and the Supplemental EIS analyzed seven stipulations proposed to be applied to leases 

resulting from CPA Lease Sale 213: Topographic Features Stipulation; the Live Bottom Stipulation; the 

Military Areas Stipulation; the Evacuation Stipulation; the Coordination Stipulation; the Blocks South of 

Baldwin County, Alabama, Stipulation; and the Protected Species Stipulation. Chapter 2.4.1.3 of the 

Multisale EIS and the Supplemental EIS discusses the effectiveness of these stipulations. Additional 

stipulations or mitigation requirements to be included in Lease Sale 213 will be described in the Final 

Notice of Sale for Lease Sale 213. 
Environmental Assessment 7 

3.3.1. Summary of Stipulations Discussed in the Multisale EIS 

Seven environmental and military mitigations, referred to as lease stipulations, were included for 

analysis in the Multisale EIS and the Supplemental EIS. These stipulations were developed as the result 

of scoping efforts over a number of years for the continuing OCS Program in the GOM. These 

stipulations and their effectiveness are described in more detail in Chapter 2 of the Multisale EIS. Any 

stipulations or mitigation requirements to be included in Lease Sale 213 will be described in detail in the 

Final Notice of Sale for Lease Sale 213. Stipulations or mitigations requirements, in addition to those 

analyzed in the Multisale EIS, can also be developed and applied, and they will also be described in detail 

in the Final Notice of Sale. 

The following environmental and military stipulations are applicable to Lease Sale 213: 

• The Topographic Features Stipulation protects the biota of the topographic 

features from adverse effects due to routine oil and gas activities, including physical 

damage from anchoring and rig emplacement and the potential toxic and smothering 

effects from muds and cuttings discharges. The Topographic Features Stipulation 

has been included in leases since 1973 and has effectively prevented damage to the 

biota of these banks from routine oil and gas activities such as anchoring. 

Monitoring studies have demonstrated that the shunting requirements of the 

stipulation are effective in preventing the muds and cuttings from impacting the biota 

of the banks. Although deferral of blocks with topographic features has been 

analyzed as an alternative in EIS’s and EA’s for all recent WPA and CPA sales, this 

alternative has never been selected. The topographic highs on and near these blocks 

are often associated with salt domes, which are attractive areas for hydrocarbon 

exploration. Instead, blocks on the topographic features have been offered for lease 

with a stipulation that has proven effective in protecting sensitive biological 

resources. 

• The Military Areas Stipulation has been applied to all blocks leased in military 

areas since 1977 and reduces potential impacts, particularly in regards to safety, but 

does not reduce or eliminate the actual physical presence of oil and gas operations in 

areas where military operations are conducted. The stipulation contains a “hold 

harmless” clause (holding the U.S. Government harmless in case of accident 

involving military operations) and requires lessees to coordinate their activities with 

appropriate local military contacts. 

• The Protected Species Stipulation has been applied to all blocks leased in the GOM 

since December 2001. This stipulation was developed in consultation with the U.S. 

Department of Commerce (USDOC), National Oceanic and Atmospheric 

Administration (NOAA), National Marine Fisheries Service (NMFS), and U.S. Fish 

and Wildlife Service (FWS) in accordance with Section 7 of the Endangered Species 

Act of 1973 (ESA) and is designed to minimize or avoid potential adverse impacts to 

federally protected species. 

• The Live Bottom (Pinnacle Trend) Stipulation covers a small portion of the 

northeastern CPA sale area that is characterized by a pinnacle trend, which is 

classified as a live bottom under the stipulation. The MMS developed the stipulation 

to protect biological resources in the Pinnacle Trend in response to concerns that 

disturbing any of the series of topographic irregularities might adversely affect 

biological communities that have developed on the surfaces of the features and affect 

the habitat they provide for pelagic fishes. The stipulation requires avoidance of the 

features during the placement of oil and gas structures and the laying of pipelines. 

The stipulation has been adopted in CPA sales since 1990 and has been effective in 

protecting the features and resident biological communities from damage. 

• The Evacuation Stipulation would apply to any lease in the easternmost portion of 

the CPA sale area. This stipulation was developed in consultation with the U.S. 

Department of Defense (DOD) to address specific potential use conflict issues 
8 Alternatives Including the Proposed Action 

between oil and gas operations and military operations in the GOM. An evacuation 

stipulation has been applied to all blocks leased in this area since 2001. This 

stipulation would provide for the evacuation of personnel and the shut-in of 

operations during any events conducted by the military that could pose a danger to 

ongoing oil and gas operations. It is expected that these measures will serve to 

eliminate dangerous conflicts between oil and gas operations and military operations. 

• The Coordination Stipulation would apply to any lease in the easternmost portion 

of the CPA sale area. This stipulation was developed in consultation with DOD to 

address specific potential use conflict issues between oil and gas operations and 

military operations in the GOM. A coordination stipulation has been applied to all 

blocks leased in this area since 2001. This stipulation would provide for the review 

of pending oil and gas operations by military authorities and could result in delaying 

oil and gas operations if military activities have been scheduled in the area that may 

put the oil and gas operations and personnel at risk. 

• The Blocks South of Baldwin County, Alabama, Stipulation will be included only 

on leases south of and within 15 mi of Baldwin County, Alabama. For several years, 

the Governor of Alabama has continually indicated opposition to new leasing south 

and within 15 mi of Baldwin County but has requested that, if the area is offered for 

lease, a lease stipulation to reduce the potential for visual impacts be applied to all 

new leases in this area. Prior to the decision in 1999 on the Final Notice of Sale for 

Sale 172, the MMS, GOM OCS Regional Director, in consultation with the 

Geological Survey of Alabama/State Oil and Gas Board, developed a lease 

stipulation to be applied to any new leases within the 15-mi area to mitigate potential 

visual impacts. The stipulation specifies requirements for consultation that lessees 

must follow when developing plans for fixed structures. The stipulation has been 

continually adopted in annual Central GOM lease sales since 1999. 

3.3.2. Information to Lessees 

The Final Notice of Sale Package for Lease Sale 213 will include a list of Information to Lessees 

(ITL) paragraphs designed to inform potential bidders of applicable requirements of Federal agencies 

other than MMS, as well as emerging OCS concerns that could apply to the sale. Two ITL’s proposed for 

Lease Sale 213 were developed to inform bidders of two inactive offshore-disposal programs that resulted 

in multiple seafloor hazards in Mississippi Canyon. After World War II, the U.S. Armed Forces used the 

GOM as a primary disposal site for unused, excess, and hazardous munitions/ordnance consisting of an 

assortment of bombs, torpedoes, projectiles, and chemical ordnance; however, absent of regulations, most 

material was undocumented and uncharted. Similarly, a commercial waste disposal site was developed in 

the GOM by the Environmental Protection Agency (USEPA) during the 1970’s to allow for the seabed 

disposal of thousands of barrels of chemical wastes. Like the disposed ordnance, the location and 

contents of most of the barrels are unknown, with much of the material actually deposited outside of the 

disposal site boundary. 

Even though both programs are now inactive, the disposed ordnance and waste barrels remain on the 

seabed and still represent a potential hazard to nearby OCS oil and gas operations. However, during the 

requisite hazard surveys and pipeline pre-surveys, the disposed material is detected as sonar targets and/or 

magnetic anomalies and, most often, they are identified correctly as either ordnance or waste barrels. 

During MMS’s site-specific NEPA review of each of the operators’ and applicants’ subsequent operation 

submittals, the proposed activities are assigned mitigation/conditions of approval that entail avoidance of 

the disposed material by several meters and, in the case of the ruptured waste barrels, decontamination 

procedures if subsea equipment comes into accidental contact with the substances. 

The following precautionary ITL’s for the inactive disposal areas are applicable to Lease Sale 213: 

• Ordnance Disposal Areas ITL: Bidders are cautioned as to the existence of two 

inactive ordnance disposal areas in Mississippi Canyon, shown on the map 

“Stipulations and Deferred Blocks, Sale 213” included in the Notice of Sale Package. 

These areas were used to dispose of ordnance of unknown quantity and composition. 
Environmental Assessment 9 

Water depths range from approximately 750 to 1,525 m (2,460 to 5,003 ft). Bottom 

sediments in both areas are soft, consisting of silty clays. Exploration and 

development activities in these areas require precautions commensurate with the 

potential hazards. The U.S. Air Force has released an indeterminable amount of 

unexploded ordnance throughout Eglin Water Test Areas 1 and 3. The exact 

locations of the unexploded ordnance are unknown, and lessees are advised that all 

lease blocks included in this sale within these water test areas should be considered 

potentially hazardous to drilling and platform and pipeline placement. 

• Commercial Waste Disposal Area ITL: Bidders are cautioned as to the existence 

of an inactive commercial waste disposal site that covers all or portions of 

Mississippi Canyon, shown on the map “Stipulations and Deferred Block, Sale 213” 

included in the Notice of Sale Package. The disposal site was established in the 

1970’s to facilitate USEPA permitting for the seafloor deposition of thousands of 

steel barrels containing chemical wastes, which according to limited USEPA 

documentation, consist mostly of chlorinated hydrocarbons and liquid metal salts. 

The exact locations of all the waste material are unknown since the geospatial data 

were not collected when the barrels were jettisoned; therefore, hundreds of barrels 

have been detected during hazards surveys conducted on blocks over 10 mi (16 km) 

away from the designated disposal site boundary. For that reason, lessees are advised 

that the aforementioned blocks associated with the disposal site and most blocks 

neighboring its boundary that are included in this sale should be considered 

potentially hazardous to drilling and platform/pipeline placement and may require 

precautions appropriate for the potential hazards. 

3.3.3. Existing Mitigations 

Chapter 2.2.2.2 of the Multisale EIS and Chapter 2.1.2 of the Supplemental EIS discuss mitigations 

that would be applied by MMS. Mitigations have been proposed, identified, evaluated, or developed 

through previous MMS lease sale NEPA review and analysis. Many of these mitigations have been 

adopted and incorporated into regulations and/or guidelines governing OCS exploration, development, 

and production activities. The MMS rigorously reviews all plans for OCS activities (e.g., exploration and 

development plans, pipeline applications, and structure-removal applications) to ensure compliance with 

established laws and regulations. Existing mitigations must be incorporated and documented in plans 

submitted to MMS. The MMS enforces operational compliance with these mitigations through the MMS 

on-site inspection program. 

Mitigations that are a standard part of the MMS program ensure that the operations are always 

conducted in an environmentally sound manner. For example, mitigations ensure that site-clearance 

procedures eliminate potential snags to commercial fishing nets and require surveys to detect and avoid 

archaeological sites and biologically-sensitive areas such as pinnacles, topographic features, and 

chemosynthetic communities. 

Some MMS-identified mitigations are incorporated into OCS operations through cooperative 

agreements or efforts with industry and various State and Federal agencies. These mitigations include 

NMFS’ Observer Program to protect marine mammals and sea turtles during explosive removals, labeling 

operational supplies to track possible sources of accidental debris loss, development of methods of 

pipeline landfall to eliminate impacts to barrier beaches, and semiannual beach cleanup events. 

Site-specific mitigations are also applied by MMS during plan reviews. The MMS determined that 

many of these site-specific mitigations were consistently applied and used these to develop a list of 

“standard” mitigations. There are currently over 120 standard mitigations. The wording of a standard 

mitigation is developed by MMS in advance and may be applied whenever conditions warrant. Standard 

mitigation text is revised as often as necessary (e.g., to reflect changes in regulatory citations, 

agency/personnel contact numbers, and internal policy). Site-specific mitigation categories include air 

quality, archaeological resources, artificial reef material, chemosynthetic communities, Flower Garden 

Banks, topographic features, hard bottoms/pinnacles, military warning areas and Eglin water test areas, 

Naval mine warfare areas, hydrogen sulfide, drilling hazards, remotely operated vehicle surveys, 

geophysical survey reviews, and general safety concerns. Site-specific mitigation types include 
10 Alternatives Including the Proposed Action 

advisories, conditions of approval, hazard survey reviews, inspection requirements, notifications, postapproval submittals, reminders, and safety precautions. In addition to standard mitigations, MMS may 

also apply nonrecurring mitigations that are developed on a case-by-case basis. 

3.3.4. Notices to Lessees and Operators 

The MMS issues Notices to Lessees and Operators (NTL’s) to provide clarification, description, or 

interpretation of a regulation; to provide guidelines on the implementation of a special lease stipulation or 

regional requirement; or to convey administrative information. A detailed listing of current GOM OCS 

Region NTL’s is available through the MMS, GOM OCS Region’s Internet website at http://

www.gomr.mms.gov/homepg/regulate/regs/ntls/ntl_lst.html or through the Region’s Public Information 

Office at (504) 736-2519 or 1-800-200-GULF. The MMS issued several NTL’s related to the 2007 

hurricane season, which are discussed in Chapter 4.1.3. Several NTL’s providing guidance on 

monitoring requirements are described in the following section. 

3.3.5. Monitoring 

The MMS requires post-activity submittals for several activities, including seismic surveys and 

installation and decommissioning operations. Post-activity submittals allow MMS to monitor compliance 

with mitigations and to determine the effectiveness of those mitigations. The MMS is continually 

revising applicable mitigations to allow the GOM Region to track more easily and routinely mitigation 

compliance and effectiveness. A primary focus of this effort is requiring post-approval submittal of 

information within a specified timeframe after a triggering event that is currently tracked by MMS (e.g., 

end of operations reports for plans, construction reports for pipelines, and removal reports for structure 

removals). 

In addition to compliance monitoring, MMS’s Environmental Studies and Research Monitoring 

involves a repeated sampling of the environment over time to establish baseline conditions, determine 

natural variability, and assess changes and trends due to human activities. The MMS either conducts or 

requires this type of monitoring through its Environmental Studies Program to determine the extent to 

which activities caused by or permitted by MMS, such as development of offshore oil and gas, sand and 

gravel, and methane hydrate resources, affect the human, marine, and coastal environments. As a part of 

the Environmental Studies Program, the GOM Region has funded more than 350 completed or ongoing 

environmental studies. 

The following describes some of these monitoring activities. 

Protected Species NTL’s 

The Protected Species Stipulation is embodied in NTL’s 2007-G02, 2007-G03, and 2007-G04, which 

instruct lessees and operators on how to implement these mitigations.

Implementation of Seismic Survey Mitigation Measures and Protected Species Observer 

Program (NTL 2007-G02) 

NTL 2007-G02, “Implementation of Seismic Survey Mitigation Measures and Protected Species 

Observer Program,” details information on ramp-up procedures, observation methods, and reporting 

requirements to be followed by the seismic industry during certain geological and geophysical survey 

operations. The conditions prescribed under the NTL aid in reducing the chance of harassment to nearby 

marine mammals and sea turtles. The MMS uses the report data received from the companies to monitor 

the effectiveness of current mitigations. 

Marine Trash and Debris Awareness and Elimination (NTL 2007-G03) 

NTL 2007-G03, “Marine Trash and Debris Awareness and Elimination,” provides guidance to 

prevent intentional and/or accidental introduction of debris into the marine environment. Operators are 

prohibited from deliberately discharging containers and other similar materials (i.e., trash and debris) into 

the marine environment (30 CFR 250.300(a) and (b)(6)) and are required to make durable identification 
Environmental Assessment 11 

markings on equipment, tools, containers (especially drums), and other material (30 CFR 250.300(c)). 

An annual report that describes the marine trash and debris awareness training process and certifies that 

the training process has been followed for the previous calendar year is to be provided to MMS by 

January 31 of each year.

Vessel Strike Avoidance and Injured/Dead Protected Species Reporting (NTL 2007-G04) 

NTL 2007-G04, “Vessel Strike Avoidance and Injured/Dead Protected Species Reporting,” explains 

how operators must implement measures to minimize the risk of vessel strikes to protected species and 

report observations of injured or dead protected species. Vessel operators and crews must maintain a 

vigilant watch for marine protected species and slow down or stop their vessel to avoid striking protected 

species. Crews must report sightings of any injured or dead protected species (marine mammals and sea 

turtles) immediately, regardless of whether the injury or death is caused by their vessel, to the Marine 

Mammal and Sea Turtle Stranding Hotline or the Marine Mammal Stranding Network. In addition, if it 

was their own vessel that collided with a protected species, MMS must be notified within 24 hours of the 

strike. 

Accurate and complete reporting of the results of the mitigations is important. Only through diligent 

and careful reporting can MMS, and subsequently NMFS, determine the need for and effectiveness of 

mitigations. Information on observer effort and seismic operations are as important as animal sighting 

and behavior data. 

Biologically Sensitive Areas of the Gulf of Mexico (NTL 2004-G05) 

The Live Bottom (Pinnacle Trend) Stipulation and Topographic Features Stipulation are described in 

the comprehensive NTL 2004-G05, “Biologically Sensitive Areas of the Gulf of Mexico.” In addition to 

existing stipulated areas for biological features, this NTL establishes a new category of protected area 

termed “Potentially Sensitive Biological Features.” These are hard-bottom features not protected by a 

biological lease stipulation that are of moderate to high relief (about 8 feet (ft); 2.4 meters (m) or higher), 

provide surface area for the growth of sessile invertebrates, and have the potential to attract large numbers 

of fish. These features would be located outside any “No Activity Zone” of any of the named topographic 

features (banks) or the 70 live-bottom (pinnacle trend) stipulated blocks. Following the completion of 

any activity that proposed disturbance of the seafloor within a specified distance of pinnacles, live-bottom 

(low-relief) features, or potentially sensitive biological features, operators must submit a map showing the 

location of the seafloor disturbance relative to these features. 

Site Clearance (NTL 98-26) 

NTL 98-26, “Minimum Interim Requirements for Site Clearance (and Verification) of Abandoned Oil 

and Gas Structures in the Gulf of Mexico,” provides the guidelines for removing bottom debris and gear 

after structure decommissioning and removal operations. These mitigations ensure that site-clearance 

procedures eliminate potential snags to commercial fishing nets and require surveys to detect and avoid 

archaeological sites and biologically-sensitive areas such as pinnacles, topographic features, and 

chemosynthetic communities. 

Once all bottom-founded components are severed and the structures/wells are removed, operators 

must verify that the seafloor is clear of obstructions and the site has been returned to prelease conditions. 

Site-clearance verification must take place within 60 days after structure-removal operations have been 

conducted. Procedures include sonar surveys and/or trawling the cleared site by a licensed “shrimp” 

trawler to ensure that no “hangs” exist. 

Remotely Operated Vehicle Surveys (NTL 2003-G03) 

On January 23, 2003, MMS issued NTL 2003-G03, “Remotely Operated Vehicle (ROV) Surveys in 

Deepwater.” The NTL provides guidance on the required ROV surveys and reports in water depths 

greater than 400 m (1,312 ft). Eighteen grid areas were developed to ensure a broad and systematic 

analysis of deep water and to depict areas of biological similarity, primarily on the basis of benthic 

communities. The grid areas cover the WPA sale area and CPA sale area, with the exception of the 

easternmost portion. 
12 Alternatives Including the Proposed Action 

Operators must submit a ROV survey plan with each exploration plan submitted in each grid area and 

with the Development Operations Coordination Document for the first surface structure proposed in each 

grid area. The ROV surveys will serve several purposes. In addition to monitoring the effects of the 

particular plans for which they are required, the surveys will improve our overall knowledge of benthic 

habitats in deep water and provide more information on the seafloor in deep water. The surveys will also 

provide information on the distribution and accumulation of muds and cuttings.

Seafloor Monitoring 

The Seafloor Monitoring Program in the GOM Region began in 1997 as a way to assess industry 

compliance with mitigations applied to offshore activities, which typically consist of avoidance criteria of 

seafloor features. The Seafloor Monitoring Program is comprised of a pool of scientific divers from 

MMS that, since its inception, has ranged in number from five to eight members. At present, the team 

consists of three biologists, two archaeologists, and one geophysicist. In addition to the divers, the team 

has one non-diving, sidescan-sonar operator who is also an archaeologist. In addition to monitoring 

industry compliance with environmental mitigations, the Seafloor Monitoring Team also supports the 

MMS Environmental Studies Program by conducting contract inspections and oversight of fieldwork. 

Since the formation of the Seafloor Monitoring Program in 1997 the team has completed 75 field 

investigations to verify archaeological and biological mitigations, to inspect industry activity on pipeline 

and well-site construction, and to support the MMS Environmental Studies Program. 

Long-Term Monitoring at the Flower Garden Banks National Marine Sanctuary 

Following the designation of the Flower Garden Banks as a National Marine Sanctuary in 1992, 

MMS, in consultation with academia and industry, implemented a program to monitor changes in coral 

populations and growth, as well as explore other important factors associated with these reefs. These 

monitoring studies have demonstrated that the shunting requirements of the Topographic Features 

Stipulation are effective in preventing the muds and cuttings from impacting the biota of the banks. 

Through establishment of the Flower Garden Banks National Marine Sanctuary, MMS made substantial 

progress in implementing many of the recommendations of previous monitoring reports. 

During the 1998-2001 period, analysis of monitoring data indicated that the Flower Garden Banks 

were healthy and productive (Dokken et al., 2003). This monitoring effort was designed to assess the 

health of the coral reefs, evaluate changes in coral population levels, measure coral and algae cover and 

growth rates, and investigate other community characteristics. The goal of the program is to address 

concerns related to both gradual and punctuated degradation of these unique offshore ecosystems. Such 

data are useful in assessing the impacts of industrial activities, as well as their value to resource 

management. No significant impact from oil/gas production activity has been documented after 

Sanctuary designation. 

Long-term monitoring has continued on a yearly basis at both the East and West Flower Garden 

banks through an equal partnership with MMS and NMFS. This monitoring not only expands MMS’s 

knowledge and understanding of the Flower Garden Banks ecosystem, but it also improves the foundation 

from which management decisions are made. 

In addition, another MMS study, Post-Hurricane Assessment of Sensitive Habitats of the Flower 

Garden Banks Vicinity (Robbart et al., 2009), is investigating hurricane effects at the East Flower Garden, 

Sonnier, McGrail, Geyer, and Bright Banks. 

Inspection Program 

The Outer Continental Shelf Lands Act authorizes and requires MMS to provide for both an annual 

scheduled inspection and a periodic unscheduled (unannounced) inspection of all oil and gas operations 

on the OCS. The GOM Region has an extensive, detailed inspection program to ensure safe and 

environmentally sound offshore oil and gas operations. This program places MMS inspectors offshore on 

drilling rigs and production platforms on a daily basis to assure compliance with all regulatory constraints 

that allowed commencement and continuation of the operation. 
Environmental Assessment 13 

4. IMPACT ANALYSIS 

4.1. UPDATE OF PROJECTIONS OF POTENTIAL ACTIVITY FROM THE PROPOSED 

ACTION

In order to describe the level of activity that could reasonably result from a proposed lease sale, MMS 

develops exploration and development scenarios of onshore and offshore activity. These scenarios 

provide a framework for detailed analyses of potential environmental and socioeconomic impacts of a 

proposed lease sale. 

4.1.1. Offshore Impact-Producing Factors and Scenario 

The Multisale EIS and the Supplemental EIS discuss projections for activities associated with a 

typical proposed CPA lease sale. The estimated amounts of resources projected to be leased, discovered, 

developed, and produced as a result of proposed CPA Lease Sale 213 are 0.807-1.336 BBO and 3.365-

5.405 Tcf of gas. Table 1 provides a summary of the major scenario elements of proposed Lease Sale 

213 and some of the related impact-producing factors by offshore subareas based upon ranges in water 

depth (Figure 3). Chapter 4.1.1 of the Multisale EIS and Chapter 3.1 of the Supplemental EIS describe 

the offshore infrastructure and activities (impact-producing factors) associated with the proposed lease 

sales and with the OCS Program that could potentially affect the biological, physical, and socioeconomic 

resources of the GOM. 

Table 1 

 

Offshore Scenario Information Related to Proposed Lease Sale 213 

Offshore Subareas1

C0-60 

(western) 

C0-60 

(eastern) C60-200 C200-400 C400-800 C800-1600 C1600-2400 C>24002 Total CPA3

Wells Drilled 

Exploration and Delineation Wells 14-16 3 9-12 7-11 9-14 10-18 7-12 8-13 67-99 

Development Wells 51-59 9-10 22-26 75-107 61-83 56-91 37-59 27-43 337-477 

Oil Wells 13-15 2-2 7-8 43-61 36-49 33-54 22-36 16-25 172-251 

Gas Wells 38-44 7-8 15-18 32-46 25-33 23-37 15-23 11-18 165-226 

Workovers and Other Well Activities 309-357 55-63 133-161 455-651 371-504 343-553 224-357 161-252 2,009-2,849 

Production Structures 

Installed 17-18 3 2-3 1-3 1-3 1-4 1-3 2-3 28-40 

Removed Using Explosives 10 2 2 0-1 0-1 0 0 0 14-16 

Total Removed 14 2-3 2-3 1-3 1-3 1-4 1-3 2-3 24-36 

Method of Oil Transportation4

Percent Piped 99% 99% 100% 100% 100% 0%-50% 0%-100% 0%-100% 63%->99% 

Percent Barged 1% 1% 0% 0% 0% 0% 0% 0% <1% 

Percent Tankered 0% 0% 0% 0% 0% 0%-50% 0%-100% 0%-50% 0%-37% 

Length of Installed Pipelines (km)5 40-720 10-130 NA NA NA NA NA NA 130-2,075 

Blowouts 0 0 0 0 0-1 0-1 0 0 2-3 

Service-Vessel Trips (1,000 round trips) 18-19 3 3-4 4-7 19-52 19-68 18-51 35-41 119-241 

Helicopter Operations (1,000 operations) 607-1,016 107-169 71-169 36-169 36-169 36-226 36-169 75-154 1,004-2,241 1

 See Figure 3. 

2

 Includes the projected activity associated with the addition of new areas. 

3

 Subarea totals may not add up to the planning area total because of rounding. 

4

 100% of gas is assumed to be piped. 

5

 Projected length of OCS pipelines does not include length in State waters. 

NA means that information is not available. 
14 Impact Analysis

Figure 3. Offshore Subareas in the Proposed Sale Area. 

The analysis of potential environmental and socioeconomic impacts presented in past EIS’s and EA’s 

were based on these exploration and development activity scenarios that, in most cases, were 

overestimated. If the level of activity was overestimated, the environmental and socioeconomic impacts 

of a lease sale may have been overstated. Based on a recent analysis prepared by MMS, slightly over half 

of the time the actual activity fell below the lowest level of forecasted activity (USDOI, MMS, 2007d). 

When within the forecasted range, the majority of time the actual activity was at or near the low end of 

the forecasted range. In addition, a single lease sale accounts for only a small percentage of the total OCS 

activities. 

The examination of previously forecasted activity did not include the proposed lease sales addressed 

in the Multisale EIS and the Supplemental EIS. In late 2002, MMS contracted with Innovation & 

Information Consultants, Inc. (IIC, Inc.) to develop a model that would estimate oil and gas exploration 

and discovery, development, and production activity in the Gulf of Mexico. The Exploration, 

Development, and Production (EDP) model was delivered to MMS in 2004. The activity scenario 

presented in the Multisale EIS and the Supplemental EIS was the first developed with the EDP model. 

The proposed sales and their resulting activity had not yet taken place and, therefore, could not be 

included in the analysis. 

Documentation of the EDP model and its subcomponents can be found in Ashton et al. (2004). As 

stated in the model’s documentation, the EDP model “incorporates actual historical data, and allows easy 

comparison between the actual historical data, and the future model years.” As the model was developed, 

modifications were made so that the model more accurately portrayed historical precedent. 

The EDP model relies on more factors than previous modeling methods (Upton and Ashton, 2005). 

Constraints include leasing policy, rig availability, and resource assessment. Inputs include prices, costs, 

field characteristics, reserve growth, and policy variables. The production function is based on historical 

production data by field size and location. Another improvement over previously used modeling methods 

is that the EDP model defines undiscovered resources by field instead of a Gulfwide undiscovered 

resource volume. 
Environmental Assessment 15 

An MMS study to estimate physical and economic performance measures to characterize lease sales 

and development in the Gulf of Mexico can be used to further refine the scenario presented in the 

Multisale EIS and the Supplemental EIS (Iledare and Kaiser, 2007). The average lag of exploration and 

production from leases issued from 1983 to 1999 increased by water depth and decreased over time as 

shown in the Tables 2 and 3 below. Due to variation by water depth, exploration and production activity 

is staggered over time taking on average 1.9-4.5 years after a lease sale before exploration begins and 3.4-

8.3 years before first production. Therefore, if activity as the result of a lease sale is assumed to be 

staggered over time, then the impacts and any strain on coastal infrastructure would also be staggered 

over time. 

Table 2 

 

Aggregate Average Lag in Months from Sales to First Spud for Leases Issued from 1983 to 1999 

Water Depth 1983-1987 1985-1989 1990-1994 1995-1999 

< 60 m 29.3 27.8 25.8 22.9 

60 m - 200 m 30.5 31.0 36.0 27.2 

200 m - 900 m 40.4 46.4 42.9 30.0 

>900 m 84.9 93.3 84.2 53.6 

Source: Iledare and Kaiser, 2007. 

Table 3 

 

Aggregate Average Lag in Months from Sales to First Production for Leases Issued 

from 1983 to 1999 

Water Depth 1983-1987 1985-1989 1990-1994 1995-1999 

< 60 m 59.0 53.2 49.5 41.1 

60 m - 200 m 74.7 65.7 60.3 47.5 

200 m - 900 m 128.1 123.0 70.2 54.1 

>900 m 180.6 176.9 105.9 99.6 

Source: Iledare and Kaiser, 2007. 

No new information has been found that necessitates a change to the offshore scenario presented in 

the Multisale EIS and the Supplemental EIS; therefore, the scenario still applies for proposed Lease Sale 

213. 

4.1.2. Coastal Impact-Producing Factors and Scenario 

Chapter 4.1.2 of the Multisale EIS and Chapter 3.1.2 of the Supplemental EIS describes the onshore 

infrastructure and activities (impact-producing factors) associated with the proposed lease sales and with 

the OCS Program that could potentially affect the biological, physical, and socioeconomic resources of 

the GOM. Up to one new pipeline landfall and up to one new gas processing plant are projected as a 

result of an individual proposed lease sale. The MMS projected no other new coastal infrastructure as a 

result of a proposed lease sale. 

The analyses of coastal infrastructure presented in the Multisale EIS and the Supplemental EIS and 

other previous EIS’s and EA’s concluded that no new solid waste facilities would be built as a result of a 

single lease sale or as a result of the OCS Program. Recent research further supports these past 

conclusions that existing solid-waste disposal infrastructure is adequate to support both existing and 

projected offshore oil and gas drilling and production needs (Dismukes et al., 2007). 

The MMS projected the number of Federal OCS landfalls that may result from proposed lease sales in 

order to analyze the potential impacts to wetlands and other coastal habitats. In the Multisale EIS, the 

Supplemental EIS and other previous EIS’s and EA’s, MMS assumed that the majority of new Federal 

OCS pipelines would connect to the existing infrastructure in Federal and State waters and that very few 

would result in new pipeline landfalls. Therefore, MMS projected up to one pipeline landfall per lease 

sale; however, recent MMS analysis showed that even one landfall as a result of an individual lease sale 

may be unlikely (USDOI, MMS, 2007e). Although there will be some instances where new pipelines 
16 Impact Analysis

may need to be constructed, there is nothing to suggest any dramatic shifts in the trends in new Federal 

OCS landfalls given the current outlook for Gulf of Mexico development, particularly in coastal 

Louisiana (Dismukes, personal communication, 2009). While there are some opportunities for new 

pipeline landfalls from increased production activity, many of those will be limited due to a number of 

factors associated with basic pipeline economics. 

Since the publication of the Supplemental EIS in September 2008, one operational petroleum spill of 

>1,000 bbl occurred in the OCS. This spill is still under investigation by the U.S. Department of 

Transportation, but it is estimated to be approximately 1,500 bbl (USDOI, MMS, 2009a). The spill 

occurred on July 25, 2009, in Ship Shoal Block 142 in the Eugene Island Pipeline System, and it has been 

added to MMS’s historical database. An historical rate of spills is derived from the database; this rate is 

then used to estimate spills from future actions proposed by MMS (Anderson and LaBelle, 2000). The 

spill has not resulted in an increase in the projected spill rates based on the historical data. The spill did 

not make landfall; therefore, coastal resources were not impacted.

Much of the coastal infrastructure presented in the Multisale EIS and the Supplemental EIS was from 

the OCS-Related Infrastructure in the Gulf of Mexico Fact Book (The Louis Berger Group, Inc., 2004). 

An update of the fact book is currently in progress. No new information has been found that necessitates 

a change to the onshore scenario presented in the Multisale EIS and the Supplemental EIS; therefore, the 

scenario still applies for proposed Lease Sale 213. 

4.1.3. Hurricanes 

Spills as the Result of Hurricanes 

Chapter 4.1.3.4.4.2 of the Multisale EIS discusses the cause and volume of spills that resulted from 

the 2004-2005 hurricanes. Since the publication of the Multisale EIS, MMS has made several updates to 

the information and quantities of oil spillage resulting from damages caused by Hurricanes Katrina and 

Rita in 2005 (USDOI, MMS, 2008b). The following is a summary of the most recent revisions. 

As of June 23, 2008, MMS has identified 165 spills of petroleum products of ≥1 barrel (bbl), totaling 

14,676 bbl that were lost from platforms, rigs, and pipelines on the Federal OCS due to the two 

hurricanes. This is up from MMS’s July 2007 report that had identified 154 spills, totaling 17,077 bbl 

(USDOI, MMS, 2007g). 

The June 2008 report also discussed spills of <1 bbl. Between October 2005 and December 2007, 

there were almost 800 petroleum spills of <1 bbl on the Federal OCS related to the 2005 hurricanes 

reported to the National Response Center (NRC). These NRC reports totaled to <50 bbl and averaged 

less than 3 gallons each in size. More recent information about chronic, small leaks is available on the 

MMS website at http://www.mms.gov/incidents/SigPoll2008.htm. These spills of <1 bbl dissipate 

quickly due to evaporation, dispersion by the winds and currents, and dilution by the ocean waters. Three 

gallons of crude oil can briefly create a sheen of an acre (43,560 ft2

) or more in size on the ocean surface. 

Unchanged from the earlier report, there were no accounts of environmental consequences resulting 

from spills from facilities: 

• no spill contacts to the shoreline; 

• no oiling of marine mammals, birds, or other wildlife; 

• no large volumes of oil on the ocean surface to be collected or cleaned up; and 

• no identified environmental impacts from any OCS spills from Hurricanes Katrina or 

Rita. 

The final estimation of the total spillage associated with Hurricanes Katrina and Rita will not be 

complete until all operators have completed recovery efforts associated with the repair and/or have 

completed decommissioning of all the damaged structures. The estimates were last updated in June 2008, 

and final estimates are expected to be completed in 2010. 
Environmental Assessment 17 

Damage to Offshore Infrastructure as the Result of Hurricanes 

During the past few years, the Gulf Coast States and GOM oil and gas activities have been impacted 

by several major hurricanes. Chapter 3.3.5.7.3 of the Multisale EIS and Chapter 3.1.1.3 of the 

Supplemental EIS summarized the latest reports by MMS on the damage to the OCS-related platforms, 

rigs, and pipelines caused by Hurricanes Ivan, Katrina, and Rita. 

In preparation for the 2007 hurricane season, MMS announced operational and administrative 

improvements that have been implemented to prepare oil and gas infrastructure in the GOM for the 

possibility of hurricanes during the 2007 season (USDOI, MMS, 2007h). Both MMS and industry had to 

reassess what possible weather conditions could occur with a major hurricane moving through the GOM. 

The reassessment was done through American Petroleum Institute (API) committees in which MMS was 

an active participant. The committees revised and updated the best practices and standards using the new 

information that had been collected following the 2005 hurricanes. 

The MMS issued several NTL’s in preparation of upcoming hurricane seasons. These NTL’s are 

summarized as follows: 

Design of New OCS Platforms and Related Structures for Hurricane Conditions 

(NTL 2007-G26) 

Hurricanes Ivan, Katrina, and Rita during the 2004 and 2005 hurricane seasons were detrimental to 

oil and gas operations on the OCS. The effects included significant structural damage to fixed and 

floating production platforms (123 fixed platforms and 1 floating platform were destroyed and dozens 

more suffered significant damage) and significant damage to semisubmersible and jack-up drilling rigs. 

Even though most of the approximately 3,000 OCS platforms that were exposed to hurricane force winds 

during these storms performed well, the MMS’s Gulf of Mexico Region (GOMR) is concerned about the 

platforms that suffered significant structural damage, as well as the potential for future damage to key 

energy infrastructure on the OCS. Therefore, MMS issued NTL 2007-G26, “Design of New OCS 

Platforms and Related Structures for Hurricane Conditions,” on October 1, 2007. The NTL provides 

guidance on designing new OCS platforms and related structures. In May 2007, API issued Interim 

Guidance for Design of Offshore Structures for Hurricane Conditions (API Bulletin 2INT-DG) to provide 

guidance on how to use the updated metocean conditions in API Bulletin 2INT-MET for the design of 

new OCS platforms. 

Assessment of Existing OCS Platforms and Related Structures for Hurricane Conditions 

(NTL 2007-G27) 

Based on impacts to OCS platforms caused by Hurricanes Ivan, Katrina, and Rita as described above, 

MMS issued NTL 2007-G27, “Assessment of Existing OCS Platforms and Related Structures for 

Hurricane Conditions,” effective October 1, 2007. The NTL provides guidance to ensure that certain 

existing OCS platforms and related structures are assessed to ensure their structural integrity by 

considering the specific environmental conditions at the platform location as required by 30 CFR 

250.900(a). In May 2007, API issued Interim Guidance for Assessment of Existing Offshore Structures 

for Hurricane Conditions (API Bulletin 2INT-EX) to provide guidance on how to use the updated 

metocean conditions in API Bulletin 2INT-MET for the assessment of existing OCS platforms. 

Guidelines for Moored Drilling Rig Fitness Requirements for Hurricane Season 

(NTL 2008-G09) 

During Hurricanes Ivan, Katrina, and Rita, there were 19 moored rigs that experienced a total failure 

of station-keeping ability. In response, MMS issued NTL 2008-G09, “Guidelines for Moored Drilling 

Rig Fitness Requirements for Hurricane Season,” on June 1, 2008. This NTL provides guidance on the 

information you must submit with Form MMS-123, Application for Permit to Drill (APD), to 

demonstrate the fitness of any moored drilling rig used to conduct operations in the Gulf of Mexico OCS 

during hurricane season. The MMS GOMR will use the recommendations in the API newly-developed 

Appendix K to the Third Edition of API Recommended Practice (RP) 2SK, Gulf of Mexico Mooring 

Practice for Hurricane Season (API RP 2SK, Appendix K) to guide the review and evaluation of the 
18 Impact Analysis

information and data that demonstrate the moored rig’s capability to perform at the proposed location. 

The MMS regulations require stability, and in the NTL, the MMS GOMR recommends that operators 

follow the recommendations in API RP 2SK, Appendix K, as they prepare APD’s to conduct drilling 

operations during hurricane season. Failure to follow the recommendations in API RP 2SK, Appendix K, 

may delay the approval of an APD or may result in disapproval. This guidance also applies to moored 

drilling rig operations conducted under Form MMS-124, Application for Permit to Modify (APM).

Guidelines for Tie-downs on OCS Production Platforms for Upcoming Hurricane Seasons 

(NTL 2009-G13) 

During Hurricanes Ivan, Katrina, Rita, and Ike, there were seven platform rigs that experienced a total 

failure or were significantly damaged. Additionally, there were numerous reports of platform facilities, 

equipment, and drilling units that were tied-down but that had shifted. 

In response, MMS issued NTL 2009-G13, “Guidelines for Tie-downs on OCS Production Platforms 

for Upcoming Hurricane Seasons,” on May 20, 2009. The NTL provides guidance on the evaluation of 

tie-downs that operators will use on OCS production platforms to secure drilling and workover rigs and 

permanent equipment and facilities during hurricane season. As required by 30 CFR 250.900(a), 

operators must design, fabricate, install, use, maintain, inspect, and assess all platforms and related 

structures on the OCS to ensure their structural integrity for the safe conduct of drilling, workover, and 

production operations, considering the specific environmental conditions at the platform location. 

Accordingly, the MMS GOMR endorses the guidelines in the API’s Guidelines for Tie-downs on 

Offshore Production Facilities for Hurricane Season, First Edition (API Bulletin 2TD) to assist in the 

review and evaluation of the information and data that demonstrate the ability of the tie-downs to perform 

during a hurricane. As required by 30 CFR 250.900(a), operators must design, fabricate, install, use, 

maintain, inspect, and assess all platforms and related structures on the OCS to ensure their structural 

integrity for the safe conduct of drilling, workover, and production operations, considering the specific 

environmental conditions at the platform location. Accordingly, the MMS GOMR endorses the 

guidelines in API’s Bulletin 2TD, Guidelines for Tie-downs on Offshore Production Facilities for 

Hurricane Season, First Edition (API Bulletin 2TD) to assist operators in the review and evaluation of the 

information and data that demonstrate the ability of the tie-downs to perform during a hurricane. 

Guidelines for Jack-up Drilling Rig Fitness Requirements for Hurricane Season 

(NTL 2009-G10) 

During Hurricanes Ivan, Katrina, Rita, and Ike, twelve jack-up rigs experienced a total failure of 

station-keeping ability. In response, MMS issued NTL 2009-G10, “Guidelines for Jack-up Drilling Rig 

Fitness Requirements for Hurricane Season,” on June 1, 2009. This NTL includes the provision for using 

a checklist to provide information regarding jack-up rig fitness, provides a guidance document statement, 

and updates contact information. 

The purpose of this NTL is to provide guidance on the information operators must submit with Form 

MMS-123, Application for Permit to Drill (APD), to demonstrate the fitness of any jack-up drilling rig 

they will use to conduct operations in the Gulf of Mexico OCS during hurricane season. As required by 

30 CFR 250.417(a), this information must demonstrate that the associated jack-up drilling rig is capable 

of performing at the proposed drilling location. The MMS GOMR will use the recommendations in 

API’s Recommended Practice 95J, Gulf of Mexico Jack-up Operations for Hurricane Season—Interim 

Recommendations, First Edition (API RP 95J) to guide the review and evaluation of the information and 

data that demonstrate the jack-up rig’s capability to perform at the proposed location. 

Global Positioning Systems for Mobile Offshore Drilling Units (NTL 2009-G16) 

The effects of several hurricanes in the past few years have been detrimental to OCS oil and gas 

operations in the Gulf of Mexico. These effects included structural damage to fixed production platforms, 

platform rigs, semisubmersibles, jack-up rigs, and other equipment and facilities. Moreover, a major 

concern for MMS is the problem of a mobile offshore drilling unit (MODU) being moved off location by 

a storm event. When an MODU is displaced by a storm event, there are potentially serious consequences 

if it strikes or otherwise damages other facilities, pipelines, or vessels. In March 2009, an incident 
Environmental Assessment 19 

occurred that involved a large oil tanker striking a missing jack-up rig that had drifted off location and 

sunk during Hurricane Ike in 2008. A global positioning system (GPS) device provides a method to 

locate and track a displaced MODU during and after a storm event. This NTL only involves the aspect of 

using real-time GPS tracking while the MODU is still afloat. 

The purpose of this NTL is to provide guidance and requirements for the following: 

• outfitting all MODU’s that are moored, including jack-up rigs, with multiple GPS 

transponders that are installed and operational by July 1, 2009; 

• providing the MMS GOMR with access to real-time GPS location data; and 

• contacting the MMS GOMR Continuity of Operations Plan office when a MODU 

moves off location during a storm event. 

4.2. ENVIRONMENTAL AND SOCIOECONOMIC RESOURCES

A detailed impact analysis of the routine, accidental, and cumulative impacts of a typical CPA lease 

sale, which is representative of proposed Lease Sale 213, on environmental and socioeconomic resources 

can be found in Chapters 4.2.2.1.15.3 and 4.2.2.1.15.4, 4.4.14, and 4.5.15 of the Multisale EIS, 

respectively, and in Chapter 4.1 of the Supplemental EIS. The following chapters provide a summary of 

these potential impacts of proposed Lease Sale 213 on each environmental and socioeconomic resource 

and the conclusions of the analyses. The cumulative analysis considers environmental and socioeconomic 

impacts that may result from the incremental impact of proposed Lease Sale 213 when added to all past, 

present, and reasonably foreseeable future human activities, including non-OCS activities, as well as all 

OCS activities (OCS Program). 

New information discovered since publication of the Supplemental EIS is also presented below. This 

information was evaluated to determine if reanalysis of the impacts of proposed Lease Sale 213 was 

necessary. No new information was found that would necessitate a reanalysis of the impacts of proposed 

Lease Sale 213 upon environmental or socioeconomic resources. The analyses and potential impacts 

detailed in the Multisale EIS and the Supplemental EIS apply for proposed Lease Sale 213. New 

information was found and is presented in the following sections. This information confirms analyses or 

information presented in the Multisale EIS and the Supplemental EIS, but it does not change the 

conclusions of any of the analyses in the Multisale EIS and the Supplemental EIS. 

4.2.1. Air Quality 

The description of air quality in the Gulf of Mexico can be found in Chapter 3.1.1 of the Multisale 

EIS. A detailed impact analysis of the routine, accidental, and cumulative impacts of proposed Lease 

Sale 213 on air quality can be found in Chapters 4.2.2.1.1, 4.4.1, and 4.5.1 of the Multisale EIS, 

respectively. The following information is a summary of the impact analysis incorporated from the 

Multisale EIS. 

The new areas are located more than 100 mi (161 km) from the nearest coast and are not projected to 

increase the overall activity that would result from proposed Lease Sale 213; therefore, no additional 

impacts on air quality are projected as a result of the inclusion of the new acreage. 

The following routine activities associated with proposed Lease Sale 213 would potentially affect air 

quality: platform construction and emplacement; platform operations; drilling activities; flaring; seismicsurvey and support-vessel operations; pipeline laying and burial operations; evaporation of volatile 

petroleum hydrocarbons during transfers and from surface oil slicks; and fugitive emissions. Supporting 

materials and discussions are presented in Chapters 3.1.1 (description of the coastal air quality status of 

the Gulf coastal area), 4.1.1.6 (air emissions), and 4.1.1.9 (hydrogen sulfide) of the Multisale EIS. The 

parameters of this analysis are emission rates, surface winds, atmospheric stability, and the mixing height. 

Emissions of pollutants into the atmosphere from the routine activities associated with proposed 

Lease Sale 213 are projected to have minimal impacts to onshore air quality because of the prevailing 

atmospheric conditions, emission heights, emission rates, and the distance of these emissions from the 

coastline. Impacts from proposed Lease Sale 213 activities, including activities associated with the new 

areas, are expected to be well within the National Ambient Air Quality Standards (NAAQS). 
20 Impact Analysis

Portions of the Gulf Coast have ozone levels that exceed the Federal air quality standard, but the 

cumulative contribution from proposed Lease Sale 213 is very small. Ozone levels are on a declining 

trend because of air pollution control measures that have been implemented by States. This downward 

trend is expected to continue as a result of local as well as nationwide air pollution control efforts. 

Proposed Lease Sale 213 would have only a small effect on ozone levels in ozone nonattainment areas 

and would not interfere with the States’ schedule for compliance with the NAAQS. 

Accidents involving high concentrations of H2S could result in deaths as well as environmental 

damage. Other emissions of pollutants into the atmosphere from accidental events as a result of proposed 

Lease Sale 213 are not projected to have significant impacts on onshore air quality because of the 

prevailing atmospheric conditions, emissions height, emission rates, and the distance of these emissions 

from the coastline. These emissions are not expected to have concentrations that would change onshore 

air quality classifications. 

Emissions of pollutants into the atmosphere from the activities associated with the cumulative 

scenario are not projected to have significant effects on onshore air quality because of the prevailing 

atmospheric conditions, emission rates and heights, and the resulting pollutant concentrations. Onshore 

impacts on air quality from emissions from cumulative OCS activities are estimated to be within 

Prevention of Significant Deterioration (PSD) Class II allowable increments. 

The Offshore and Coastal Dispersion modeling results show that increases in onshore annual average 

concentrations of NOx, SO2, and PM10 are estimated to be less than the maximum increases allowed in the 

PSD Class II areas. 

The modeling results indicate that all concentrations are below the maximum allowable PSD 

increments. The impacts from proposed Lease Sale 213 are well within the PSD Class I allowable 

increment. The incremental contribution of proposed Lease Sale 213 (as analyzed in Chapter 4.2.2.1.1 in 

the Multisale EIS) to the cumulative impacts is not significant and is not expected to alter onshore air 

quality classifications. 

The Gulf Coast has significant visibility impairment from anthropogenic emission sources. Area 

visibility is expected to improve somewhat as a result of regional and national programs to reduce 

emissions. The cumulative contribution to visibility impairment from proposed Lease Sale 213 is 

expected to be very small. 

Ozone concentrations in the Baton Rouge, Louisiana, area exceed Federal standards. However, the 

contribution from OCS activities to that ozone concentration is very small (see also the 5-Year Program 

EIS; USDOI, MMS, 2007c). Ozone levels are expected to decline due to local as well as nationwide 

emission control measures. Emissions from the proposed Lease Sale 213 activities would contribute very 

little to the cumulative impacts from all pollution sources. 

The MMS is responsible for assessing the potential impacts of air pollutant emissions from offshore 

oil and gas exploration, development, and production sources in the OCS. This responsibility is driven by 

the Outer Continental Shelf Lands Act, which directs MMS to regulate OCS emission sources to assure 

that they do not significantly affect onshore air quality. The MMS air quality regulations are contained in 

30 CFR 250.303 through 304. In particular, MMS is responsible for determining if air pollutant 

emissions from oil and natural gas platforms and other sources in the Gulf of Mexico influence the ozone 

attainment (and nonattainment) status of onshore areas. This responsibility was mandated by the Clean 

Air Act Amendments of 1990 (CAAA). 

In addition, the CAAA requires MMS to coordinate air pollution control activities with USEPA. 

Thus, there will be a continuing need for emission inventories and modeling in the future, especially with 

the implementation of the 8-hour ozone standard. The future area of interest is not only Louisiana but it 

also includes Mississippi, Alabama, and Florida. Under provisions of the CAAA, the USEPA’s 

Administrator, in consultation with the Secretary of the Interior and the Commandant of the Coast Guard, 

will establish the requirements to control air pollution in OCS areas of the Pacific, Atlantic, Arctic, and 

eastward of 87o30'W. longitude in the Gulf of Mexico. 

To assess the emissions of offshore oil and gas platforms and their associated emissions, MMS 

conducted the Gulf of Mexico Air Quality Study (GMAQS) (Systems Applications International et al., 

1995). To develop a base year 2000 inventory of criteria pollutant and greenhouse gas emissions for all 

OCS oil and gas production-related sources in the Gulf of Mexico, MMS collected activity data from 

platform operators during the year 2000 (Wilson et al., 2004). The 2000 emission inventory has been 

updated by a 2005 emission inventory, which is now available (Wilson et al., 2007). A new emission 

inventory study has been awarded and updated emissions inventory data is now being collected for 2008. 
Environmental Assessment 21 

Additionally, a 5-year meteorological database has been completed. This database will be used by 

industry and MMS in point-source modeling plans analysis to ensure there are no significant impacts to 

onshore areas (Douglas and Hudischewskyj, 2008). 

The MMS is conducting a synthesis study (Douglas et al., in press) that will consolidate all MMS air 

quality studies, meteorological studies, and emissions studies (1990-2005) into one database, which is 

more suitable for analysis. Also, general analysis is being done on 8-hour ozone nonattainment coastal 

areas and the Breton Class I area to ensure there are no significant impacts to onshore areas. The USEPA 

has issued a new ozone 8-hour standard of 75 parts per billion, effective March 12, 2008 (USEPA, 

2009a). 

Figure 3-1 of the Multisale EIS presents the air quality status (i.e., ozone nonattainment) in the Gulf 

Coast as of September 2005. Figure 4 below shows that the status of these coastal counties has not 

changed as of March 12, 2009 (USEPA, 2009b). 

Figure 4. Status of Ozone Attainment in the Coastal Counties and Parishes of the Central and Western Gulf of 

Mexico (USEPA, 2009b). 

Air quality data for 2008 from Mississippi, Alabama, and Florida show all States in attainment of the 

NAAQS for all criteria pollutants (USEPA, 2009b). However, for criteria pollutant PM2.5, Alabama has 

four nonattainment counties (USEPA, 2009c). Jefferson, Shelby, Walker, and Jackson Counties are 

located in north and central Alabama; therefore, their status is not associated with offshore oil and gas 

activities or coastal infrastructure related to offshore oil and gas activity. 

The MMS has reexamined the analysis for air quality presented in the Multisale EIS and the 

Supplemental EIS, based on the additional information presented above. No new significant information 

was discovered that would alter the impacts for air quality presented in the two documents; therefore, a 

new analysis of the potential impacts of proposed Lease Sale 213 on air quality is not required. The 

analysis and potential impacts detailed in the Multisale EIS and the Supplemental EIS still apply for 

proposed Lease Sale 213. 
22 Impact Analysis

4.2.2. Water Quality 

A description of water quality in coastal and marine waters can be found in Chapter 3.1.2 of the 

Multisale EIS. An analysis of the routine, accidental, and cumulative impacts of proposed Lease Sale 213 

on water quality can be found in Chapters 4.2.2.1.2, 4.4.2, and 4.5.2 of the Multisale EIS, respectively. 

The following information is a summary of the impact analysis incorporated from the Multisale EIS. The 

new areas are located more than 100 mi (161 km) from the nearest coast and are not projected to increase 

the overall activity that would result from proposed Lease Sale 213; therefore, no additional impacts on 

water quality are projected as a result of the inclusion of the new acreage. 

The primary sources of impacts to water quality in coastal waters from routine operations are pointsource and storm-water discharges from land-based support facilities, and vessel discharges while in 

coastal waters. Recently, USEPA signed the final Vessel General Permit (VGP), and it became effective 

on December 19, 2008. This permit is in addition to already existing National Pollutant and Discharge 

Elimination System (NPDES) permit requirements and now increases the NPDES regulations so that 

discharges incidental to the normal operation of vessels operating as a means of transportation are no 

longer excluded unless exempted from NPDES permitting by Congressional legislation (USEPA, 2008a). 

The impacts to coastal water quality from proposed Lease Sale 213 should be minimal as long as all 

existing regulatory requirements are met. 

The primary impacting sources to marine water quality during exploratory activities are discharges of 

drilling fluids and cuttings. During installation activities, the primary impacting sources to water quality 

are sediment disturbance and turbidity. Impacting discharges during production activities include 

produced water and supply-vessel discharges. Regulations are in place to limit the levels of contaminants 

in these discharges. During platform removal, sediment disturbance, gaseous by-products of explosives 

or abrasive grit from cutting are the impacting discharges. Impacts to marine waters from routine 

activities associated with proposed Lease Sale 213, including the new areas, should be minimal as long as 

regulatory requirements are followed. 

Accidental events associated with proposed Lease Sale 213 that could impact water quality include 

spills of oil and refined hydrocarbons, spills of chemicals or drilling fluids, and collisions and loss of well 

control that result in spills. Water quality is altered and degraded by oil spills through the increase of 

petroleum hydrocarbons and their various transformation/degradation products in the water. The extent 

of impact from a spill depends on the behavior and fate of oil in the water column (e.g., movement of oil 

and rate and nature of weathering), which, in turn, depends on oceanographic and meteorological 

conditions at the time. Smaller spills (<1,000 bbl) are not expected to significantly impact water quality 

in marine and coastal waters. Larger spills, however, could impact water quality, especially in coastal 

waters. Chemical spills, the accidental release of synthetic-based fluids, and blowouts are expected to 

have temporary localized impacts on water quality. 

Coastal water quality can be cumulatively impacted by inputs, which are transported through river 

inflows. These inputs include hydrocarbons, trace metals, sediment, and nutrients from human activities. 

Cumulative impacts on the water quality of the marine environment result from the addition of discharges 

from exploratory and production activities to a relatively pristine environment. The incremental 

contribution of proposed Lease Sale 213 to the cumulative impacts on marine water quality is not 

expected to be significant as long as all regulations are followed. 

The most recent information available was sought during the preparation of this EA for Lease Sale 

213. A broad Internet search for relevant new information, as well as a search for scientific journal 

articles, was conducted using a publicly available search engine. In addition, the websites for Federal and 

State agencies, and the Gulf of Mexico Alliance as well as other organizations were reviewed for newly 

released information. The Gulf of Mexico Alliance, a partnership between the Gulf States, was organized 

in 2005 as a collaborative means to solve regional problems to implement the U.S. Ocean Action Plan. 

Although new research and ongoing monitoring information is continuously available from many sources 

about various water quality parameters in the Gulf of Mexico, only new information (i.e., information not 

already summarized by the Multisale EIS and the Supplemental EIS) was included. Updated Federal 

reports and regulations were included if available. 

The overall coastal condition of the Gulf Coast was evaluated from 2001 to 2002 by USEPA and was 

rated as fair to poor (USEPA, 2008b). Specifically, water quality was rated as fair while sediment quality 

and the coastal habit index, a rating of wetlands habitat loss, which both affect water quality, were rated 

as poor. The USEPA also conducted similar evaluations from 1990 to 1996 (USEPA, 2001) and again 
Environmental Assessment 23 

from 1997 to 2000 (USEPA, 2005). Water quality was poor overall in the first Coastal Condition Report, 

but it increased to fair overall in the latter reports. Conversely, sediment quality was generally fair in the 

first two reports and decreased to poor in the last report. The Barataria/Terrebonne Estuary near Port 

Fourchon, which is a common service base, was ranked fair in terms of water quality (USEPA, 2007a) 

and was assessed as having moderately high eutrophic conditions by NOAA (Bricker et al., 2007). 

Although rated slightly better, Mobile Bay was still considered fair (USEPA, 2007a) and was assessed as 

having moderately low overall eutrophic conditions (Bricker et al., 2007). The NOAA examined 

additional Gulf Coast estuary systems near the CPA and, of those with sufficient data, the 

Mississippi/Atchafalaya Plume and Perdido Bay had high overall eutrophic conditions, Barataria Bay had 

moderate high overall eutrophic conditions, Breton/Chandeleur Sound and Lake Pontchartrain were 

ranked as having moderate overall eutrophic conditions, the Mississippi River had moderately low overall 

eutrophic conditions, and Mississippi Sound and Lake Borgne had overall low eutrophic conditions 

(Bricker et al., 2007). 

The leading source of contaminants that impair coastal water quality is urban runoff. Urban runoff 

can include suspended solids, heavy metals and pesticides, oil and grease, and nutrients. Urban runoff 

increases with population growth, and the Gulf Coast region has experienced a 103 percent population 

growth since 1970 (USDOC, NOAA, 2008). Other pollutant source categories include (1) agricultural 

runoff, (2) municipal point sources, (3) industrial sources, (4) hydromodification, and (5) shipping. 

The USEPA’s NPDES general permit for the Western Gulf of Mexico (GMG290000, which 

authorizes discharges to surface water during drilling and production) was reissued and went into effect 

on October 1, 2007 (USEPA, 2007b). The permit will expire on September 30, 2012. The USEPA was a 

cooperating agency on the Multisale EIS, and USEPA relied on the Multisale EIS and the Supplemental 

EIS in reissuing the permit. The USEPA Region 4 NPDES general permit (GMG460000) for offshore oil 

and gas activities in Federal waters in the eastern portion (east of 87.5o W. longitude) of the OCS of the 

Gulf of Mexico expires on December 31, 2009 (USEPA, 2007c). The USEPA’s Region 4 is currently 

working on the new permit and expects to publish a public notice by November 2009 (Robinson-Shell, 

personal communication, 2009). 

The zone of hypoxia on the Louisiana-Texas shelf occurs seasonally and is affected by the timing of 

the Mississippi and Atchafalaya Rivers’ discharges carrying nutrients to the surface waters. The hypoxic 

conditions last until local wind-driven circulation mixes the water again. During the mapping cruise of 

July 18-23, 2009, the hypoxic zone measured 8,000 km2 (3,000 mi2

) (LUMCON, 2009). This was far 

smaller than the forecasted amount of 22,000-25,000 km2 (7,500-8,500 mi2

) (LUMCON, 2009), as well as 

smaller than the 20,720 km2

 (8,000 mi2) dead zone area reported last year (LUMCON, 2008). However, 

the dead zone was “thicker” (i.e., higher volume) than normal this year and was severely low in oxygen, 

with values usually less than 0.5 milligrams/liter. Factors that may have contributed to smaller than 

predicted average area of the dead zone include (1) below average flow of the Mississippi River in July; 

(2) the timing of the single research cruise; (3) weather conditions prior to and during the cruise, 

including wind and wave conditions; and (4) the optimization of the forecast models (i.e., the models are 

optimized for long-term conditions, not short-term conditions) (LUMCON, 2009). The primary waste 

stream associated with oil and gas exploration and production is produced water (Veil et al., 2004), and 

the contribution of produced water to hypoxic conditions is minimal. The amount of oxygen-demanding 

pollutants in produced water was determined for produced water discharged into the hypoxic zone (Veil 

et al., 2005) as a requirement for the Region 6 reissued NPDES general permit. Existing hypoxia models 

were used to analyze the potential incremental impacts to the hypoxia from produced-water discharges. 

The USEPA determined that the potential impact on the hypoxia from produced-water discharges was 

insignificant (USEPA, 2007d). Thus, proposed Lease Sale 213 should have insignificant impacts on the 

Gulf of Mexico hypoxic zone. 

The MMS has reexamined the analysis for water quality presented in the Multisale EIS and the 

Supplemental EIS, based on the additional information presented above. No new significant information 

was discovered that would alter the impacts for water quality presented in the two documents; therefore, a 

new analysis of the potential impacts of proposed Lease Sale 213 on water quality is not required. The 

analysis and potential impacts detailed in the Multisale EIS and the Supplemental EIS still apply for 

proposed Lease Sale 213. 
24 Impact Analysis

4.2.3. Sensitive Coastal Environments 

4.2.3.1. Coastal Barrier Beaches and Associated Dunes 

The description, physical location, and formative processes that create the various coastal beaches and 

barrier island complexes are described in Chapter 3.2.1.1 of the Multisale EIS. A description of 

integrated shoreline environments, the barrier islands, and the dune zones that comprise and delineate the 

various vegetated habitats along these mainland and barrier beaches can also be found in Chapter 3.2.1.1 

of the Multisale EIS. 

Hurricane Katrina in August 2005 caused severe erosion and landloss for the coastal barrier islands of 

the deltaic plain. The pre-storm land area of the Chandeleur Islands was reduced to half of their size by 

Hurricane Katrina, based on aerial post-storm surveys by the U.S. Geological Survey (USDOI, GS, 2005 

and 2008). A search was conducted for new information published since completion of the Supplemental 

EIS. An electronic search of available literature and agency Internet sites, and personal interviews with 

various Federal and State agency researchers and mangers responsible for these coastal resources were 

conducted. Additional information regarding the impacts of Hurricanes Gustav and Ike were found and 

noted in the appropriate sections below. 

Updated physical descriptions and topographical changes in the barrier islands and beaches due to the 

impacts of Hurricanes Katrina and Rita were included in the Supplemental EIS. Additional updates 

concerning the condition of the resources following the landfall of Hurricanes Gustav and Ike were 

included in the Dalmatian South SEA (USDOI, MMS, 2009b). 

The 2008 hurricane season was devastating to both the Louisiana and east Texas coasts. Hurricanes 

Gustav and Ike impacted the coastal areas of Louisiana and Texas within a 2-week period. Hurricane 

Gustav had the greatest impact on the Louisiana coast, further degrading the easternmost barrier islands 

and beaches that had been initially impacted by Hurricanes Katrina and Rita. The more severe damages 

occurred along islands in the Isle Deniers chain, with major landloss leaving Wine Island as a small 

mound barely above the waterline. East Timbalier Island was also overtopped and heavily eroded, with 

Whiskey Island now divided in half by a deep channel. Raccoon Island lost over one-third of its mass and 

almost all of its elevation (Wells, 2008). The beach berms and dunes along Grand Isle were breached, 

heavily eroded, or washed away. The live oak forest around Grand Isle was badly damaged by saltwater. 

The Texas coast was spared major damage from Hurricane Gustav but took the brunt of Hurricane 

Ike. The most extensive damage occurred on the Bolivar Peninsula as a result of the overtopping of 

dunes and breeching beach ridges, resulting in reduced dune height or, in some cases, the removal of the 

dunes completely. Closer to the location of peak surge though, just east of High Island, Texas, the flood 

waters were high enough to completely submerge the barriers as the surge flowed rapidly back into the 

Gulf of Mexico. Dune-height changes exceeding 3 ft (1 m) were observed more than 32 mi (60 km) to 

the east of the landfall position, while dune-height changes exceeding 3 ft (1 m) were observed as far as 

25 mi (40 km) to the west of landfall. In Galveston, Texas, the seawall is considered to be the dune crest 

and the elevation change is roughly 12 inches (30 centimeter), which is consistent with the previously 

determined vertical offset. Shoreline erosion of 492 ft (150 m) was observed near Gilchrist, Texas. More 

than 164 ft (50 m) of shoreline erosion was experienced over a wide region from the seawall, extending 9 

mi (15 km) to the west. The area of positive shoreline change at the south end of Galveston Island is 

related to spit formation at San Luis Pass and may not be related to Hurricane Ike. The area of positive 

shoreline change 50 mi (80 km) to the east of landfall is due to the seaward transport of sediment as storm 

water drained from the marshes (Doran et al., 2009). Only general, qualitative damage assessments using 

aerial photography have been prepared to date by the U.S. Geological Survey (USGS) for impacts 

associated with Hurricane Gustav. 

While most of the wildlife refugees along the Texas coast were impacted by the surge from Hurricane 

Ike, the J.W. Murphree Wildlife Management area received the most substantial damage to dunes, 

beaches, and marsh ponds. West of Hurricane Ike’s landfall, the differences in the storm surge, winds, 

and waves, as well as higher coastal elevations, all worked together to lessen the storm’s impact on the 

coast. Galveston Island had partial seawall protection along the beach front, lessening the erosion of 

shore face to areas in front of the seawall. On the sandy beaches west of the seawall, peak dune 

elevations before the storm were 2-4 m (7-13 ft), roughly half of the elevation of the seawall. The coastal 

change along this unprotected stretch of Galveston Island was considerably more than on the sea-walled 

section nearby, but it was less than the visible impacts on the Bolivar Peninsula. 
Environmental Assessment 25 

The intensity and frequency of hurricanes in the Gulf over the last 5 years has greatly impacted the 

system of protective barrier islands, beaches, and dunes and associated wetlands along the Gulf Coast. As 

a result of losing dune and island elevations, as well as associated marshes and backshore and foreshore 

wetlands, the inland coasts and wetlands are more vulnerable to future hurricanes and wind-driven tidal or 

storm events. 

A detailed impact analysis of the routine, accidental, and cumulative impacts of proposed Lease Sale 

213 on barrier islands and coastal beaches can be found in Chapters 4.2.2.1.3.1, 4.4.3.1, and 4.5.3.1 of the 

Multisale EIS, respectively. The following information is a summary of the impact analysis incorporated 

from the Multisale EIS, along with any additional information noted in the available literature and Federal 

and State agency reports or research, as well as information noted through Internet searches of pertinent 

literature. 

A variety of activities required to implement and support proposed Lease Sale 213 include pipeline 

emplacements, navigation channel use and dredging, and construction or continued use of oil and gas 

infrastructure. These activities are expected to be restricted to temporary and localized disturbances of 

the coastal barrier beaches and associated dunes. The 0-1 pipeline landfalls projected in support of 

proposed Lease Sale 213 are not expected to cause significant impacts to barrier beaches because of the 

use of non-intrusive installation methods. The projected 0-1 gas processing plants would not be expected 

to be constructed on barrier beaches. The use of existing facilities built inland may, through natural storm 

driven erosion and shoreline recession, be located in the barrier beach and dune zone and may contribute 

to the erosion there. Proposed Lease Sale 213 may contribute to the extended use of these facilities. No 

facilities are expected to be constructed on barrier beaches. Channel and inlet maintenance needed, as 

well as erosion protection works (jetties) required to assure access to the production and supply facilities, 

may contribute to minor and localized impacts on adjacent barrier beaches due to sediment deprivation. 

This would likely occur in the sediment starved coasts of Louisiana. Based on use, proposed Lease Sale 

213 would account for a very small percentage of these impacts, which would occur whether proposed 

Lease Sale 213 is implemented or not. Strategic placement of dredged material from channel 

maintenance, channel deepening, or related actions can mitigate adverse impacts upon those localized 

areas. Proposed Lease Sale 213 is not expected to adversely alter barrier beach configurations 

significantly beyond existing, ongoing impacts in very localized areas down drift of artificially jettied and 

maintained channels. 

No significant impacts to the physical shape and structure of the barrier beaches are expected as a 

result of accidental events associated with proposed Lease Sale 213. The primary accidental impacts that 

may be associated with proposed Lease Sale 213 results from the probability of offshore or coastal oil 

spills contacting the barrier or coastal beaches. The probabilities of proposed-action-related spills 

occurring in OCS waters and contacting various parishes and counties are provided in Chapter 4.3.1 of the 

Multisale EIS. The risk of offshore spills ≥1,000 bbl occurring and contacting barrier beaches within 10 

days is discussed in Chapter 4.3.1.8 of the Multisale EIS. Generally, the coastal, deltaic parishes of 

Louisiana have the highest risk of being contacted by an offshore spill resulting from proposed Lease Sale 

213; Plaquemines Parish has the highest probability at 10-15 percent. Should a slick from such a spill 

make landfall, the volume of oil remaining in the slick is expected to be small. Coastal spills in offshore 

coastal waters or in the vicinity of Gulf tidal inlets present a greater potential risk to barrier beaches 

because of their close proximity. Inland spills that occur away from Gulf tidal inlets are generally not 

expected to significantly impact barrier beaches and dunes. The additional oil production added to the 

existing CPA lease area is not projected to substantially increase the probabilities for occurrence of 

offshore spills. Activity that would result from the two new areas would cause a negligible increase, if 

any, in the risk of an offshore spill ≥1,000 bbl occurring and contacting environmental resources. 

Because spills on the OCS would occur at least 3-10 nmi (4-12 mi; 6-19 km) from shore, it is unlikely 

that any diesel spills would make landfall prior to breaking up. Diesel fuel, with its lighter distillate 

components, does not contain the heavier components that contribute to crude oil’s longer persistence in 

the environment. Spills <1,000 bbl are not expected to persist as a slick on the surface of the water 

beyond a few days, and only spills >50 bbl have a chance of remaining as a cohesive mass long enough to 

be transported any distance. In Louisiana, Plaquemines Parish has the greatest risk (10-15%) of a spill 

occurring and contacting shore within 10 days. During the time that a spill in this area would take to 

reach shore, the spill would be acted upon by various weathering processes to degrade and disperse it, 

thereby greatly reducing the amount of oil in the surface slick. 
26 Impact Analysis

The passage of four powerful hurricanes in 2005 (Katrina and Rita) and 2008 (Gustav and Ike) 

resulted in changes in barrier island topography, lowering beach elevation and, therefore, potentially 

increasing the probability for beach oiling farther up the beach head in some locations. Due to the now 

more gentle slopes and, in some cases, cuts into the mainland barrier beaches left by the storms, more of 

the transition zone between the water and beach ridge may be more vulnerable to spills. In some areas 

along the Louisiana Coast, barrier islands were severely damaged either by heavily degrading beach front 

elevations and beach ridges or by completely overtopping the islands by either removing or completely 

redistributing the sediments on the island so that the island becomes submerged. Should a spill contact a 

barrier beach, oiling is expected to be light and sand removal during cleanup activities should be 

minimized. No significant impacts to the physical shape and structure of barrier beaches and associated 

dunes are expected to occur as a result of proposed Lease Sale 213. 

Barrier beaches along coastal Louisiana and Texas have experienced severe erosion and landward 

retreat (marine transgression) because of natural processes enhanced by human activities. Mississippi, 

Alabama, and Florida have also experienced beach erosion and shoreline depletion in varying degrees as a 

result of Hurricanes Ivan, Katrina, Rita, Wilma, and to some extent Gustav. Four significant hurricanes 

(Katrina, Rita, Gustav, and Ike) have made landfall along the Texas/Louisiana coast in the last 3 years, 

greatly degrading the coastal beaches, marshes, and barrier islands. Due to these reduced elevations and 

the continued effect of subsidence, sea level rise and saltwater intrusion, the protection once afforded the 

inland marshes and mainland has been greatly reduced. Impact-producing factors from non-OCS activity 

that contribute to barrier beach and dune erosion or to the conversion to another environment include (1) 

levee construction and stabilization structures for channels and beaches; (2) natural processes such as 

hurricanes, erosion, and subsidence and sea level rise; (3) recreational vehicle use on dunes and beaches; 

(4) recreational and commercial development; and (5) removal of coastal vegetation. The deterioration of 

Gulf barrier beaches is expected to continue in the future. The Texas coast has experienced land loss 

because of a decrease in the volume of sediment delivered to the coast because of dams on coastal rivers, 

a natural decrease in sediment supply as a result of climatic changes during the past several thousand 

years, and subsidence along the coast. Louisiana is currently continuing to initiate ongoing, state- and 

Federally-sponsored coastal programs and projects through the Coastal Wetlands, Planning, Protection 

and Restoration Act (CWPPRA) and Louisiana Coastal Area (LCA) programs, along with the federallyfunded Coastal Impact Assistance Program (CIAP) initiatives being finalized and managed by MMS. All 

of these programs will cumulatively protect, build, restore, and enhance coastal ecosystems, and they will 

attempt to reduce coastal land loss in general and will include assistance in coastal and barrier beach 

rehabilitation or restoration. 

The impact-producing factors that could affect barrier beaches, islands, and dunes which are related 

to OCS activities may include oil spills, beach cleanup, pipeline emplacement, and vessel-induced 

erosion. However, due to the distance of the proposed action from shore, the absence of pipeline 

landfalls, and the minimal supply-vessel support, only the following impact-producing factors could 

potentially affect the barrier beaches and shorelines. The impact-producing factors would include the 

minimal potential of beach oiling from oil spills. Additional OCS activities in the foreseeable future 

could include the need for pipeline emplacement, onshore facilities, and increased supply-vessel support. 

The incremental contribution of the proposed action’s impacts to the cumulative impact on barrier islands 

and beaches is negligible and is likely undetectable among the other cumulative impacts. However, if 

future pipeline installations are necessary, avoidance procedures for pipeline emplacement near barrier 

islands and beaches have been included in “conditioned permits” required by the U.S. Army, Corps of 

Engineers. These procedures assure that either the pipeline activities near these sensitive beaches are 

placed under the barrier islands and beaches, using indirect drilling techniques, or the pipeline routing is 

planned to avoid these sensitive areas. While there was some refinement of post-storm data and working 

drafts of various storm impacts, no new significant information was discovered that would alter the 

impacts for coastal beaches and barrier island complexes presented in the Multisale EIS; therefore, a new 

analysis of the potential impacts of proposed Lease Sale 213 on coastal beaches and barrier island 

complexes is not required. 

The MMS has reexamined the analysis for coastal barrier beaches and associated dunes presented in 

the Multisale EIS and the Supplemental EIS, based on the additional information presented above. No 

new significant information was discovered that would alter the impacts for coastal barrier beaches and 

associated dunes presented in the two documents; therefore, a new analysis of the potential impacts of 
Environmental Assessment 27 

proposed Lease Sale 213 on these resources is not required. The analysis and potential impacts detailed 

in the Multisale EIS and the Supplemental EIS still apply for proposed Lease Sale 213. 

4.2.3.2. Wetlands 

A detailed description of coastal wetlands can be found in Chapter 3.2.1.2 of the Multisale EIS. A 

detailed impact analysis of the routine, accidental, and cumulative impacts of proposed Lease Sale 213 on 

coastal wetlands can be found in Chapters 4.2.2.1.3.2, 4.4.3.2, and 4.5.3.2 of the Multisale EIS, 

respectively. An explanation of the routine and accidental impact-producing factors can be found in 

Chapters 4.1 and 4.3 of the Multisale EIS, respectively. A detailed discussion of the potential effects of 

OCS activities on wetland resources can be found in Chapter 4.3.2.2 of the Programmatic EA (USDOI, 

MMS, 2003); Chapters 4.2.2.1.3.2, 4.3.1.3.1, 4.3.1.3.2, and 4.4.3.2 of the Multisale EIS (USDOI, MMS, 

2007a); and Chapter 4.1.3.2.3 of the Supplemental EIS (USDOI, MMS, 2008a); and they are hereby 

incorporated by reference into this EA. This EA directly tiers from these recent lease sale NEPA analyses 

in the CPA. No significant cumulative impacts on wetlands would be expected from proposed Lease Sale 

213 or as the result of past, present, or reasonably foreseeable oil and gas development in the area. The 

following information is a summary of that information, along with updated information. 

Hurricane-induced wetlands damage as a result of Hurricanes Katrina and Rita has been incorporated 

by reference, and the damages were further refined and discussed in subsequent NEPA documents as 

information or data became available. The Dalmatian South SEA further discussed and described 

damages to Louisiana and Texas wetland habitat as a result of Hurricanes Gustav and Ike (USDOI, MMS, 

2009). The descriptions of these damages are hereby incorporated by reference and are summarized 

below. 

The post-storm (Hurricanes Katrina and Rita) estimates of land change made by USGS (Barras, 2006) 

indicated that there was an increase of 217 mi2

 (562 km2) of land lost to open water (which primarily 

comprised of wetlands being replaced by open water). These new water areas represent losses caused by 

the direct removal of wetlands vegetation by scouring, water-level variation attributed to normal tidal and 

transitory areas and meteorological variation in satellite imagery. Hurricane Katrina focused on the 

coastal area of Louisiana around New Orleans, as well as Mississippi, eastern Alabama, and west Florida. 

Following Hurricanes Katrina and Rita, another series of hurricanes (Gustav and Ike) made landfall along 

the Louisiana and Texas coasts in September 2008. 

Hurricane Gustav made landfall as a Category 2 storm near Cocodrie, Louisiana, pushing large surges 

of saline water into the fresh marshes and coastal swamps of Louisiana from Grand Isle westward. Areas 

of Lower Plaquemines and Lafourche Parishes had levees that were breeched or overtopped, trapping the 

saline storm water in the marshes and wooded swamps, thus inundating oak ridges, which were impacted 

by the standing storm water. Fresh and brackish marshes in the Point Au Chene, Salvador, and Pass a 

Loutre State Wildlife Management Areas suffered damage to the various wetland types as a result of 

rollover, blow over, scour, salt burn, and long-term inundation. While Hurricane Gustav did not impact 

the quantity of wetlands that Hurricanes Katrina and Rita impacted, it did have a severe and continuing 

effect on the coastal barrier islands and the wetlands associated with backshore and foreshore. While 

submerged aquatic vegetation is relatively sparse or spotty throughout the Louisiana coastal area, it was 

heavily impacted throughout the coastal shallows, with some ponds shown to be completely devoid of 

submerged aquatic vegetation. While Hurricane Gustav affected the eastern portion of the Louisiana 

coast closer to Grand Isle and Houma, Hurricane Ike concentrated on Louisiana’s western coast. The 

forested areas inundated by Hurricane Ike’s floodwaters have drained and most trees appear to have 

suffered minimal impacts. Maples and willows appear to have suffered the most damage (i.e., broken 

limbs and blow downs) from Hurricane Gustav’s winds. Cypress and oaks directly exposed to the winds 

of Hurricanes Gustav and Ike were “burned” from wind and salt spray. 

The Texas coast received the brunt of Hurricane Ike, where it made landfall slightly east of 

Galveston. The resulting 13- to 15-ft (4- to 5-m) storm surges washed over the elevated western coastline 

of Texas from High Island westward across the Bolivar Peninsula to the west side of Galveston Island. 

The storm surge basically removed the dune systems and significantly lowered the beach elevations along 

this portion of the Texas coast. The erosion and washover associated with Hurricane Ike’s tidal surge 

breeched beach ridges, opening the inland freshwater ponds and their associated wetlands to the sea. 

As a result of the four successive storms, the Louisiana and Texas coasts have lost protective 

elevations, barrier islands, and wetlands, and they now have the potential for transitioning to a less 
28 Impact Analysis

productive salt-marsh system in areas where fresh-marsh systems once existed. State (Louisiana Dept. of 

Natural Resource) and Federal (MMS and U.S. Army, Corps of Engineers) governments are currently 

implementing coastal restoration projects, including freshwater and sediment diversions, beach 

restorations, marsh building, and restoration through several programs such as CWPPRA, CIAP, LCA, 

and Louisiana’s Coastal Planning and Restoration. 

A detailed explanation of the routine and accidental impact-producing factors can be found in 

Chapters 4.1 and 4.3 of the Multisale EIS, respectively. A detailed discussion of the potential effects of 

OCS activities on wetland resources can be found in Chapter 4.3.2.2 of the Programmatic EA (USDOI, 

MMS, 2003a); Chapters 4.2.2.1.3.2, 4.3.1.3.1, 4.3.1.3.2, and 4.4.3.2 of the Multisale EIS; and Chapter 

4.1.3.2.3 of the Supplemental EIS; and they are hereby incorporated by reference into this EA. This EA 

directly tiers from these recent lease sale NEPA analyses in the CPA. No significant cumulative impacts 

on wetlands would be expected from the proposed Lease Sale 213 or as the result of past, present, or 

reasonably foreseeable oil and gas development in the area. 

The primary impacts resulting from routine activities associated with proposed Lease Sale 213 that 

could affect wetlands and marshes include 0-1 pipeline emplacements, possible channel maintenance, 

increased vessel traffic, disposal of OCS-related wastes, and the use and construction of support 

infrastructure in these coastal areas. Other potential impacts that are indirectly associated with OCS oil 

and gas activities are wake erosion resulting from increased vessel traffic, interruption of necessary 

sedimentary processes caused by flood protection (levees) and erosion protection, saltwater intrusion that 

changes the hydrology leading to unfavorable conditions for wetland vegetation, and vulnerability to 

storm damage from eroded wetlands. The existing armored navigation channels (such as Port Fourchon) 

that are used to reach the shore base will eliminate or, in the worst case, minimize the potential for any 

shoreline erosion that could result from vessel traffic. Widening rates for navigation canals in general 

have been reduced as a result of aggressive management and the restoration of canal edges to prevent 

erosion, including the construction of rock breakwaters along portions of some of these canals, as well as 

enforcing “wake zone” speeds (Johnston et al., 2007). The draft of the study entitled “Navigation Canal 

Bank Erosion in the Western and Central Gulf of Mexico” (Thatcher et al., in preparation) is expected to 

be finalized in December 2009. This study indicates that shoreline retreat rates along the canals were 

highly variable within and across unarmored portions of the navigation canals. It was noted that geology 

and vegetation type influenced the rate of shoreline change. In general, the study noted that the canal 

widening rate slowed to -0.99 m/yr (-3.25 ft/yr) for the 1996/1998-2005/2006 time period compared with 

-1.71 m/yr (-5.61 ft/yr) for the earlier 1978/1979-1996/1998 time period. 

Offshore oil spills resulting from the proposed action are not expected to significantly damage any 

wetlands along the Gulf Coast. The additional oil production added to the existing CPA lease area is not 

projected to substantially increase the probabilities for occurrence of offshore spills. Activity that would 

result from the two new areas would cause a negligible increase, if any, in the risk of an offshore spill 

≥1,000 bbl occurring and contacting environmental resources. Because spills on the OCS would occur at 

least 3-10 nmi (4-12 mi; 6-19 km) from shore, it is unlikely that any diesel spills would make landfall 

prior to breaking up. Diesel fuel, with its lighter distillate components, does not contain the heavier 

components that contribute to crude oil’s longer persistence in the environment. Spills <1,000 bbl are not 

expected to persist as a slick on the surface of the water beyond a few days, and only spills >50 bbl have a 

chance of remaining as a cohesive mass long enough to be transported any distance. Although the impact 

may occur generally over coastal regions, the impact has the highest probability of occurring in and 

around Plaquemines and St. Bernard Parishes, Louisiana. 

If a spill should occur, a spill plan is in place to confine and trap the spill offshore. Only elevated 

tides or strong southerly winds could drive a surface slick into coastal waters and environments. High 

winds would act to disperse oil slicks before they contact vegetated wetlands behind barrier islands, pass 

over narrow shoreline beaches, or penetrate inland along shorelines lacking beaches, which is typical of 

many areas of coastal Louisiana. 

Although the probability of occurrence is low, the greatest threat to wetland habitat is from an inland 

spill resulting from a vessel accident or pipeline rupture because of the proximity of the spill to the 

wetlands. While a resulting inland slick may cause minor impacts to wetland habitat and surrounding 

seagrass communities, the equipment and personnel used to clean up a slick over the impacted area may 

generate the greatest impacts. However, if an inland oil spill related to proposed Lease Sale 213 occurs, 

some impact to wetland habitat would be expected. Impacts to wetland habitats from an oil spill 

associated with activities related to proposed Lease Sale 213 would be expected to be low and temporary. 
Environmental Assessment 29 

Concerns were raised related to the potential impact of oil spills on the marine and coastal 

environments, specifically regarding the potential effects of oil spills on tourism, emergency response 

capabilities, spill prevention, effect of winds and currents on the transport of oil spills, accidental 

discharges from both deepwater blowouts and pipeline ruptures, and oil spills resulting from past and 

future hurricanes. While there is a concern for offshore oil spills resulting from proposed Lease Sale 213, 

they are not expected to damage significantly any wetlands along the Gulf Coast. The fate and behavior 

of oil spills, availability and adequacy of oil-spill containment and cleanup technologies, oil-spill cleanup 

strategies, impacts of various oil-spill cleanup methods, effects of weathering on oil spills, toxicological 

effects of fresh and weathered oil, air pollution associated with spilled oil, and short-term and long-term 

impacts of oil on wetlands are additional accidental concerns. However, if an inland oil spill related to 

proposed Lease Sale 213 occurs, some impact to wetland habitat would be expected. 

As noted in the discussion above, Hurricanes Katrina and Rita resulted in 217 mi2

 (562 km2) of land 

change, primarily conversion of wetlands to open water (Barras, 2006). These new water areas represent 

landlosses caused by the direct removal of wetlands. Barras (2007a) noted permanent losses cannot be 

estimated until several growing seasons have passed and the transitory impacts of the hurricanes are 

minimized. It is, however, too early to estimate the actual overall marsh loss. Both the Louisiana and 

Texas coasts have incurred additional impacts as a result of Hurricanes Gustav and Ike. These two storms 

further reduced the elevations of barrier islands, breeched beach ridges, and overtopped or removed dunes 

along the Texas coast. In some cases, the resulting breeches in beach ridges (Texas) have resulted in the 

draining of inland freshwater ponds, opening these areas and their surrounding wetlands to saltwater 

intrusion. Dune elevation loss was the most extreme (20 ft; 3 m) along the portion of the Bolivar 

Peninsula near Crystal Beach, Texas, which was in the front quadrant of Hurricane Ike’s landfall. In 

general, beach ridges and dune elevations have been reduced by hurricane activity. This reduction in 

protective elevation potentially increases the vulnerability of these once-protected wetlands to oiling. 

Cumulative impacts on wetlands that result from oil and gas leasing, exploration, development, and 

production activity were discussed in Chapter 4.5.3.2 of the Multisale EIS. Wetland losses resulting from 

storms, hurricanes, coastal development, subsidence, and manmade and natural erosion will continue. 

The vulnerability of the coasts is increasingly at risk due to the disappearance of marsh and the loss of 

barrier island elevations that afforded some barrier for coastal protection. The already eroded Louisiana 

barrier island chain was severely impacted by Hurricanes Katrina, Rita, Gustav, and Ike, thus further 

lowering the protection (substantial reduction in dune and island elevations) afforded the mainland 

marshes and beaches from oil spills that these barrier features previously provided (USDOI, GS, 2008; 

USEPA, 2008b). Breton Island, one of the islands comprising the hard-hit Chandeleur barrier island 

chain, lost approximately 50 percent of its landmass (Hall, 2006). Raccoon and Wine Islands were also 

severely degraded by Hurricane Gustav. Overall, impacts from OCS activities are expected to be low and 

could be further reduced through mitigation, such as horizontal, directional (trenchless) drilling 

techniques to avoid damages to these sensitive habitats. Secondary impacts to wetlands would be 

primarily from vessel traffic corridors. Vessel traffic associated with the proposed action is expected to 

contribute minimally to the erosion and widening of navigation channels and canals due to the use of 

armored channels and enforcement of speeds that will reduce wake-related erosion. In cooperation with 

USGS, MMS is currently developing a study design to better understand the relationship between OCS 

vessel activity and marshes bordering active navigation canals. 

The effects of pipelines, canal dredging, navigation activities, and oil spills on wetlands are described 

in Chapters 4.2.1.1.3.2, 4.4.3.2, and 4.5.3.2 of the Multisale EIS. The subsidence of wetlands is discussed 

in more detail in Chapter 4.1.3.3.1 of the Multisale EIS. Existing regulations and development permitting 

procedures indicate that development-related wetland loss may be slowed and that very few new onshore 

OCS facilities, other than pipelines, will be constructed in wetlands. Impacts from State onshore oil and 

gas activities are expected to occur as a result of dredging for new canals, maintenance and usage of 

existing rig access canals and drill slips, and preparation of new well sites. Indirect impacts from such 

activities are expected to continue. The State of Louisiana’s onshore oil activities will continue to have 

impacts associated with the construction and maintenance of navigation channels, pipeline canals, 

wellhead, or distribution hubs in coastal wetland areas. 

The primary concern for the potential impact from accidental activities associated with proposed 

Lease Sale 213 is related to oil spills. The potential for the occurrence of nearshore and inland oils spills 

(along with their associated impacts) as a result of Lease Sale 213 is low because of the small number of 

pipelines that will come ashore and because of the expected small increases in support vessel traffic. 
30 Impact Analysis

While there is a concern for offshore oil spills resulting from proposed Lease Sale 213, the spills are not 

expected to damage significantly any wetlands along the Gulf Coast. However, if an inland oil spill 

related to proposed Lease Sale 213 occurs, some impact to wetland habitat would be expected. 

A search was conducted for new information published since completion of the Supplemental EIS. A 

search of Internet information sources (Bernier et al., 2006; Clark and LaGrone, 2006; FDEP, 2005 and 

2007; USDOI, GS, 2007a-e), as well as personal interviews with personnel from State and Federal 

resource agencies (Cahoon, personal communication, 2007), was conducted to determine the availability 

of recent information. Various Internet sources were examined to assess recent information regarding 

wetland loss or potential new threats to coastal wetlands that may be pertinent to the CPA. The search 

revealed a recent study indicating the very structure of coastal wetlands will likely be altered by sea-level 

rise, as community shifts will be governed by the responses of individual species to new environmental 

conditions (Spalding and Hester, 2007). While this information is not new, the study did explore, through 

the use of controlled experiments, how the variance in flooding regimes, salinities, and the particular plant 

species involved respond to the changed coastal environment. Other findings related to changes in Statemandated coastal policies addressing wetland protection, restoration, preservation, and development. 

John Barras with the USGS Wetland Resources Center noted that, while the current wetland loss numbers 

cited in the Multisale EIS and the Supplemental EIS have not changed significantly, marsh recovery (or 

land gain) varies from location to location. Marsh recovery seems to be doing well in the Caernarvon 

area, located in St. Bernard Parish, Louisiana, where the marsh was not completely uprooted. Other areas 

comprised of large shallow flats are becoming vegetated with various aquatic species, but not necessarily 

with viable marsh. In marsh areas in the vicinity of Pearl River, where there is still an active delta 

providing sediments, the marshes are coming back. Current overflights have revealed large scour scars 

caused by the hurricane surge in some marshes as a result of Hurricane Katrina (Barras, personal 

communication, 2007b). These scars are a result of the complete uprooting of the marsh vegetation and 

some may never revegetate depending on the depth of the scar. Where root mats have not been 

completely removed, the marsh is recovering. The visual overflight inspection of the area south of the 

Stennis Space Center in Mississippi revealed a great deal of marsh loss, but no quantification of this loss 

is available at this time. 

Based on conversations with Bob Morton of the USGS Integrated Science Center in St. Petersburg, 

Florida, and Ralph Clark with the Florida Department of Natural Resources, Bureau of Beaches, there has 

been no new information released concerning wetland loss in Florida (Clark, personal communication, 

2009; Morton, personal communication, 2009). Mr. Clark indicated that the primary wetlands along the 

Florida coast are located in the more stable, low-energy environments in southern Florida around the 

Tampa Bay area. Florida is in the process of combining, updating, and standardizing their various 

vegetative inventory databases, but there is no deadline for completion at this time. 

The MMS has reexamined the analysis for wetlands presented in the Multisale EIS and the 

Supplemental EIS, based on the additional information presented above. No new significant information 

was discovered that would alter the impacts for wetlands presented in the two documents; therefore, a 

new analysis of the potential impacts of proposed Lease Sale 213 on wetlands is not required. The 

analysis and potential impacts detailed in the Multisale EIS and the Supplemental EIS still apply for 

proposed Lease Sale 213. 

4.2.3.3. Seagrass Communities 

The description of the biology and distribution of seagrass can be found in Chapter 3.2.1.3 of the 

Multisale EIS. A detailed impact analysis of the routine, accidental, and cumulative impacts of proposed 

Lease Sale 213 on seagrass can be found in Chapters 4.2.2.1.3.3, 4.4.3.3, and 4.5.3.3 of the Multisale EIS, 

respectively. The following information is a summary of the impact analysis incorporated from the 

Multisale EIS. 

The routine activities associated with proposed Lease Sale 213 that could adversely affect seagrass 

communities include construction of pipelines, canals, navigation channels, and shore facilities; 

maintenance dredging; vessel traffic (propeller scars, etc.); and oil spills, spill-response, and cleanup 

activities. Environmental permit requirements for locating pipelines will result in very minimal impact to 

seagrass if any new pipeline runs to shore due to proposed Lease Sale 213. Impacts from routine 

activities resulting from proposed Lease Sale 213 are expected to have negligible effects on seagrass 

communities. 
Environmental Assessment 31 

Pipeline construction in coastal waters would temporarily elevate turbidity in nearby submerged 

vegetation beds, depending upon currents. If constructed, the pipeline landfall would temporarily elevate 

turbidity in submerged vegetation beds near the pipeline routes. The COE and State permit requirements 

are expected to require pipeline routes that avoid beds of high-salinity, submerged vegetation and to 

reduce turbidity impacts to within tolerable limits. Hence, impacts to submerged vegetation by pipeline 

installation are projected to be very small and short term. 

After bottom sediments are disturbed by pipeline installation, they will be generally more easily 

suspended by storms than before the disturbance. In estuaries, this increase is not projected to be a 

problem. Due to tidal flushing, this increased turbidity is projected to be below significant levels. 

Dredging generates the greatest overall risk to submerged vegetation, and hurricanes cause direct 

damage to seagrass beds, which may fail to recover in the presence of cumulative stresses. Maintenance 

dredging will not have a substantial impact on existing seagrass habitat given that no new channels are 

expected to be dredged as a result of proposed Lease Sale 213. Increased dredging is expected only in 

areas that do not support seagrass beds. 

Vessel traffic will generally only pose a risk to seagrass when nearshore. Beds of submerged 

vegetation within a navigation channel’s area of influence will have already adjusted their bed 

configurations in response to turbidity generated there. Very little, if any, damage would then occur as a 

result of typical channel traffic. Generally, propwash will not resuspend sediments in navigation channels 

beyond pre-project conditions. 

Depending upon the submerged plant species involved, narrow prop scars in dense portions of the 

beds will take 1-7 years to recover. Scars through sparser areas will take 10 years or more to recover. 

The recovery period increases with the width of the scar. Extensive damage to a broad area or damage to 

an already stressed area may never be corrected. 

Most seagrass communities on the Gulf Coast are located behind barrier islands and in embayments. 

Because of the location of most seagrass communities, inshore oil spills pose the most severe threat. 

Such spills may result from either vessel collisions that release fuel and lubricants or from pipelines that 

rupture. Increased water turbulence due to storms or vessel traffic can break apart the surface sheen and 

disperse some oil into the water column, potentially causing some dieback of leaves for one growing 

season. It may take as much as 5-10 years of community succession before faunal composition resembles 

pre-impact conditions. 

A search was conducted for new information published since completion of the Multisale EIS. 

Various Internet sources were examined to determine any recent information regarding seagrass. Sources 

investigated include the USGS National Wetlands Research Center, the USGS Gulf of Mexico Integrated 

Science Data Information Management System, Gulf of Mexico Alliance workshops in spring of 2007, 

Florida Department of Environmental Protection, USEPA, and coastal universities. Other sites were 

found through general internet searches. 

New information was discovered from these information sources. The workshops held by the Gulf of 

Mexico Alliance in the spring of 2007 revealed some new research and new collations of old information 

(May, 2007; Vittor, 2007; Hardegree, 2007). May (2007) discussed the distribution of seagrass in 

southeastern Mississippi waters, finding some burial of seagrass after Hurricane Katrina, seasonal 

fluctuation of Ruppia maritima, and persistent Halodule wrightii. Vittor (2007) discussed seagrass in 

Mississippi Sound and Alabama based on four aerial surveys from 1940 to 2002. His analysis showed 

seagrass declines of from 52 to 88 percent in these areas since 1940. Hardegree (2007) highlighted 

declines in seagrass in Christmas Bay and the Lower Laguna Madre. He also analyzed propeller scarring, 

recovery, and regulation. One new master’s thesis on seagrass communities in Biloxi Marsh, Mississippi, 

was published. In 2006, fish communities at sites denuded of seagrass by Hurricane Katrina resembled 

those of sites with no seagrass before the hurricane (Maiaro, 2007). 

The effects of Hurricane Ike on seagrass communities around Galveston Bay have not been reported. 

Thorough internet searches for information reveal no new assessments of seagrasses in the area. The 

nearest substantial seagrass beds are in Christmas Bay, about 30 miles (48 km) west of the storm track of 

Hurricane Ike. These beds likely sustained some damage from wind driven wave action from the north 

side of the barrier islands. The USGS assessed shoreline change after Ike. Their report includes an aerial 

image of the shoreline at Christmas Bay which shows limited dune washover onto the coastal highway. 

The salt marsh behind the beach appears relatively intact, suggesting little damage to adjacent seagrass 

habitats (Doran et al. 2009). 
32 Impact Analysis

The MMS has reexamined the analysis for seagrasses presented in the Multisale EIS and the 

Supplemental EIS, based on the additional information presented above. No new significant information 

was discovered that would alter the impacts for seagrasses presented in the two documents; therefore, a 

new analysis of the potential impacts of proposed Lease Sale 213 on seagrasses is not required. The 

analysis and potential impacts detailed in the Multisale EIS and the Supplemental EIS still apply for 

proposed Lease Sale 213. 

4.2.4. Sensitive Offshore Benthic Resources 

4.2.4.1. Continental Shelf Benthic Resources 

4.2.4.1.1. Live Bottoms (Pinnacle Trend) 

The description of the biology of Live Bottoms (Pinnacle Trend) can be found in Chapter 3.2.2.1.1 of 

the Multisale EIS. A detailed impact analysis of the routine, accidental, and cumulative impacts of 

proposed Lease Sale 213 on the Pinnacle Trend can be found in Chapters 4.2.2.1.4.1.1, 4.4.4.1.1, and 

4.5.4.1.1 of the Multisale EIS, respectively. The following information is a summary of the impact 

analysis incorporated from the Multisale EIS. 

Seventy blocks are within the region defined as the pinnacle trend, which contains live bottoms that 

may be sensitive to oil and gas activities. These blocks are located in the northeastern portion of the CPA 

and are located between 60- and 120-m (197- and 394-ft) water depths in the Main Pass and Viosca Knoll 

lease areas. 

The MMS developed the Live Bottom (Pinnacle Trend) Stipulation to protect biological resources in 

the Pinnacle Trend in response to concerns that disturbing any of the series of topographic irregularities 

might adversely affect biological communities that have developed on the surfaces of the features and 

affect the habitat they provide for pelagic fishes. The stipulation requires avoidance of the features during 

the placement of oil and gas structures and the laying of pipelines. The stipulation has been adopted in 

CPA sales since 1990 and has been effective in protecting the features and resident biological 

communities from damage. The proposed Live Bottom (Pinnacle Trend) Stipulation is presented in 

Chapter 2.4.1.3.2 of the Multisale EIS as a potential mitigating measure for leases resulting from 

proposed Lease Sale 213. 

Impact-producing factors resulting from routine activities of OCS oil and gas operations include 

physical damage, anchoring, structure emplacement and removal, pipeline emplacement, drilling 

discharges, discharges of produced waters, and discharges of domestic and sanitary wastes. In addition, 

accidental subsea oil spills or blowouts associated with OCS activities can cause damage to live bottoms. 

The inclusion of the Live Bottom (Pinnacle Trend) Stipulation would preclude the occurrence of physical 

damage and limit other impact-producing factors. Few operations exist in the region and no communitywide impacts are projected. 

Non-OCS activities in the vicinity of the hard-bottom communities include recreational boating and 

fishing, import tankering, and natural events such as extreme weather conditions, and extreme 

fluctuations of environmental conditions (e.g., nutrient pulses, low dissolved oxygen levels, seawater 

temperature minima, and seasonal algal blooms). These activities could cause severe damage that could 

threaten the survival of the live/hard-bottom communities. Ships using fairways in the vicinity of the 

Pinnacle Trend anchor in the general area on occasion, and numerous fishermen take advantage of the 

relatively shallow and easily accessible resources of regional live/hard bottoms. These activities could 

lead to severe and permanent physical damage. During severe storms, such as hurricanes, large waves 

may reach deep enough to stir bottom sediments. Because of the depth of the Pinnacle Trend area, these 

forces are not expected to be strong enough to cause direct physical damage to organisms living on the 

reefs. 

Impacts from blowouts, pipeline emplacement, muds and cuttings discharges, other operational 

discharges, and structure removals should be minimized because of the proposed Live Bottom (Pinnacle 

Trend) Stipulation, and the dilution of discharges and resuspended sediments in the area. Potential 

impacts from discharges will probably be further reduced by USEPA discharge regulations and permits 

restrictions. Potential impacts from oil spills ≥1,000 bbl would be restricted because of the depth of the 

features (>20 m (66 ft)) (if the spill occurs on the sea surface), because subsea pipeline spills are expected 

to rise rapidly, and because of the low prospect of pipelines being routed immediately adjacent to 
Environmental Assessment 33 

live/hard bottoms. The frequency of impacts to live/hard bottoms should be rare and the severity slight. 

Impacts from accidents involving anchor placement on live/hard bottoms could be severe in small areas 

(those actually crushed or subjected to abrasions). 

The incremental contribution of proposed Lease Sale 213 to the cumulative impact is expected to be 

slight, with possible impacts from physical disturbance of the bottom, discharges of drilling muds and 

cuttings, other OCS discharges, structure removals, and oil spills. Negative impacts should be restricted 

by the implementation of the Live Bottom (Pinnacle Trend) Stipulation and site-specific stipulations, the 

depths of the features, and the currents in the live/hard-bottom area. 

A search was conducted for new information published since completion of the Multisale EIS. 

Various Internet sources were examined to determine any recent information regarding the Pinnacle 

Trend. Sources investigated include USGS, NOAA, USEPA, and coastal universities. Other sites were 

found through general Internet searches. 

The MMS is the lead researcher of the Pinnacle Trend, and the results of the most recent MMSfunded studies were incorporated into the Multisale EIS. Additional information was found regarding 

ongoing USGS studies conducted to support MMS management (Gardner et al., 2002; USDOI, GS, 2003; 

Weaver et al., 2001). The USGS Florida Integrated Science Center’s pinnacles project works to identify 

patterns of demersal fish distribution, community structure, and trophic relationships associated with reeflike carbonate banks and mounds in the Pinnacle Trend area (USDOI, GS, 2003). The present research 

seeks to further define the basis of physical-biological coupling, aspects of community structure and 

function, biotope affinities, and critical habitat parameters for hard-bottom areas in the eastern Gulf of 

Mexico. The project applies state-of-the-art geological tools to resolve community differentiation in 

terms of physical geological structure (topography), detail (surface characteristics), and topographically 

induced current complexity, i.e., physical mechanisms driving community structure. This work enhances 

the understanding of the Pinnacle Trend regional ecosystem to support MMS management and 

decisionmaking. 

The MMS has reexamined the analysis for the Pinnacle Trend presented in the Multisale EIS and the 

Supplemental EIS, based on the additional information presented above. No new significant information 

was discovered that would alter the impacts for the Pinnacle Trend presented in the two documents; 

therefore, a new analysis of the potential impacts of proposed Lease Sale 213 on the Pinnacle Trend is not 

required. The analysis and potential impacts detailed in the Multisale EIS and the Supplemental EIS still 

apply for proposed Lease Sale 213. 

4.2.4.1.2. Topographic Features 

The description of the biology of topographic features can be found in Chapter 3.2.2.1.2 of the 

Multisale EIS. A detailed impact analysis of the routine, accidental, and cumulative impacts of proposed 

Lease Sale 213 on topographic features can be found in Chapters 4.2.2.1.4.1.2, 4.4.4.1.2, and 4.5.4.1.2 of 

the Multisale EIS, respectively. A description of the Topographic Features Stipulation governing oil and 

gas activities near these features can be found in Chapter 2.4.1.3.1 of the Multisale EIS. The following 

information is a summary of the impact analysis incorporated from the Multisale EIS. 

Potential OCS-related impacts include the anchoring of vessels and structure emplacement, 

operational discharges (drilling muds and cuttings, and produced waters), blowouts, oil spills, and 

structure removal. Activities causing mechanical disturbance represent the greatest threat to the 

topographic features. This would, however, be prevented by the continued application of the 

Topographic Features Stipulation. 

Non-OCS activities are thought to have the greatest potential of impacting the topographic features, 

particularly those that could mechanically disrupt the bottom (such as anchoring and treasure-hunting 

activities). Natural events such as hurricanes or the collapse of the tops of the topographic features 

(through dissolution of the underlying salt structure) could cause severe impacts. Impacts from scuba 

diving, fishing, ocean dumping, and discharges or spills from tankering of imported oil are likely to have 

little or no impact on the topographic features. 

It is assumed that a resuspension of sediments or a subsurface oil spill following a blowout could 

reach the biota of a topographic feature. If this were to occur, the impacts would be primarily sublethal 

with the disruption or impairment of a few elements at the local scale, but no interference to the general 

system performance would occur. Oil spills can cause damage to benthic organisms when the oil contacts 

the organisms. In the unlikely event that oil from a subsurface spill would reach the biota of a 
34 Impact Analysis

topographic feature, the effects would be primarily sublethal for corals and much of the other fully 

developed biota. It is anticipated that potential recovery for such an event would occur within a period of 

2 years (USDOC, NOAA, 2007a; Shigenaka, 2001; Rice et al., 1983). In the highly unlikely event that 

oil from a subsurface spill reached an area containing coral cover (e.g., Flower Garden Banks and Stetson 

Bank) in lethal concentrations, the impacted area would be small, but its recovery could take in excess of 

10 years. However, due to the application of the proposed Topographic Features Stipulation, blowouts 

would not occur in the immediate vicinity of the topographic features and associated biota. Therefore, 

there would be little impact on the features. 

The incremental contribution of proposed Lease Sale 213 (as analyzed in Chapter 4.2.2.1.4.1.2 of the 

Multisale EIS) to the cumulative impact is negligible because of the implementation of the Topographic 

Features Stipulation, which would limit mechanical impacts and operational discharges. Furthermore, 

there is a low probability and low risk of accidental OCS-related events such as blowouts and oil spills 

occurring in the immediate vicinity of a topographic feature. 

A search was conducted for new information published since completion of the Multisale EIS. 

Various Internet sources were examined to determine any recent information regarding topographic 

features. Sources investigated include USGS, NOAA, USEPA, and coastal universities. Other sites were 

found through general Internet searches. 

One ongoing study reports some preliminary results that indicate small shifts in benthic cover 

including an increase in algae and decrease in sponges (Kraus et al., 2007). They also report some shifts 

in fish community composition. These shifts are likely the result of impacts from Hurricane Rita in 

September 2005. 

The MMS has conducted studies of select topographic features since Hurricane Rita. Long-term 

monitoring has continued on a yearly basis at the East and West Flower Garden Banks through an equal 

partnership between MMS and NOAA’s National Marine Sanctuary program. This monitoring not only 

expands MMS’s knowledge and understanding of the Flower Garden Banks ecosystem, but it also 

improves the foundation from which management decisions are made. Another MMS study, PostHurricane Assessment of Sensitive Habitats of the Flower Garden Banks Vicinity (Robbart et al., 2009), is 

investigating hurricane effects at the East Flower Garden, Sonnier, McGrail, Geyer, and Bright Banks. 

Initial assessment of the East Flower Garden Bank reveals mechanical damage from Hurricane Rita and a 

major bleaching event (up to 46% of corals). This was followed by an outbreak of coral disease affecting 

up to 8 percent of corals at the East Flower Garden Bank. These are the most severe recorded outbreaks 

of bleaching and disease at the Flower Garden Banks (Precht et al., 2008). Other preliminary results 

suggest little hurricane damage to McGrail, Geyer, and Bright Banks but severe damage at Sonnier Bank 

(Robbart et al., 2009). Speculation is that Sonnier Bank was more affected because of its shallower depth 

and position on the east side of the storm track. Anecdotal information also suggests that repeated anchor 

damage has affected Sonnier Bank. Community recovery is expected to take at least 5 years if anchor 

damage is prevented. The Flower Garden Bank National Marine Sanctuary (FGBNMS) is revising its 

management plan (pending Congressional approval) to include Sonnier Bank within its protective 

boundaries. Monitoring at the Flower Garden Banks in 2006 and 2007 shows good recovery of corals 

with no significant deterioration of community health (Precht et al., 2006; Zimmer et al., in preparation). 

Initial assessments by the FGBNMS show damage from Hurricane Ike, which passed directly over the 

East Flower Garden Bank, to be similar to that of Hurricane Rita. Numerous large coral heads were 

toppled, scarring from projectiles is evident across the reef, a field of Madracis mirabilis (yellow pencil 

coral) was broken, and sand was redistributed. Preliminary results from long-term monitoring by MMS 

and the FGBNMS in August 2009 reveal good recovery, which continues to support the evaluation of the 

Flower Garden Banks as a healthy and resilient reef habitat. 

The MMS has reexamined the analysis for topographic features presented in the Multisale EIS and 

the Supplemental EIS, based on the additional information presented above. This new information 

illustrates the potential effects of natural events, especially the cumulative impacts of hurricanes. 

However, OCS-related oil and gas impacts remain unchanged and previous assessments are still accurate. 

No new significant information was discovered that would alter the impacts for topographic features 

presented in the two documents; therefore, a new analysis of the potential impacts of proposed Lease Sale 

213 on topographic features is not required. The analysis and potential impacts detailed in the Multisale 

EIS and the Supplemental EIS still apply for proposed Lease Sale 213. 
Environmental Assessment 35 

4.2.4.2. Continental Slope and Deepwater Resources 

4.2.4.2.1. Chemosynthetic Deepwater Benthic Communities 

The description of the biology, life history, and distribution of chemosynthetic deepwater benthic 

communities can be found in Chapter 3.2.2.2.1 of the Multisale EIS. A detailed impact analysis of the 

routine, accidental, and cumulative impacts of proposed Lease Sale 213 on chemosynthetic communities 

can be found in Chapters 4.2.2.1.4.2.1, 4.4.4.2.1, and 4.5.4.2 of the Multisale EIS, respectively. The 

following information is a summary of the impact analysis incorporated from the Multisale EIS. 

Chemosynthetic communities are susceptible to physical impacts from structure placement (including 

templates or subsea completions), anchoring, pipeline installation, or from a blowout depending on 

bottom-current conditions. The regulations explained by NTL 2000-G20 greatly reduce the risk of these 

physical impacts by requiring avoidance of potential chemosynthetic communities identified on required 

geophysical survey records or by requiring photodocumentation to establish the absence of 

chemosynthetic communities prior to approval of the structure or pipeline emplacement. 

If the presence of a high-density community was missed using existing procedures, potentially severe 

or catastrophic impacts could occur due to raking of the sea bottom by anchors and anchor chains and 

partial or complete burial by muds and cuttings associated with pre-riser discharges or some types of 

riserless drilling. Variations in water currents may affect the dispersal of synthetic-based drilling fluids 

and influence the areal extent of impacts. The severity of such an impact is such that there would be 

incremental losses of productivity, reproduction, community relationships, and overall ecological 

functions of the community, and incremental damage to ecological relationships with the surrounding 

benthos. Impacts to chemosynthetic communities from any accidental release of oil would be a remote 

possibility. 

Impacts to deepwater communities in the Gulf of Mexico from sources other than OCS activities are 

considered negligible. The incremental contribution of proposed Lease Sale 213 to the cumulative impact 

is expected to be slight, and to result from the effects of the possible impacts caused by physical 

disturbance of the seafloor and minor impacts from sediment resuspension. 

Proposed Lease Sale 213 is expected to cause little damage to the ecological function or biological 

productivity of the widespread, low-density chemosynthetic communities. The rarer, widely scattered, 

high-density, Bush Hill-type chemosynthetic communities could experience very minor (if any) impacts 

from drilling discharges or resuspended sediments located at more than 1,500 ft (457 m) away as required 

by NTL 2000-G20. 

A search was conducted for new information published since completion of the Multisale EIS. A 

search of Internet information sources (including scientific journals) as well as interviews with personnel 

from academic institutions and governmental resource agencies was conducted to determine the 

availability of new information. In addition, there is an ongoing MMS/National Oceanic and 

Atmospheric Administration, Office of Ocean Exploration (NOAA-OE) co-sponsored research project, 

Investigations of Chemosynthetic Communities on the Lower Continental Slope of the Gulf of Mexico, 

specifically targeting chemosynthetic communities in the deep GOM (USDOI, MMS, 2006; Brooks et, 

al., 2008). This study was referenced in the Multisale EIS and the Supplemental EIS and is being tracked. 

Some new chemosynthetic communities were discovered in 2006 and 2007; however, they were located 

using the same criteria used during the biological review process for plans or pipeline applications to 

determine the proximity of areas with potential chemosynthetic communities. 

The MMS has reexamined the analysis for chemosynthetic communities presented in the Multisale 

EIS and the Supplemental EIS, based on the additional information presented above. No new significant 

information was discovered that would alter the impacts for chemosynthetic communities presented in the 

two documents; therefore, a new analysis of the potential impacts of proposed Lease Sale 213 on 

chemosynthetic communities is not required. The analysis and potential impacts detailed in the Multisale 

EIS and the Supplemental EIS still apply for proposed Lease Sale 213. 

4.2.4.2.2. Nonchemosynthetic Deepwater Benthic Communities 

The description of the biology, life history, and distribution of nonchemosynthetic deepwater benthic 

communities can be found in Chapter 3.2.2.2.2 of the Multisale EIS. A detailed impact analysis of the 

routine, accidental, and cumulative impacts of proposed Lease Sale 213 on nonchemosynthetic 

communities can be found in Chapters 4.2.2.1.4.2.2, 4.4.4.2.2, and 4.5.4.2 of the Multisale EIS, 
36 Impact Analysis

respectively. The following information is a summary of the impact analysis incorporated from the 

Multisale EIS. 

Some impact to soft-bottom, benthic communities from drilling and production activities would occur 

as a result of physical impact from structure placement (including templates or subsea completions), 

anchoring, and installation of pipelines regardless of their locations. Megafauna and infauna communities 

at or below the sediment/water interface would be impacted from the muds and cuttings normally 

discharged at the seafloor at the start of every new well prior to riser installation. The impact from muds 

and cuttings discharged at the surface over deep water is expected to be low. Drilling muds and cuttings 

would not be expected to accumulate on the seafloor in layers thick enough to produce negative impacts 

on benthic infauna beyond a few hundred meters from the surface-discharge location. Even in situations 

where substantial burial of typical benthic infaunal communities occurred, recolonization from 

populations from neighboring soft-bottom substrate would be expected over a relatively short period of 

time for all size ranges of organisms, in a matter of days for bacteria, and probably less than 1 year for 

most all macrofauna species. 

Deepwater coral habitats and other potential hard-bottom communities not associated with 

chemosynthetic communities appear to be relatively rare. These unique communities are distinctive and 

similar in nature to protected pinnacles and topographic features on the continental shelf. Any hard 

substrate communities located in deep water would be particularly sensitive to impacts from OCS 

activities. Impacts to these sensitive habitats could permanently prevent recolonization with similar 

organisms requiring hard substrate. 

Accidental events resulting from proposed Lease Sale 213 are expected to cause little damage to the 

ecological function or biological productivity of the widespread, typical, deep-sea benthic communities. 

Some impact to benthic communities would occur as a result from an accidental blowout. Megafauna and 

infauna communities at or below the sediment/water interface would be impacted by the physical 

disturbance of a blowout or by burial from resuspended sediments. Even in situations where substantial 

burial of typical benthic communities occurred due to a blowout, recolonization from populations from 

neighboring substrate would be expected over a relatively short period of time for all size ranges of 

organisms in the same timeframes as described above. 

Impacts to deepwater communities in the Gulf of Mexico from sources other than OCS activities are 

considered negligible. The incremental contribution of proposed Lease Sale 213 to the cumulative impact 

is expected to be slight, and to result from the effects of the possible impacts caused by physical 

disturbance of the seafloor and minor impacts from sediment resuspension. 

Proposed Lease Sale 213 is expected to cause little damage to the ecological function or biological 

productivity of the widespread, typical soft-bottom, deep-sea benthic communities. Impacts to other 

hard-bottom communities are expected to be avoided as a consequence of the application of the existing 

NTL 2000-G20 for chemosynthetic communities. The same geophysical conditions associated with the 

potential presence of chemosynthetic communities also results in hard carbonate substrate. Therefore, the 

NTL protects both types of habitat. 

A search was conducted for new information published since completion of the Multisale EIS. A 

search of Internet information sources (including scientific journals) as well as interviews with personnel 

from academic institutions and governmental resource agencies was conducted to determine availability 

of new information. 

Interest in deepwater corals has increased rapidly in the last decade as more coral systems are 

discovered worldwide and their importance in providing habitat for diverse communities is realized. The 

MMS recently published two studies on hard-bottom communities with an emphasis on Lophelia coral. 

The following are summaries of the results of these two studies, which will be used to develop additional 

studies of hard-bottom habitats in the deep Gulf of Mexico and which will also enhance the ability of 

MMS to protect sensitive, deepwater biological features. 

The report, Characterization of Northern Gulf of Mexico Deepwater Hard-Bottom Communities with 

Emphasis on Lophelia Coral (CSA, 2007), presents the results of a study of 10 sites on the northern Gulf 

of Mexico continental slope consisting of hard-bottom areas that generally include dense assemblages of 

the coral Lophelia pertusa. Study elements include geological characterization; biological 

characterization, imaging, and sampling; water chemistry; and physical oceanography including shortterm and long-term current meter deployments. This was the first comprehensive study of the distribution 

of Lophelia pertusa and its biology and ecology in the Gulf of Mexico. Results suggest that Lophelia 

pertusa plays a major role in the ecology of hard-bottom habitats on the upper slope. 
Environmental Assessment 37 

The report, Seafloor Characteristics and Distribution Patterns of Lophelia pertusa and Other Sessile 

Megafauna at Two Upper-Slope Sites in the Northeastern Gulf of Mexico (Schroeder, 2007), presents 

results of a study funded to document the seafloor characteristics and the distribution patterns of the 

deepwater coral Lophelia pertusa and other sessile megafauna at two sites in the Gulf of Mexico. The 

two sites, Viosca Knoll 826 and Viosca Knoll 862-906, are located on the upper DeSoto Slope 

subprovince. One of the sites, Viosca Knoll 862-906, is in close proximity to the site reported from the 

1950’s field sampling by Moore and Bullis (1960). The dominant taxa at both the Viosca Knoll 862 and 

Viosca Knoll 906 sites, in terms of numbers and biomass, are anemones. The largest megafauna observed 

were the antipatharians at Viosca Knoll 862-906, with individual colonies estimated to be between 2.1 

and 2.4 m (7 and 8 ft) tall. There appear to be at least four species of antipatharians, and collectively, 

they are the second most abundant megafauna taxa at both sites. The dominant megafauna taxon at the 

Viosca Knoll 862 site is L. pertusa, which has successfully developed extensive assemblage complexes, 

comprised of large colony aggregations/thickets, at numerous locations. Viosca Knoll 826 has the most 

extensive development of L. pertusa found in the Gulf of Mexico to date. 

The report also discusses evidence of manmade disturbances. Furrows apparently produced when 

wire anchor cables, deployed in conjunction with oil and gas drilling operations conducted in this region, 

struck the bottom one or more times. When megafauna were present, moderate to severe damage to 

individual colonies or colony aggregations often resulted. However, there was no indication that 

extensive areawide destruction has occurred, even though these features are present throughout the main 

knoll survey area. 

In addition, there is an ongoing MMS/NOAA-OE co-sponsored research project, Investigations of 

Chemosynthetic Communities on the Lower Continental Slope of the Gulf of Mexico, which also looked at 

other hard bottoms including nonchemosynthetic communities (USDOI, MMS, 2006). This study was 

referenced in the Multisale EIS and the Supplemental EIS and is being tracked. Some new deepwater 

coral communities were discovered in 2006 and 2007; however, they were located using the same criteria 

used during the biological review process for plans or pipeline applications to determine the proximity of 

areas with potential chemosynthetic communities that also incorporates hard bottom and potential 

deepwater coral habitats. 

The MMS has reexamined the analysis for nonchemosynthetic deepwater benthic communities 

presented in the Multisale EIS and the Supplemental EIS, based on the additional information presented 

above. No new significant information was discovered that would alter the impacts for 

nonchemosynthetic deepwater benthic communities presented in the two documents; therefore, a new 

analysis of the potential impacts of proposed Lease Sale 213 on nonchemosynthetic deepwater benthic 

communities is not required. The analysis and potential impacts detailed in the Multisale EIS and the 

Supplemental EIS still apply for proposed Lease Sale 213. 

4.2.5. Marine Mammals 

The description of the biology, life history, and distribution of marine mammals in the Gulf of 

Mexico can be found in Chapter 3.2.3 of the Multisale EIS. A detailed impact analysis of the routine, 

accidental and cumulative impacts of proposed Lease Sale 213 on marine mammals can be found in 

Chapters 4.2.2.1.5, 4.4.5, and 4.5.5 of the Multisale EIS, respectively. The following information is a 

summary of the impact analysis incorporated from the Multisale EIS. With the exception of manatees, 

any of the marine species that occur in the GOM may be found in the new areas. However, the new areas 

are not unique in regards to marine mammal distribution. 

Potential effects on marine mammal species may occur from routine activities associated with 

proposed Lease Sale 213 and may be direct or indirect. The major impact-producing factors affecting 

marine mammals as a result of routine OCS activities include the degradation of water quality from 

operational discharges; noise generated by helicopters, vessels, operating platforms, and drillships; vessel 

traffic; explosive structure removals; seismic surveys; and marine debris from service vessels and OCS 

structures. 

Small numbers of marine mammals could be killed or injured by a chance collision with a service 

vessel; however, current MMS requirements and guidelines for vessel operation in the vicinity of 

protected species should minimize this risk (the proposed Protected Species Lease Stipulation and NTL 

2007-G04). 
38 Impact Analysis

Marine mammal ingestion of accidentally released industry debris is a concern. Entanglement in 

debris could have serious consequences. A marine mammal could suffer diminished feeding and 

reproductive success, and potential injury, infection, and death from entanglement in lost packing 

materials or debris. Industry has made good progress in debris management on vessels and offshore 

structures in the last several years. The debris awareness training, instruction, and placards required by 

the proposed Protected Species Lease Stipulation and NTL 2007-G03 should greatly minimize the 

amount of debris that is accidentally lost overboard by offshore personnel. 

There is no conclusive evidence whether anthropogenic noise has or has not caused long-term 

displacements of, or reductions in, marine mammal populations (Southall et al., 2007). Noise associated 

with proposed Lease Sale 213, including drilling noise, aircraft, and vessels, may affect marine mammals 

by eliciting a startle response or masking other sounds. However, many of the industry-related sounds are 

believed to be out of, or on the limits of, marine mammal hearing, and the sounds are also generally 

temporary. The continued presence of sperm whales in close proximity to some of the deepwater 

structures in the GOM tends to rule out concerns of permanent displacement from disturbance. 

Seismic operations have the potential to harm marine mammals in close proximity to firing airgun 

arrays. The proposed Protected Species Lease Stipulation and several mitigation measures, including 

onboard observers and airgun shut-downs for whales in the exclusion zone, included in NTL 2007-G02, 

Implementation of Seismic Survey Mitigation Measures and Protected Species Observer Program, 

minimize the potential of harm from seismic operations to marine mammals. 

Marine mammal death or injury is not expected from explosive structure-removal operations. 

Existing mitigations and those recently developed for structures placed in oceanic waters should continue 

to minimize adverse effects to marine mammals from these activities. 

Contaminants in waste discharges and drilling muds might indirectly affect marine mammals through 

food-chain biomagnification. Although the scope and magnitude of such effects are not known, direct or 

indirect effects are not expected to be lethal. 

Routine activities related to proposed Lease Sale 213, particularly when mitigated as required by 

MMS, are not expected to have long-term adverse effects on the size and productivity of any marine 

mammal species or population endemic to the northern GOM. 

Accidental blowouts, oil spills, and spill-response activities potentially resulting from proposed Lease 

Sale 213 could impact marine mammals in the GOM. Characteristics of impacts (i.e., acute vs. chronic 

impacts) depend on the magnitude, frequency, location, and date of accidents; characteristics of spilled 

oil; spill-response capabilities and timing; and various meteorological and hydrological factors. Chronic 

or acute exposure may result in harassment, harm, or mortality to marine mammals occurring in the 

northern Gulf. Marine mammals made no apparent attempt to avoid spilled oil in some cases (Smultea 

and Würsig, 1995); however, marine mammals have been observed apparently detecting and avoiding 

slicks in other reports (Geraci and St. Aubin, 1987). Exposure to hydrocarbons persisting in the sea 

following the dispersal of an oil slick is likely to result in sublethal impacts (e.g., decreased health and 

reproductive fitness, increased vulnerability to disease) to marine mammals. 

Activities considered under the cumulative scenario could affect protected cetaceans and sirenians. 

These marine mammals could be impacted by marine debris, contaminant spills and spill-response 

activities, vessel traffic, noise, seismic surveys, explosive structure removals, commercial fishing, capture 

and removal, and pathogens. The cumulative impact on marine mammals is expected to result in a 

number of chronic and sporadic sublethal effects (behavioral effects and nonfatal exposure to or intake of 

contaminants or debris) that may stress and/or weaken individuals and predispose them to infection from 

natural or anthropogenic sources. Few deaths are expected from potential impacts. Disturbance (e.g., 

noise) and/or exposure to sublethal levels of toxins and anthropogenic contaminants may stress animals, 

weaken their immune systems, and make them more vulnerable to parasites and diseases that normally 

would not be fatal. The net result of any disturbance would be dependent upon the size and percentage of 

the population likely to be affected, the ecological importance of the disturbed area, the environmental 

and biological parameters that influence an animal’s sensitivity to disturbance and stress, or the 

accommodation time in response to prolonged disturbance (Geraci and St. Aubin, 1980). Collisions 

between cetaceans and ships, although expected to be rare events, could cause serious injury or mortality. 

Natural phenomenon, such as tropical storms and hurricanes, are impossible to predict, but they will occur 

in the GOM. Generally, the offshore species and the offshore habitat are not expected to have been 

severely affected in the long term. However, species that occupy more nearshore habitats may have 
Environmental Assessment 39 

suffered more long-term impacts. The effects of recent Gulf of Mexico hurricanes are difficult to assess, 

but major impacts to Gulf marine mammal populations have not been reported. 

Effects of the incremental contribution of proposed Lease Sale 213, combined with non-OCS 

activities, may be deleterious to cetaceans occurring in the GOM. Biological significance, according to 

the National Research Council (2005) “an action or activity becomes biologically significant to an 

individual animal when it affects the ability of the animal to grow, survive, and reproduce. Those are the 

effects on individuals that can have population-level consequences and affect the viability of the species.” 

of any mortality would depend, in part, on the size and reproductive rates of the affected stocks, as well as 

the number, age, and size of animals affected. However, potential impacts from Lease Sale 213 activities 

are not expected to result in mortality. 

The ESA (16 U.S.C. 1631 et seq.), as amended (43 U.S.C. 1331 et seq.), establishes a national policy 

designed to protect and conserve threatened and endangered species and the ecosystems upon which they 

depend. The ESA is administered by FWS and NMFS. Section 7 of the ESA governs interagency 

cooperation and consultation. Under Section 7, MMS consults with FWS and NMFS to ensure that OCS 

activities under MMS jurisdiction do not jeopardize the continued existence of threatened or endangered 

species and/or result in adverse modification or destruction of their critical habitat. 

The formal consultation with NMFS was concluded with the Biological Opinion (BO) dated June 29, 

2007, and received by MMS on July 3, 2007 (USDOC, NMFS, 2007a). The BO concludes that the 

proposed lease sales and associated activities in the GOM in the 2007-2012 OCS Leasing Program, which 

includes Lease Sale 213, are not likely to jeopardize the continued existence of threatened and endangered 

species under NMFS jurisdiction or destroy or adversely modify designated critical habitat. 

Section 7(b)(4)(c) of the ESA specifies that, in order to provide an incidental take statement for an 

endangered or threatened species of marine mammal, the taking must be authorized under Section 

101(a)(5) of the Marine Mammal Protection Act (MMPA). Since no incidental take of listed marine 

mammals is expected or has been authorized under Section 101(a)(5)(A) of the MMPA and/or its 1994 

amendments (see ESA Section 7(b)(4)(C)), no statement on incidental take of endangered whales is 

provided and no take is authorized. Nevertheless, MMS must immediately notify (within 24 hours, if 

communication is possible) the NMFS’ Office of Protected Resources should a take of a listed marine 

mammal occur. 

On December 26, 2002, MMS submitted a request for 5-year regulations under the MMPA for the 

taking, by harassment, of sperm whales incidental to the oil and gas industry’s seismic surveys to 

discover oil and gas deposits offshore in the GOM. The NMFS published an Advance Notice of 

Proposed Rulemaking regarding the small take authorization on March 3, 2003 (68 FR 9991) and 

regulations are pending. Following issuance of such regulations under the MMPA, NMFS will amend 

this opinion to include any authorized incidental take of sperm whales, as may be appropriate at that time. 

The NMFS believes that a small number of listed species will experience adverse effects as the result 

of exposure to a large oil spill or ingestion of accidentally spilled oil over the lifetime of the action. 

Spilled oil resulting from proposed Lease Sale 213 could take up to 11 nonlethal takes of sperm whales 

over the 40-year lifetime of the proposed lease sale. However, NMFS is not including an incidental take 

statement for the incidental take of listed species due to oil exposure. Incidental take, as defined at 50 

CFR 402.02, refers only to takings that result from an otherwise lawful activity. The Clean Water Act (33 

U.S.C. 1251 et seq.), as amended by the Oil Pollution Act of 1990 (33 U.S.C. 2701 et seq.), prohibits 

discharges of harmful quantities of oil, as defined at 40 CFR 110.3, into waters of the United States. 

Therefore, even though the BO considered the effects on listed species by oil spills that may result from 

proposed Lease Sale 213, those takings that would result from an unlawful activity (i.e., oil spills) are not 

specified in this Incidental Take Statement and have no protective coverage under Section 7(o)(2) of the 

ESA. 

The FWS and MMS have consulted informally per FWS guidance on proposed Lease Sale 213. As a 

result, there were no new mitigations or terms and conditions from FWS (Chapter 5.2). 

The following information was not present in the Multisale EIS. A recent report presents the results 

of a study that collected dive patterns of sperm whales in the Atlantic Ocean to compare with the dive 

patterns and social structure of sperm whales in the Gulf of Mexico (Palka and Johnson, 2007). The 

study started a baseline of line transect, photo-identification, oceanographic, and genetic data for the 

Atlantic sperm whale. Compared with the Delta region in the Gulf of Mexico, parts of the Atlantic Ocean 

may serve as a control population of sperm whales with little exposure to sounds of oil- and gas-related 

activities. The study found Gulf of Mexico sperm whales follow a foraging and socializing cycle similar 
40 Impact Analysis

to that seen for the North Atlantic whales, but North Atlantic sperm whales dive considerably deeper 

(average 934 m (3,064 ft) compared with 639 m (2,096 ft) for GOM whales) when foraging (Jochens et 

al., 2008; Palka and Johnson, 2007). 

Based on MMS studies, NOAA surveys, opportunistic sightings, whaling catches, and stranding 

records, sperm whales in the GOM occur year-round. Sperm whales appear to favor water depths of 

about 1,000 m (3,281 ft) and may be concentrated in at least two geographic regions of the northern Gulf: 

an area off the Dry Tortugas and offshore of the Mississippi River Delta (Maze-Foley and Mullin, 2006); 

however, distribution also appears influenced by the occurrence and movement of cyclonic/anticyclonic 

currents in the GOM. The MMS released the results of the multiyear, multifaceted Sperm Whale Seismic 

Study in 2008. This comprehensive research greatly increased the knowledge of sperm whale distribution 

and behavior in the Gulf of Mexico and contributed substantially to the worldwide body of knowledge on 

sperm whales (Jochens et al., 2008). 

The MMS has reexamined the analysis for marine mammals presented in the Multisale EIS and the 

Supplemental EIS, based on the additional information presented above. No new significant information 

was discovered that would alter the impacts for marine mammals presented in the two documents; 

therefore, a new analysis of the potential impacts of proposed Lease Sale 213 on marine mammals is not 

required. The analysis and potential impacts detailed in the Multisale EIS and the Supplemental EIS still 

apply for proposed Lease Sale 213. 

4.2.6. Sea Turtles 

The description of the biology, life history, and distribution of sea turtles in the Gulf of Mexico can 

be found in Chapter 3.2.4 of the Multisale EIS. A detailed impact analysis of the routine, accidental, and 

cumulative impacts of proposed Lease Sale 213 on sea turtles can be found in Chapters 4.2.2.1.6, 4.4.6, 

and 4.5.6 of the Multisale EIS, respectively. The following information is a summary of the impact 

analysis incorporated from the Multisale EIS. Because the new areas are more than 100 mi (160 km) 

from the nearest coast, sea turtles may potentially exist within these areas. However, impacts in the new 

areas are expected to be similar to those in the rest of the proposed CPA sale area. 

Routine activities resulting from proposed Lease Sale 213 have the potential to harm sea turtles and 

therefore have been analyzed in the Multisale EIS. Activities considered include the degradation of water 

quality resulting from operational discharges; noise generated by seismic exploration, helicopter and 

vessel traffic, platforms and drillships; vessel collisions; and marine debris generated by service vessels 

and OCS facilities. Lethal effects are most likely to be from chance collisions with OCS service vessels 

and ingestion of plastic materials. Most OCS activities are expected to have sublethal effects (e.g., 

behavioral effects and nonfatal exposure to intake of OCS-related contaminants or debris). 

Contaminants in waste discharges and drilling muds might indirectly affect sea turtles through foodchain biomagnification, but there is uncertainty concerning the possible effects. Rapid dilution of the 

discharges should minimize impact. Chronic sublethal effects (e.g., stress) resulting in persistent 

physiological or behavioral changes and/or avoidance of impacted areas from noise disturbance could 

cause declines in survival or fecundity and result in population declines; however, such declines are not 

expected. The required seismic operation mitigations, particularly clearance of the impact area of sea 

turtles prior to ramp-up, and the subsequent gradual ramping up of the airguns, should minimize the 

impact of rapid onset of, and close proximity to, very loud noise. Vessel traffic is a serious threat to sea 

turtles. Diligence on the part of vessel operators, as encouraged by the vessel strike mitigations, should 

minimize vessel/sea turtle collisions. Actual sea turtle impacts from explosive removals in recent years 

have been small. The updated pre- and post-detonation mitigations should ensure that injuries remain 

extremely rare. Greatly improved handling of waste and trash by industry, along with the annual 

awareness training required by the marine debris mitigations, is decreasing the plastics in the ocean and 

minimizing the devastating effects on sea turtles. The routine activities of proposed Lease Sale 213 are 

unlikely to have significant adverse effects on the size and recovery of any sea turtle species or population 

in the GOM. 

Accidental blowouts, oil spills, and spill-response activities resulting from proposed Lease Sale 213 

have the potential to impact small to large numbers of sea turtles in the GOM, depending on the 

magnitude and frequency of accidents, the ability to respond to accidents, the location and date of 

accidents, and various meteorological and hydrological factors. Chronic or acute exposure may result in 

the harassment, harm, or mortality to sea turtles occurring in the northern Gulf., However, exposure to 
Environmental Assessment 41 

hydrocarbons persisting in the sea following the dispersal of an oil slick are expected to most often result 

in sublethal impacts (e.g., decreased health, reproductive fitness, increased vulnerability to disease) to sea 

turtles. Sea turtle hatchling exposure to, fouling by, or consumption of tarballs persisting in the sea 

following the dispersal of an oil slick would likely be fatal. 

The majority of impacts from OCS activities are estimated to be sublethal. Chronic sublethal effects 

(e.g., stress) resulting in persistent physiological or behavioral changes and/or avoidance of impacted 

areas could cause declines in survival or productivity, resulting in either acute or gradual population 

declines. However, mitigations currently in place have, and will continue to, minimize sea turtle impacts. 

Natural phenomenon, such as tropical storms and hurricanes, are impossible to predict, but they will 

occur in the GOM. Generally, the offshore species and the offshore habitat are not expected to be 

severely affected in the long-term. However, species that occupy more nearshore habitats and those that 

use nearshore habitats (sea turtle nesting) may suffer more long-term impacts. Several major hurricanes 

have hit the Gulf Coast in the last several years. Storm impacts, including the loss of nesting habitat, 

increased marine debris, and spilled pollutants, can be detrimental to sea turtles. Impacts from the storms 

to nesting activity can be hard to assess. Hurricane Katrina in 2005 decimated the northern Gulf Coast, 

including the Chandeleur Islands off of Louisiana/Mississippi. This barrier island chain was an important 

loggerhead nesting site (Lohoefener et al., 1990). Very little area remains above sea level that would be 

suitable for nesting, and subsequent storms have delayed any rebuilding of the Chandeleur Islands. 

Hurricanes Ike and Gustav in 2008 also occurred in areas used by sea turtles for nesting. Hurricane Ike 

hit the northern Texas coast where Kemp’s ridley sea turtles have begun nesting in recent years after 

decades of nest and hatchling relocation from beaches in Mexico. The massive amount of storm debris 

from Hurricane Ike littered beaches well into south Texas, including the Padre Island, which is a very 

important Kemp’s ridley nesting habitat. Both the washing away of sand beaches and the proliferation of 

debris on nesting beaches can pose major barriers to successful nesting. Although the beach cleanup in 

Texas will be a long process, the start of the 2009 nesting season showed that the turtles were returning 

and attempting to nest despite last year’s destruction; 48 nests were counted as of May 3, 2009 (Sea 

Turtle Restoration Project, 2009). The late August/September timeframe of most of the recent Gulf of 

Mexico storms was toward the end of the sea turtle nesting season (generally April/May to October); 

therefore, many nests had successfully hatched prior to storm damage (Florida Fish and Wildlife 

Commission, 2008). 

In response to a request by the Gulf of Mexico Fishery Management Council, NMFS has issued an 

emergency closure for the bottom longline fishery in the eastern Gulf from May 18 through October 28, 

2009 (Federal Register, 2009). This action was promulgated by recent observer data analysis that 

showed the number of sea turtle takes authorized in the 2005 BO had been substantially exceeded. The 

affected fishery operates primarily off the west Florida shelf, which is an important sea turtle foraging 

habitat. A decline in the number of reproducing female loggerheads has been suggested as one of the 

reasons for recent declines in the annual loggerhead sea turtle nest counts in peninsular Florida. The 

bottom longline fishery takes sea turtles, including adult females, incidentally as bycatch. Further 

restrictions and/or mitigations may be required after the expiration of this closure. Although the area of 

greatest impact from this commercial fishing activity is not in the CPA, such impacts to the loggerhead 

sea turtle population must be considered with the cumulative impacts. Concern over the declining 

numbers of loggerhead sea turtles is reflected in NMFS’s second revision of the “Recovery Plan for the 

Northwest Atlantic Population of the Loggerhead Sea Turtle (Caretta caretta),” which replaced the 

previous 1991 report (USDOC, NMFS and USDOI, FWS, 2008). 

The incremental contribution of proposed Lease Sale 213 to the numerous cumulative impacts to sea 

turtles is not expected to be significant, especially due to mitigations currently in place. Most of the 

potential impacts from Lease Sale 213 are expected to be sublethal. 

The ESA (16 U.S.C. 1631 et seq.), as amended (43 U.S.C. 1331 et seq.), establishes a national policy 

designed to protect and conserve threatened and endangered species and the ecosystems upon which they 

depend. The ESA is administered by FWS and NMFS. Section 7 of the ESA governs interagency 

cooperation and consultation. Under Section 7, MMS consults with FWS and NMFS to ensure that OCS 

activities under MMS jurisdiction do not jeopardize the continued existence of threatened or endangered 

species and/or result in adverse modification or destruction of their critical habitat. 

The formal consultation with NMFS was concluded with the BO dated June 29, 2007, and received 

by MMS on July 3, 2007 (USDOC, NMFS, 2007a). The BO concludes that the proposed lease sales and 

associated activities in the GOM in the 2007-2012 OCS Leasing Program, which includes Lease Sale 213, 
42 Impact Analysis

are not likely to jeopardize the continued existence of threatened and endangered species under NMFS 

jurisdiction, or destroy or adversely modify designated critical habitat. The NMFS issued an Incidental 

Take Statement on sea turtle species; the Statement contains reasonable and prudent measures (RPM’s) 

with implementing terms and conditions to help minimize take. 

The NMFS has determined that the following RPM’s are necessary and appropriate to minimize 

impacts of the incidental take of sea turtles from vessel operation. 

(1) The MMS must reduce the potential for sea turtles to be struck and injured by vessels 

operating in support of oil and gas development activities in the GOM. 

(2) The MMS must require the monitoring and reporting of any sea turtles struck or 

observed to have sign of vessel interaction to assess the actual level of incidental take 

in comparison with the anticipated incidental take. 

In order to be exempt from liability for take prohibited by Section 9 of the ESA, MMS must comply 

with the following terms and conditions, which implement the RPM’s described above. These terms and 

conditions are nondiscretionary. 

The following terms and conditions implement RPM No. 1. 

(1) The MMS must implement NMFS measures to reduce the risk of accidental vessel 

strikes with sea turtles by use of its legal authorities to ensure implementation of, and 

compliance with NTL No 2007-G04. 

The following terms and conditions implement RPM No. 2. 

(1) The MMS must make information available to vessel operators concerning species 

information on sea turtles in the GOM and reporting of vessel-struck, or injured and 

dead animals. 

(2) The MMS must ensure that all vessel-struck, or injured or dead turtles with 

indications of vessel interactions are reported to the Sea Turtle Stranding Network 

Coordinator in the nearest coastal state. Any takes of listed species shall be reported 

to the NMFS Southeast Regional Office within no more than 24 hours of the incident 

to takereport.nmfsser@noaa.gov. If an MMS action is responsible for the injured or 

dead animals (e.g., because of a vessel strike), MMS shall require the responsible 

parties to assist the respective salvage and stranding network as appropriate. Report 

dead or injured protected species to your local stranding network contacts. 

(3) The MMS must submit an annual report to NMFS Southeast Regional Office 

regarding the reports of vessel-struck sea turtles, and injured and dead sea turtles 

reported from oil and gas operators. Hardcopies of all annual reports will be 

submitted to the following address: 

Assistant Regional Administrator for Protected Resources 

National Marine Fisheries Service 

263 13th Avenue South 

St. Petersburg, FL 33701

The NMFS expects impacts to sea turtles in the proposed lease sale area as a result of OCS oil and 

gas leasing activities. Based on stranding records, incidental captures during recreational and commercial 

fishing operations, scientific surveys, and historical data, the five species of sea turtles are known to occur 

in GOM waters in and around the proposed lease sale area. The vessel strike avoidance requirements 

(NTL 2003-G10) will appreciably reduce the numbers of sea turtles that may be incidentally taken from 

routine offshore vessel operations associated with proposed Lease Sale 213; however, the available 

information on the relationship between these species and OCS oil and gas activities indicates that sea 

turtles may be killed or injured by vessel strikes as a result of proposed Lease Sale 213. Therefore, 

pursuant to Section 7(b)(4) of the ESA, NMFS anticipates incidental take as follows: 
Environmental Assessment 43 

• 119 lethal takes (2.9 individuals annually, on average) and 238 nonlethal takes (5.9 

individuals annually, on average) of loggerhead sea turtles over the 40-year lifetime 

of proposed Lease Sale 213. 

• 10 lethal takes (1 individual every 4 years, on average) and 21 nonlethal takes (1 

individual every 1.9 years, on average) of leatherback sea turtles over the 40-year 

lifetime of proposed Lease Sale 213. 

• 13 lethal takes (1 individual every 3 years, on average) and 26 nonlethal takes (1 

individual every 1.5 years, on average) of Kemp’s ridley sea turtles over the 40-year 

lifetime of proposed Lease Sale 213. 

• 38 lethal takes (1 individual every 1.1 years, on average) and 76 nonlethal takes (1.9 

individuals annually, on average) of green sea turtles over the 40-year lifetime of 

proposed Lease Sale 213. 

• 1 lethal take and 1 nonlethal take of a hawksbill sea turtle over the 40-year lifetime of 

proposed Lease Sale 213. 

If the actual incidental take exceeds this level, MMS must immediately reinitiate formal consultation. 

The NMFS believes that a small number of listed species will experience adverse effects as the result 

of exposure to a large oil spill or ingestion of accidentally spilled oil over the lifetime of proposed Lease 

Sale 213. Spilled oil resulting from proposed Lease Sale 213 could take up to 42 lethal and 111 nonlethal 

takes of loggerheads; 2 lethal and 7 nonlethal takes of a leatherback sea turtles; 9 lethal and 16 nonlethal 

takes of Kemp’s ridley sea turtles; and 13 lethal and 36 nonlethal take of green sea turtles over the 40-

year lifetime of the proposed lease sale. However, NMFS is not including an Incidental Take Statement 

for the incidental take of listed species due to oil exposure. Incidental take, as defined at 50 CFR 402.02, 

refers only to takings that result from an otherwise lawful activity. The Clean Water Act (33 U.S.C. 1251 

et seq.), as amended by Oil Pollution Act of 1990 (33 U.S.C. 2701 et seq.), prohibits discharges of 

harmful quantities of oil, as defined at 40 CFR 110.3, into waters of the United States. Therefore, even 

though the BO considered the effects on listed species by oil spills that may result from proposed Lease 

Sale 213, those takings that would result from an unlawful activity (i.e., oil spills) are not specified in the 

Incidental Take Statement and have no protective coverage under Section 7(o)(2) of the ESA. 

The FWS and MMS have consulted informally per FWS guidance on proposed Lease Sale 213. As a 

result, there were no new mitigations or Terms and Conditions from FWS (Chapter 5.2). 

The MMS has reexamined the analysis for sea turtles presented in the Multisale EIS and the 

Supplemental EIS, based on the additional information presented above. No new significant information 

was discovered that would alter the impacts for sea turtles presented in the two documents; therefore, a 

new analysis of the potential impacts of proposed Lease Sale 213 on sea turtles is not required. The 

analysis and potential impacts detailed in the Multisale EIS and the Supplemental EIS still apply for 

proposed Lease Sale 213. 

4.2.7. Alabama, Choctawhatchee, St. Andrew, and Perdido Key Beach Mice 

The description of the biology, life history, and distribution of the Alabama, Choctawhatchee, St. 

Andrew and Perdido Key beach mice can be found in Chapter 3.2.5 of the Multisale EIS. A detailed 

impact analysis of the routine, accidental, and cumulative impacts of proposed Lease Sale 213 on beach 

mice can be found in Chapters 4.2.2.1.7, 4.4.7, and 4.5.7 of the Multisale EIS, respectively. The 

following information is a summary of the impact analysis incorporated from the Multisale EIS. Because 

of the extended distance from shore (more than 100 mi; 161 km), impacts associated with activities 

occurring in the new areas are not expected to impact beach mice. 

Impacts resulting from routine activities in the CPA on the Alabama, Choctawhatchee, St. Andrew, 

and Perdido Key beach mice are possible but unlikely. Impacts may result from the consumption of 

beach trash and debris. Proposed Lease Sale 213 would deposit only a small portion of the total debris 

that would reach the habitat. Efforts undertaken for the removal of marine debris may temporarily scare 

away beach mice, destroy their food resources, or collapse the tops of their burrows. 
44 Impact Analysis

Given the low probability of a large spill (≥1,000 bbl) occurring, direct impacts of oil spills on beach 

mice from proposed Lease Sale 213 are highly unlikely. Oil-spill response and cleanup activities could 

have a significant impact to the beach mice and their habitat if not properly regulated. 

Cumulative activities have a potential to harm or reduce the numbers of Alabama, Choctawhatchee, 

St. Andrew, and Perdido Key beach mice. Those activities include oil spills, alteration and reduction of 

habitat, predation and competition, and consumption of beach trash and debris. Most Multisale EISrelated spills, as well as oil spills stemming from import tankering and prior and future lease sales, are not 

expected to contact beach mice or their habitats. Cumulative activities posing the greatest potential harm 

to beach mice are non-OCS activities (i.e., beach development and coastal spills) and natural catastrophes 

(i.e., hurricanes) which, in combination, could potentially deplete some beach mice populations to 

unsustainable levels. The expected incremental contribution of proposed Lease Sale 213 to the 

cumulative impacts is negligible. 

Leblanc (personal communication, 2007) revealed that a population genetics study on the Alabama 

beach mouse was published in 2007 (Tenaglia et al., 2007). Adult males were often trapped with adult 

females, which were probably their mates in this monogamous species. These pairs were more distantly 

related than expected, probably because kin recognition allowed the selection of unrelated mates to avoid 

inbreeding depression, which reduced the fitness of a population as a result of the breeding of related 

individuals. As population levels have declined, inbreeding avoidance has become important to this 

subspecies. Subadults were often captured with related mice, suggesting that mice form sibling and adultsubadult familial bonds before final adult dispersal, which itself is a short distance. Consequences for 

inbreeding impacts remain to be investigated. 

The FWS designated 6,194 ac (2,507 hectares (ha)) of critical habitat for the Perdido Key, 

Choctawhatchee, and St. Andrew beach mice on October 12, 2006 (71 FR 60237-60370). The habitat 

includes 1,300 ac (526 ha) for the Perdido Key beach mouse in Escambia County, Florida, and Baldwin 

County, Alabama; 2,404 ac (973 ha) for the Choctawhatchee beach mouse in Okaloosa, Walton, and Bay 

Counties, Florida; and 2,490 ac (1,008 ha) for the St. Andrew beach mouse in Bay and Gulf Counties, 

Florida. On January 30, 2007, FWS designated 1,211 ac (490 ha) of coastal dune and scrub habitat in 

Baldwin County, Alabama, for the Alabama beach mouse (72 FR 4329-4369). 

A search was conducted for new information published since completion of the Multisale EIS and the 

Supplemental EIS. A search of Internet bibliographic databases, as well as personal interviews with 

subject-matter experts in other agencies, was conducted to determine the availability of recent 

information. Mitchell (personal communication, 2009) reported that there were no new articles on beach 

mice in Florida and that the Perdido beach mice are still slowly recovering after Hurricane Ivan. 

The MMS has reexamined the analysis for the Alabama, Choctawhatchee, St. Andrew, and Perdido 

Key beach mice presented in the Multisale EIS and the Supplemental EIS, based on the additional 

information presented above. No new significant information was discovered that would alter the impacts 

for the Alabama, Choctawhatchee, St. Andrew, and Perdido Key beach mice presented in the two 

documents; therefore, a new analysis of the potential impacts of proposed Lease Sale 213 on the 

Alabama, Choctawhatchee, St. Andrew, and Perdido Key beach mice is not required. The analysis and 

potential impacts detailed in the Multisale EIS and the Supplemental EIS still apply for proposed Lease 

Sale 213. 

4.2.8. Coastal and Marine Birds 

The description of the biology, life history, and distribution of coastal and marine birds in the Gulf of 

Mexico can be found in Chapter 3.2.5 of the Multisale EIS. A detailed impact analysis of the routine, 

accidental, and cumulative impacts of proposed Lease Sale 213 on coastal and marine birds can be found 

in Chapters 4.2.2.1.8, 4.4.8, and 4.5.8 of the Multisale EIS, respectively. The following information is a 

summary of the impact analysis incorporated from the Multisale EIS. Because of the extended distance 

from shore (more than 100 mi; 161 km), impacts associated with activities occurring in the new areas are 

expected to affect only pelagic seabirds and trans-Gulf of Mexico migrants. 

The majority of effects resulting from proposed Lease Sale 213 on endangered/threatened and 

nonendangered/nonthreatened coastal and marine birds are expected to be sublethal: behavioral effects, 

sublethal exposure to or intake of OCS-related contaminants or debris, temporary disturbances, and 

displacement of localized groups from impacted habitats. Chronic sublethal stress, however, is often 

undetectable in birds. As a result of stress, individuals may weaken, facilitating infection and disease; 
Environmental Assessment 45 

then, migratory species may not have the strength to reach their destination. Nocturnal circulation around 

platforms may create acute sublethal stress from energy loss and increase the risks of collision, while 

stopovers on platforms would reduce energy loss. No significant habitat impacts are expected to occur 

directly from routine activities resulting from proposed Lease Sale 213. Secondary impacts to coastal 

habitats from pipeline and navigation canals will occur over the long-term and may ultimately displace 

species from traditional sites to alternative sites. 

Oil spills from proposed Lease Sale 213 pose the greatest potential direct and indirect impacts to 

coastal and marine birds. Birds that are heavily oiled are usually killed. If the physical oiling of 

individuals or local groups of birds occurs, some degree of both acute and chronic physiological stress 

associated with the direct and secondary uptake of oil would be expected. Small coastal spills, pipeline 

spills, and spills from accidents in navigated waterways can contact and affect the different groups of 

coastal and marine birds, most commonly marsh birds, waders, waterfowl, and certain shorebirds. 

Lightly oiled birds can sustain tissue and organ damage from oil ingested during feeding and grooming or 

from oil that is inhaled. Stress, trauma, and shock enhance the effects of exposure and poisoning. Low 

levels of oil could stress birds by interfering with food detection, feeding impulses, predator avoidance, 

territory definition, navigation by migratory species, susceptibility to physiological disorders, disease 

resistance, growth rates, reproduction, and respiration. Reproductive success can be affected by the 

toxins in oil. Indirect effects occur by the fouling of nesting habitat and the displacement of individuals, 

breeding pairs, or populations to less favorable habitats. Competition may displace refugee seabirds from 

all habitats. 

New research, experience, and testing will help the efficacy of the rehabilitation of oiled birds and 

probably improve scare methods that will keep birds away from an oil slick. Rehabilitation can be critical 

to the survival of threatened and endangered bird species. 

Dispersants used in spill cleanup activity can have toxic effects similar to oil on the reproductive 

success of coastal and marine birds. The air, vehicle, and foot traffic that takes place during shoreline 

cleanup activity can disturb nesting populations and degrade or destroy habitat if not properly regulated. 

Activities considered under the cumulative activities scenario will detrimentally affect coastal and 

marine birds. It is expected that the majority of effects from the major impact-producing factors on 

coastal and marine birds are sublethal (behavioral effects and nonfatal exposure to or intake of OCSrelated contaminants or debris) and will usually cause temporary disturbances and displacement of 

localized groups inshore. The net effect of habitat loss from oil spills, new construction, and maintenance 

and use of pipeline corridors and navigation waterways will alter species composition and reduce the 

overall carrying capacity of disturbed area(s) in general. 

The incremental contribution of proposed Lease Sale 213 (Chapters 4.2.1.1.8, 4.2.2.1.1.10, and 4.4.10 

of the Multisale EIS) to the cumulative impacts on coastal and marine birds is negligible because the 

effects of the most probable impacts, such as sale-related operational discharges and helicopters and 

service-vessel noise and traffic, are estimated to be sublethal, and some displacement of local individuals 

or groups may occur. It is expected that there will be little interaction between oil spills from proposed 

Lease Sale 213 and coastal and marine birds. 

The cumulative effect of programmatic activities on coastal and marine birds is expected to result in a 

small but discernible decline in the numbers of birds, with associated change in species composition and 

distribution. Some of these changes are expected to be permanent, as exemplified in historic census data, 

and to stem from a net decrease in preferred and/or critical habitat. 

On June 28, 2007, FWS announced (effective July 9, 2007; 72 FR 37345-37372) the removal of the 

bald eagle from the list of threatened and endangered species (USDOI, FWS, 2007a). The FWS will 

work with State wildlife agencies to monitor eagles for at least 5 years. The FWS can propose to relist 

the species if it appears that bald eagles again need the protection of the Endangered Species Act. The 

bald eagle will continue to be protected by the Bald and Golden Eagle Protection Act and the Migratory 

Bird Treaty Act. Both Federal laws prohibit “taking”—killing, selling, or otherwise harming eagles, their 

nests, or eggs. 

Authors were contacted and interviewed to investigate any recent published data that may be 

available. A large study of military aircraft and the impacts of noise on birds offshore of California is in 

preparation (Bowles, personal communication, 2009). Nisbet (personal communication, 2009) knows of 

no new information on the impacts of human disturbance on breeding colonial waterbirds and any 

relevant published literature. 
46 Impact Analysis

A literature search found Burger (1997), who reports that exposure to small amounts of oil may 

weaken birds or decrease their body weight so they live for years without problems until they face a 

severe environmental stress. Then, they have a higher mortality than unexposed birds. Burger (1993) 

notes that spill volume has little or no correlation with bird mortality. The density of seabirds in the 

affected area, wind conditions, wave action, and distance to the shore may have more effect. Khan and 

Ryan (1991) note substantial mortality in seabirds after attempts at rehabilitation. Sublethal symptoms of 

contamination were numerous and substantial prior to the mortality. Similarly, numerous symptoms were 

found in dead birds on the shore and in birds dying after rehabilitation that were affected by the Prestige

oil spill in Spain on November 19, 2002 (Balseiro et al., 2005). Final major impacts to European shags 

(Phalacrocorax aristotelis) from the Prestige spill probably came in 2003 from a decimated food supply 

of fish (Velando et al., 2005). As oil weathered, the exposure of seabirds to oil from the Exxon Valdez

spill shifted from direct oiling to ingestion with food (Hartung, 1995). 

Parsons (1994) provides the following unique before and after data for impacts of a spill on birds. 

Extensive shoreline and salt marsh were oiled by a January 1990 Exxon spill in the Arthur Kill and Kill 

van Kull estuaries of New York Harbor. Double-crested cormorants had reached their pre-spill 

population growth by 1991. Productivity of herring gulls remained unchanged by the spill. Most heron 

populations increased after the spill. Great black-backed gulls had a loss of abundance. Snowy egrets 

and glossy ibis used salt marsh and mud flat habitat, some of which was oiled. Black-crowned night 

heron and glossy ibis had delayed nesting after the spill, and along with snowy egret showed lower 

reproductive success after the spill. Egg laying and hatching were generally more successful than chickrearing, due to shortage of food fed to chicks. Waterfowl were not affected seriously, except for a shortterm decline in mallards. 

The piping plover (Charadrius melodus), is listed as threatened under the Endangered Species Act on 

the Gulf coast of Texas, Louisiana, Mississippi, Alabama, and Florida (Smith, personal communication, 

2009). The species, is a migratory shorebird that is endemic to North America. It winters on the Atlantic 

and Gulf Coasts from North Carolina to Mexico and in the Bahamas West Indies but does not winter on 

the Gulf Coast. Critical wintering habitat includes the land between mean low water and any densely 

vegetated habitat, which is not used by the piping plover. It has been hypothesized that specific wintering 

habitat, which includes coastal sand flats and mud flats in close proximity to large inlets or passes, may 

attract the largest concentrations of piping plovers because of a preferred prey base and/or because the 

substrate coloration provides protection from aerial predators due to chromatic matching, or camouflage 

(Nicholls and Baldassarre, 1990). This species remains in a precarious state given its low population 

numbers, sparse distribution, and continued threats to habitat throughout its range. Eliott-Smith et al. 

(2009) reported that about 3,274 piping plover were located during the 2006 International Census. This 

increase of 975 birds from the 2001 International Census (Haig and Ferland, 2002) results in a slight but 

not significant reduction in expected impacts on the piping plover. 

A search was conducted for new information published since completion of the Multisale EIS. A 

search of Internet bibliographic databases, as well as personal interviews with subject-matter experts in 

other agencies, was conducted to determine the availability of recent information. Nisbet (personal 

communication, 2009) knows of no new information on the impacts of human disturbance on breeding 

colonial waterbirds and any relevant published literature. 

The MMS has reexamined the analysis for coastal and marine birds presented in the Multisale EIS 

and the Supplemental EIS based on the additional information presented above. No significant new 

information was found that would alter the impacts for coastal or marine birds presented in the two 

documents. For coastal and marine birds, a new analysis of the potential impacts of proposed Lease Sale 

213 on coastal and marine birds is not required. The analysis and potential impacts detailed in the 

Multisale EIS and the Supplemental EIS still apply for proposed Lease Sale 213. 

4.2.9. Endangered and Threatened Fish 

4.2.9.1. Gulf Sturgeon 

The description of the biology, life history, and distribution of Gulf sturgeon can be found in Chapter 

3.2.7.1 of the Multisale EIS. A detailed impact analysis of the routine, accidental, and cumulative 

impacts of proposed Lease Sale 213 on Gulf sturgeon can be found in Chapters 4.2.2.1.9.1, 4.4.9.1, and 

4.5.9.1 of the Multisale EIS, respectively. The following information is a summary of the impact analysis 
Environmental Assessment 47 

incorporated from the Multisale EIS. The new areas are located more than 100 mi (161 km) from the 

nearest coast and are not located within the designated critical habitat for Gulf sturgeon. It is extremely 

unlikely that there will be any sturgeon in the new areas due to water depths that far exceed the recorded 

depths preferred by this sturgeon species. In addition, substrate type and the potential forage base 

associated with bottom types at these depths are not conducive for sustaining a Gulf sturgeon food base. 

The NOAA Fisheries Service and FWS listed the Gulf sturgeon as a threatened species on 

September 30, 1991. Critical habitat was proposed on June 6, 2002, in the Federal Register and was 

designated on April 18, 2003. 

Potential impacts on Gulf sturgeon and the designated critical habitat may occur from drilling and 

produced-water discharges, degradation of estuarine and marine water quality by nonpoint runoff from 

estuarine OCS-related facilities, vessel traffic, explosive removal of structures, and pipeline installation. 

The dilution and low toxicity of this pollution is expected to result in a negligible impact on Gulf sturgeon 

as a result of proposed Lease Sale 213. Vessel traffic will generally only pose a risk to Gulf sturgeon 

when leaving and returning to port. Major navigation channels are excluded from critical habitat. The 

Gulf sturgeon’s characteristics of bottom-feeding and general avoidance of disturbance make the 

probability of vessel strike extremely remote. Explosive removal of structures as a result of proposed 

Lease Sale 213 will occur well offshore of Gulf sturgeon critical habitat and the riverine, estuarine, and 

shallow Gulf habitats where sturgeon are generally located. Environmental permit requirements and 

recent techniques for locating pipelines will result in a very minimal impact to Gulf sturgeon critical 

habitat if any pipeline is installed nearshore due to proposed Lease Sale 213. Impacts from routine 

activities resulting from proposed Lease Sale 213 are expected to have negligible effects on Gulf sturgeon 

and their designated critical habitat. 

The Gulf sturgeon could be impacted by oil spills resulting from proposed Lease Sale 213. Contact 

with spilled oil could have detrimental physiological effects. The juvenile and subadult Gulf sturgeon, at 

a minimum, seasonally use the nearshore coastal waters and could potentially be at risk from both coastal 

and offshore spills. However, several factors influence the probability of spilled oil contact with Gulf 

sturgeon or their critical habitat. The likelihood of spill occurrence and subsequent contact with, or 

impact to, Gulf sturgeon and/or designated critical habitat is extremely low. 

The Gulf sturgeon and its critical habitat can be cumulatively impacted by activities such as oil spills, 

alteration and destruction of habitat, and commercial fishing. The effects from contact with spilled oil 

will be sublethal and last for less than one month. Substantial damage to Gulf sturgeon critical habitat is 

expected from inshore alteration activities and natural catastrophes. As a result, it is expected that the 

Gulf sturgeon will experience a decline in population sizes and a displacement from their current 

distribution that will last more than one generation. Deaths of adult sturgeon are expected to occur from 

commercial fishing. The incremental contribution of proposed Lease Sale 213 to the cumulative impact is 

negligible because the effect of contact between sale-specific oil spills and Gulf sturgeon is expected to be 

sublethal and last less than one month. 

A search was conducted for new information published since completion of the Multisale EIS and the 

Supplemental EIS. A search of Internet information sources, as well as interviews with personnel from 

State and Federal resource agencies, was conducted to determine the availability of recent information. 

Various Internet sources were examined to determine any recent information regarding Gulf sturgeon 

(Florida Fish and Wildlife Commission, 2007; USDOI, FWS, 2007b). No new information was 

discovered from these information sources. 

State and Federal resource agencies were contacted and interviews conducted to investigate any 

recent published or unpublished data that may be available. Current information indicates that there may 

have been some displacement of sturgeon or possibly damage to their habitat in localized areas where the 

storm forces were strongest. The current sampling programs along the Gulf Coast indicate (at least 

anecdotally) that sturgeon are returning to the areas they occupied prior to Hurricane Katrina, which may 

indicate somewhat of a recovery of those areas (Paruka, personal communication, 2007). No changes in 

migratory patterns or blockages of migratory pathways have been noted. In general, the researchers noted 

that the sturgeon are normally found approximately 0.5 mi (0.8 km) from shore between the shoreline and 

the barrier islands, with the bulk of the fish located in the CPA between Petit Bois, Dauphin, and 

Chandeleur Islands and from Perdido to Panama City as far as Fort Walton Beach (Slack, personal 

communication, 2007; Paruka, personal communication, 2007). 

At present, NOAA indicates no changes in critical habitat have occurred, and they are working to 

develop an estimate of sturgeon habitat loss and a habitat suitability index for the species (Bolden, 
48 Impact Analysis

personal communication, 2007). They also have no data indicating that sturgeons are utilizing the deeper 

Gulf waters. In general, the mud substrates found in the Gulf waters do not support the appropriate 

benthic food source for Gulf sturgeon. Gulf sturgeon population studies that recently analyzed data from 

coastal rivers along the Alabama and west Florida (especially Choctawhatchee) coasts indicate that 

sturgeon populations have recovered to pre-hurricane conditions (Paruka, personal communication, 

2008). It was noted that Hurricanes Gustav and Ike did initially displace some of the Gulf sturgeon in the 

Mississippi-Louisiana area much like what happened in Florida during Hurricane Katrina. Current 

surveys along the Mississippi coast indicate no permanent impact to critical habitat, and Paruka 

acknowledged that the sturgeons have returned to their normal feeding and resting areas along the coastal 

rivers. Sampling is not yet complete to see if the population has had any change in composition or if 

spawning has occurred (Slack, personal communication, 2008). 

The MMS has consulted with NMFS for the proposed CPA and WPA lease sales in the 2007-2012 

OCS Leasing Program, including Lease Sale 213. The NMFS BO, signed on June 29, 2007, concludes 

that the proposed lease sales, including Lease Sale 213, and the associated activities are not likely to 

jeopardize the continued existence of threatened and endangered species under NMFS jurisdiction or 

destroy or adversely modify designated critical habitat. 

The MMS has reexamined the analysis for the Gulf sturgeon presented in the Multisale EIS and the 

Supplemental EIS, based on the additional information presented above. No new significant information 

was discovered that would alter the impacts for Gulf sturgeon presented in the two documents; therefore, 

a new analysis of the potential impacts of proposed Lease Sale 213 on Gulf sturgeon is not required. The 

analysis and potential impacts detailed in the Multisale EIS and the Supplemental EIS still apply for 

proposed Lease Sale 213. 

4.2.10. Fish Resources and Essential Fish Habitat 

The description of the biology, life history, and distribution of fish resources and descriptions of 

essential fish habitat (EFH), as designated under the authority of the Magnuson-Stevens Fishery 

Conservation and Management Act, can be found in Chapters 3.2.8.1 and 3.2.8.2 of the Multisale EIS, 

respectively. A detailed impact analysis of the routine, accidental, and cumulative impacts of proposed 

Lease Sale 213 on fish resources and EFH can be found in Chapters 4.2.2.1.10, 4.4.10, and 4.5.10 of the 

Multisale EIS, respectively. The following information is a summary of the impact analysis incorporated 

from the Multisale EIS. 

It is expected that coastal and marine environmental degradation from proposed Lease Sale 213 

would have little effect on fish resources or EFH. The impact of coastal and marine environmental 

degradation is expected to cause an undetectable decrease in fish resources or in EFH. Fish resources and 

EFH losses as a result of coastal and marine environmental degradation are expected to be negligible. 

Fish populations, if left undisturbed, will regenerate quickly but any loss of wetlands as EFH would likely 

be permanent. 

Routine activities such as pipeline trenching and OCS discharge of drilling muds and produced water 

would cause negligible impacts and would not deleteriously affect fish resources or EFH. At the expected 

level of impact, the resultant influence on fish resources would not cause significant change in fish 

populations or EFH. As a result, there would be little disturbance to fish resources or EFH. 

Accidental events resulting from oil and gas development in the proposed Lease Sale 213 area of the 

GOM have the potential to cause some detrimental effects on fisheries and commercial fishing practices. 

A subsurface blowout would have a negligible effect on GOM fish resources. If spills due to proposed 

Lease Sale 213 were to occur in open waters of the OCS proximate to mobile adult finfish or shellfish, the 

effects would likely be nonfatal and the extent of damage would be reduced due to the capability of adult 

fish and shellfish to avoid a spill, to metabolize hydrocarbons, and to excrete both metabolites and parent 

compounds (recognizing that spill impacts are substantial when contacting fish eggs and larvae). The 

effect of proposed Lease Sale 213-related oil spills on fish resources is expected to cause less than a 1 

percent decrease in standing stocks of any population, landings, or value of those landings. Historically, 

there have been no oil spills of any size that have had a long-term impact on fishery populations. 

Additional hard substrate habitat provided by structure installation in areas where natural hard bottom 

is rare will tend to increase fish populations. Removal of these structures will eliminate that habitat 

except when decommissioning results in platforms being utilized as artificial reef material. This practice 

is expected to increase over time. 
Environmental Assessment 49 

Activities resulting from other OCS Program and non-OCS events in the northern GOM have the 

potential to cause detrimental effects on fish resources and EFH. Impact-producing factors of the 

cumulative scenario that are expected to substantially affect fish resources and EFH include coastal and 

marine environmental degradation, overfishing, and to a lesser degree, coastal petroleum spills and 

coastal pipeline trenching. At the estimated level of cumulative impact, from OCS Program and nonOCS events, the resultant influence on fish resources and EFH is expected to be substantial, but not easily 

distinguished from effects due to natural population variations. 

The incremental contribution of proposed Lease Sale 213’s impacts on fish resources and EFH to the 

cumulative impact is small. The effects of impact-producing factors (coastal and marine environmental 

degradation, petroleum spills, subsurface blowouts, pipeline trenching, and offshore discharges of drilling 

muds and produced waters) related to proposed Lease Sale 213 are expected to be negligible (resulting in 

less than a 1% decrease in fish populations or EFH) and almost undetectable among the other cumulative 

impacts. Even with consideration of an extreme year of major hurricane impacts to coastal wetlands in 

2005, the cumulative impact of proposed Lease Sale 213 is expected to be negligible and undetectable. 

At the expected level of impact, the resultant influence on fish populations and EFH from proposed 

Lease Sale 213 would be negligible and indistinguishable from variations due to natural causes; however, 

wetland loss could occur due to a petroleum spill contacting inland areas. Proposed Lease Sale 213 is 

expected to result in negligible decreases in fish resources and/or standing stocks or in EFH. Fish 

resources will quickly recover from most of the impacts. Recovery from the loss of wetlands habitat 

would probably not occur as quickly. 

A search was conducted for new information published since completion of the Multisale EIS. A 

search of Internet information sources (including scientific journals), as well as interviews with personnel 

from academic institutions and governmental resource agencies, was conducted to determine the 

availability of new information. Relevant informational Internet websites include those from the Gulf of 

Mexico Fisheries Management Council at http://www.gulfcouncil.org/ and the NMFS Southeast Region 

at http://sero.nmfs.noaa.gov/. Some recent reports from NOAA have further documented impacts from 

the 2005 hurricanes on fish and fishery habitat. One very recent example is Report to Congress on the 

Impact of Hurricanes Katrina, Rita, and Wilma on Commercial and Recreational Fishery Habitat of 

Alabama, Florida, Louisiana, Mississippi, and Texas, which was published in July 2007 (USDOC, 

NMFS, 2007b). This report confirms the substantial impacts of the 2005 hurricanes to nearshore habitats, 

especially oyster reefs. Offshore fisheries habitat sustained some impact, but as far as population census 

are able to discern, the impact was not substantial. The impacts of the 2008 hurricanes (i.e., Gustav and 

Ike) on the fisheries of the Gulf Coast are not yet available. Similar information (i.e., the effects of 

Hurricanes Katrina and Rita on GOM fisheries) was presented in the Multisale EIS. 

No new significant information was discovered that would alter the impacts for fish resources and 

EFH presented in the Multisale EIS and the Supplemental EIS; therefore, a new analysis of the potential 

impacts of proposed Lease Sale 213 on fish resources and EFH is not required. The analysis and potential 

impacts detailed in the Multisale EIS and the Supplemental EIS still apply for proposed Lease Sale 213. 

4.2.11. Commercial Fishing 

The description of commercial fishing in the proposed Lease Sale 213 area can be found in Chapter 

3.3.1 of the Multisale EIS. A detailed impact analysis of the routine, accidental, and cumulative impacts 

of proposed Lease Sale 213 on commercial fishing can be found in Chapters 4.2.2.1.11, 4.4.10, and 4.5.11 

of the Multisale EIS, respectively. The following information is a summary of the impact analysis 

incorporated from the Multisale EIS. 

The new areas are located more than 100 mi (161 km) from the nearest coast and are not projected to 

increase the overall activity that would result from proposed Lease Sale 213. There are no special 

regulations designated within these areas that would indicate any difference in the commercial fisheries 

than what is found in adjacent areas of the Gulf; therefore, no additional impacts on commercial fisheries 

are projected as a result of the inclusion of the new acreage. 

Effects on commercial fishing from activities associated with proposed Lease Sale 213 could result 

from the installation of production platforms, underwater OCS obstructions, production platform 

removals, seismic surveys, subsurface blowouts, pipeline trenching, and petroleum spills. Activities such 

as seismic surveys and pipeline trenching will cause negligible impacts and will not deleteriously affect 

commercial fishing activities. Seismic surveys are not expected to cause long-term or permanent 
50 Impact Analysis

displacement of any listed species from critical habitat/preferred habitat or to result in the destruction or 

adverse modification of critical habitat or essential fish habitat. Operations such as production platform 

emplacement, underwater OCS impediments, and explosive platform removal will cause slightly greater 

impacts on commercial fishing. 

Commercial fishermen would actively avoid the area of a spill. Even if fish resources successfully 

avoid spills, tainting (oily-tasting fish), public perception of tainting, or the potential of tainting 

commercial catches would prevent fishermen (either voluntarily or imposed by regulation) from initiating 

activities in the spill area. This, in turn, could decrease landings and/or the value of catch for several 

months. The effect of proposed Lease Sale 213-related oil spills on fish resources and commercial fishing 

is expected to cause less than a 1 percent decrease in standing stocks of any population, commercial 

fishing efforts, landings, or value of those landings. 

At the expected level of impact, the resultant influence on commercial fishing activities from 

proposed Lease Sale 213 would be negligible and indistinguishable from variations due to natural causes. 

As a result, there would be very little impact on commercial fishing. Proposed Lease Sale 213 is expected 

to result in negligible change in activities, in pounds landed, or in the value of landings. 

A search was conducted for new information published since completion of the Multisale EIS. A 

search of Internet information sources (including scientific journals) as well as interviews with personnel 

from academic institutions and governmental resource agencies was conducted to determine availability 

of new information. Some recent reports (USDOC, NMFS, 2007b and c) have further documented 

impacts from the 2005 hurricanes on fish and fishery habitat discussed above under “Fish Resources and 

Essential Fish Habitat” (Chapter 4.2.10). 

In August 2009, NMFS published a preliminary report for 2008 on U.S. commercial fisheries 

(USDOC, NMFS, 2009). Table 4 below shows the change in commercial landings from 2007 to 2008 for 

the Gulf of Mexico and the Gulf States. Despite Louisiana’s drop in number of landings following 

Hurricane Katrina, Louisiana still remains the leader in Gulf landings, followed by Mississippi, Texas, 

Florida (West Coast), and Alabama. Kirkham (2007) states “though the migration into other state waters 

is not new, the post-storm NOAA statistics suggest a new trend: Fishers are taking more seafood from 

Louisiana waters than what is brought in to Louisiana ports” and “whether the trends will continue is up 

for debate. According to a recent Wildlife and Fisheries report, fishers will be able to bring their catch 

back to pre-storm ports and buyers (Louisiana Dept. of Wildlife and Fisheries, 2007). 

Table 4 

 

U.S. Domestic Landings for the Gulf of Mexico and Gulf States, 2007 and 2008 

2007 

(thousand 

pounds) 

2008 

(thousand 

pounds) 

Change 

2007 

(thousand 

dollars) 

2008 

(thousand 

dollars) 

Change 

Florida, West Coast 59,015 59,402 +.7% 131,939 122,108 -7.5% 

Alabama 29,379 24,420 -17% 48,723 44,313 -9% 

Mississippi 227,834 201,822 -12% 39,340 43,697 +11% 

Louisiana 998,763 915,956 -8% 288,952 272,844 -5.6% 

Texas 84,940 73,048 -14% 174,356 176,098 +1% 

Source: USDOC, NMFS, 2009. 

A recent report by Caffey (2008) has estimated that commercial fisheries losses from Hurricanes 

Gustav and Ike will result in approximately $5.8 million, including losses from crawfish, catfish, all 

alligators, and turtles (inshore and farmed species), over the 2007 harvest value. The report estimates 

losses between $6.53 and $10.29 million, including oysters, shrimp, crabs, marine fisheries and charter 

fisheries. These hurricanes likely explain the losses in fisheries landings reflected in Table 4. 

Infrastructural losses estimated in the report, including seafood processors docks, dealers commercial 

and recreational vessels marines and aquaculture, could possibly represent between a $127- and 

$178-million dollar loss from 2007 revenues. 

The MMS has reexamined the analysis for commercial fishing presented in the Multisale EIS and the 

Supplemental EIS, based on the additional information presented above. Percent changes in the statistics 
Environmental Assessment 51 

included in Table 4 may reflect differences in population but they are also dependent upon the fishing 

effort as affected by hurricanes, particularly Gustav and Ike and weather conditions in general, as well as 

the cost per unit effort and the market value of catch. No new significant information was discovered that 

would alter the impacts for commercial fishing presented in the two documents; therefore, a new analysis 

of the potential impacts of proposed Lease Sale 213 on commercial fishing is not required. The analysis 

and potential impacts detailed in the Multisale EIS and the Supplemental EIS still apply for proposed 

Lease Sale 213. 

4.2.12. Recreational Fishing 

The description of the environment for recreational fishing is in Chapter 3.3.2 of the Multisale EIS. 

Detailed analysis of the routine, accidental, and cumulative impacts of proposed Lease Sale 213 on 

recreational fishing is in Chapters 4.2.2.1.12, 4.4.11, and 4.5.12 of the Multisale EIS, respectively. The 

following is a summary of the impact analysis from the Multisale EIS. Because of their distance from the 

nearest coast (more than 100 mi; 160 km), the inclusion of the new areas will have no direct routine 

impacts on recreational fishing. 

With respect to routine events, the development of oil and gas in the proposed lease sale area could 

attract additional recreational fishing activity to structures installed on productive leases. Each structure 

placed in the GOM to produce oil or gas would function as a de facto artificial reef, attract sport fish, and 

improve fishing prospects in the immediate vicinity of platforms. This impact would last for the life of 

the structure, i.e., until the structures are removed from the location and the marine environment. 

Proposed Lease Sale 213 would have a beneficial effect on offshore and deep-sea recreational fishing 

within developed leases accessible to fishermen. These effects would last until the production structures 

are removed from the marine environment. Short-term, space-use conflict could occur during the time 

that any pipeline is being installed. 

With respect to accidental events, the estimated number and size of potential spills associated with 

proposed Lease Sale 213’s activities (Chapter 4.3.1.2 of the Multisale EIS) are unlikely to decrease 

recreational fishing activity but may divert the location or timing of planned fishing trips. Potential 

impacts on recreational fisheries due to accidental events as a result of proposed Lease Sale 213 would be 

minor to moderate. Based on the sizes of oil spills assumed for proposed Lease Sale 213, only localized 

and short-term disruption of recreational fishing activity might result (minor impact). 

With respect to cumulative events, recreational fishing continues to be a popular nearshore and 

offshore recreational activity in the northeastern and central GOM. Concern for the sustainability of fish 

resources and marine recreational fishing has led to Federal legislation that established a fisheries 

management process that will include the identification and protection of EFH. The incremental 

contribution of proposed Lease Sale 213 (as analyzed in Chapter 4.2.2.1.12 in the Multisale EIS) to the 

cumulative impact on recreational fishing is positive, although minor due to the relatively small number 

of structures projected for the next 40 years. The cumulative impact of OCS and State oil and gas 

activities and import tanker spills would be minor. Implementation of proposed Lease Sale 213 would 

attract some private and charter-boat recreational fishermen farther offshore to the vicinity of the 

developed lease tracts in pursuit of targeted species known to be associated with petroleum structures in 

deep water. 

A search was conducted for new information published since completion of the Multisale EIS. 

Research of recreational fishing revealed the following new information. 

The NMFS has published the 2008 Marine Recreational Fisheries Statistics Survey (MRFSS) 

(USDOC, NMFS, 2008). In 2008, 5.7 million residents participated in marine recreational fishing. All 

participants, including visitors, took nearly 24 million trips and caught approximately 168 million fish. In 

2007, about 66 percent of the trips were made in west Florida, followed by 18 percent in Louisiana, 11 

percent in Alabama, and 5 percent in Mississippi. In 2008, about 70 percent of the trips were from West 

Florida followed by 19 percent from Louisiana, nearly 7 percent from Alabama, and 4 percent from 

Mississippi. The MRFSS is the primary source for marine recreational fisheries data in U.S. waters. This 

survey combines random telephone interviews and onsite intercept surveys of anglers to estimate 

recreational catch and effort for inland, State, and Federal waters. In the GOM, surveys are conducted in 

western Florida, Alabama, Mississippi, and Louisiana. 

Hurricanes Katrina and Rita impacted recreational fishing from the Florida Panhandle to the Texas 

border, with additional impacts felt in southern Florida. The hurricanes had a major impact on the 
52 Impact Analysis

supporting infrastructure that anglers require to go fishing (e.g., bait shops, docks and marinas, lodging, 

fuel and ice facilities, etc.). In addition to damages to boats and facilities, revenue losses associated with 

lost markets of products or services are occurring. When considered on a regional basis, these lost market 

channels constitute a considerable reduction in the levels of economic activity, income generation, 

employment creation, and tax collections. 

In addition, Hurricanes Katrina and Rita deposited extensive amounts of debris over various areas of 

the Gulf Coast (USDOC, NOAA, 2007b). Submerged marine debris poses a hazard to vessel traffic. The 

NOAA is conducting underwater surveys off the coasts of Louisiana, Mississippi, and Alabama. This 

information is being used by State and Federal agencies tasked with removing marine debris left by 

Hurricane Katrina, and it will aid in planning for the aftermath of future storms. Hurricanes Gustav and 

Ike affected the Louisiana and Texas coasts during 2008 and will certainly affect recreational fisheries 

and fishing infrastructure, but no definitive data are yet available on their impacts. 

Estimates of damage to the recreational fisheries are summarized above, but they are specifically 

represented as an initial approximation in the report (i.e., recreational vessels) as a $6.4- to $10.3-million 

loss from 2007 revenues, and infrastructural losses are approximated at nearly $11.9 million to 

approximately $14.5 million in revenues for recreational infrastructure (i.e., marinas, docks, etc). 

The MMS has reexamined the analysis for recreational fishing presented in the Multisale EIS and the 

Supplemental EIS, based on the additional information presented above. No new significant information 

was discovered that would alter the impacts for recreational fishing presented in the two documents; 

therefore, a new analysis of the potential impacts of proposed Lease Sale 213 on recreational fishing is 

not required. The analysis and potential impacts detailed in the Multisale EIS and the Supplemental EIS 

still apply for proposed Lease Sale 213. 

4.2.13. Recreational Resources 

The description of the environment for recreational resources can be found in Chapter 3.3.3 of the 

Multisale EIS and Chapter 4.1.14.1 of the Supplemental EIS. Detailed analysis of the routine, accidental, 

and cumulative impacts of proposed Lease Sale 213 on recreational resources can be found in Chapters 

4.2.2.1.13, 4.4.12, and 4.5.13 of the Multisale EIS and Chapters 4.1.14.2, 4.1.14.3, and 4.1.14.4 of the 

Supplemental EIS, respectively. The following is a summary of the impact analysis from the Multisale 

EIS and the Supplemental EIS. 

The new areas are located more than 100 mi (161 km) from the nearest coast and are not projected to 

increase the overall activity that would result from proposed Lease Sale 213; therefore, no additional 

impacts on recreation resources are projected as a result of the inclusion of the new acreage. 

The northern GOM coastal zone is one of the major recreational regions of the U.S., particularly in 

connection with marine fishing and beach-related activities. The coastal beaches, barrier islands, 

estuarine bays and sounds, river deltas, and tidal marshes are used extensively and intensively for 

recreational activity by residents of the Gulf South and tourists from throughout the Nation, as well as 

from foreign countries. Commercial and private recreational facilities and establishments (such as resorts 

and marinas) also serve as primary interest areas and support services for people who seek enjoyment 

from the recreational resources associated with the GOM. 

With respect to routine events, marine debris will be lost from time to time from operations resulting 

from proposed Lease Sale 213. The impact on Gulf Coast recreational beaches is expected to be minimal. 

The incremental increase in helicopter and vessel traffic is expected to add very little additional noise that 

may affect beach users. Proposed Lease Sale 213 is expected to result in nearshore operations that may 

adversely affect the enjoyment of some Gulf Coast beach uses; however, these will have little effect on 

the number of beach users. 

With respect to accidental events, it is unlikely that a spill would be a major threat to recreational 

beaches because any impacts would be short-term and localized. Should a spill contact a recreational 

beach, short-term displacement of recreational activity from the areas directly affected would occur. 

Beaches directly impacted would be expected to close for periods of 2-6 weeks or until the cleanup 

operations were complete. Should a spill result in a large volume of oil contacting a beach or a large 

recreational area being contacted by an oil slick, visitation to the area could be reduced by as much as 

5-15 percent for as long as one season, but such an event should have no long-term effect on tourism. 

Tarballs can lessen the enjoyment of the recreational beaches but should have no long-term effect on the 

overall use of beaches. 
Environmental Assessment 53 

With respect to cumulative events, debris and litter derived from both offshore and onshore sources 

are likely to diminish the tourist potential of beaches and to degrade the ambience of shoreline 

recreational activities, thereby affecting the enjoyment of recreational beaches throughout the area. The 

incremental beach trash resulting from proposed Lease Sale 213 is expected to be minimal. Platforms and 

drilling rigs operating nearshore may affect the ambience of recreational beaches, especially beach 

wilderness areas. The sound, sight, and wakes of OCS-related and non-OCS-related vessels, as well as 

OCS helicopters and other light aircraft traffic, are occasional distractions that are noticed by some beach 

users. Oil that contacts the coast may preclude short-term recreational use of one or more Gulf Coast 

beaches at the park or community levels. Displacement of recreational use from impacted areas will 

occur, and a short-term decline in tourism may result. Beach use at the regional level is unlikely to 

change from normal patterns; however, closure of specific beaches or parks directly impacted by a large 

oil spill is likely during cleanup operations. The incremental contribution of proposed Lease Sale 213 (as 

analyzed in Chapter 4.2.2.1.13 of the Multisale EIS and Chapter 4.1.14.4 of the Supplemental EIS) to the 

cumulative impact on recreational resources is minor due to the limited effect of increased helicopter, 

vessel traffic, and marine debris on the number of beach users. 

Recreation and tourism are major sources of employment along the Gulf Coast. Table 4-9 of the 

Supplemental EIS presents employment in tourism-related industries in 2005 and is included here by 

reference. The data in Table 4-9 are a compilation of data from travel- and tourism-related industries in 

the County Business Patterns (USDOC, Bureau of the Census, 2007). Employment data are assumed to 

be in various travel-related industries, including: food and beverage stores, gas stations, general 

merchandise stores, passenger air transportation, transit and ground passenger transportation, scenic and 

sightseeing transportation, passenger car rental, travel arrangement and reservation services, 

arts/entertainment/recreation, and accommodation and food services. The data are only for coastal 

counties and parishes because they are the ones potentially affected by routine events, such as OCSrelated air and vessel traffic, and accidental events, such as oil spills. This is different from the data for 

all counties and parishes in Labor Market Areas (LMA’s) and Economic Impact Areas (EIA’s) in Tables 

3-15 and 3-16 in the Multisale EIS. The LMA’s and EIA’s extend inland geographically including inland 

counties and parishes not economically linked to the tourism and recreation of coastal counties. The data 

in Table 4-9 of the Supplemental EIS more correctly describe the level of tourism-related employment 

and establishments potentially affected by OCS activities. Additional research was conducted to 

investigate recently available information since completion of the Supplemental EIS. A search of Internet 

information sources, available literature, and Federal and State agencies and industry websites was 

conducted to determine the availability of new information. Research revealed the following new 

information. 

Beach visitation in Louisiana is low compared with other Gulf Coast States. Gambling is one of the 

most popular activities for nonresident visitors to Louisiana. In 2004, approximately 21 percent of 

nonresident visitors gambled on their trip to the State, which is down from 25 percent in 2002 and 23 

percent in 2003 (Travel Industry Association of America, 2003, 2004, and 2005). 

There are 14 casinos and 4 racetracks currently operating in Louisiana, several of which are located 

along Louisiana’s coast in Lake Charles, Houma, and the New Orleans area. The casinos generate over 

$2.5 billion in gaming revenues and approximately $559.19 million in tax revenues. The taxes are 

allocated among the general fund, the City of New Orleans, public retirement systems, State Capitol 

improvements, and a rainy day fund. It is estimated that Louisiana casinos admitted 37.07 million visitors 

and employed approximately 18,009 workers in 2007 (American Gaming Association, 2007). 

There are 29 casinos operating in Mississippi that generate over $2.8 billion in gaming revenues and 

approximately $350 million in tax revenues. The taxes are allocated among housing, education, 

transportation, health care services, youth counseling programs, and local safety programs. It is estimated 

that Mississippi casinos admitted over 36 million visitors and employed 30,572 workers in 2007 

(American Gaming Association, 2007). 

The Mississippi Gulf Coast gaming industry has rebounded well after Hurricane Katrina. Of the 12 

casinos operating in the Biloxi-Gulfport Metropolitan Statistical Area, 10 were back in operation by 

December 2006 (Scott, 2007). For the Mississippi Gulf Coast (Gulfport and Biloxi), January 2007 

gaming revenues were $106 million compared with $119 million for January 2005, and February 2007 

revenues were $110 million compared with $109 million for February 2005 (Mississippi Gulf Coast 

Convention & Visitors Bureau, 2007). 
54 Impact Analysis

During the 2005 hurricane season, Hurricanes Katrina and Rita inflicted severe damage on the Gulf 

Coast and deposited extensive amounts of debris over various areas of the Gulf Coast (USDOC, NOAA, 

2007b). Submerged marine debris poses a hazard to vessel traffic. The NOAA is conducting underwater 

surveys off the coasts of Louisiana, Mississippi, and Alabama. This information is being used by State 

and Federal agencies tasked with removing marine debris left by Hurricane Katrina and will aid in 

planning for the aftermath of future storms. 

The Ocean Conservancy sponsors national and international beach cleanups, including annual events 

in Louisiana, Mississippi, and Alabama. In the Louisiana Coastal Cleanup on September 15, 2007, 

volunteers collected 5.483 pounds of trash and debris from 47 mi (76 km) of Louisiana beaches and 

barrier islands. The majority (75.1%) of the debris collected came from land-based activities such as 

beach outings, sporting events, and festivals (Ocean Conservancy, 2008). The Mississippi Marine Debris 

Task Force sponsors the annual Mississippi Coastal Cleanup. During the 19th Annual Mississippi 

Coastal Cleanup on September 15, 2007, more than 3,400 volunteers collected over 53,840 pounds of 

trash along 159 mi (256 km) of Mississippi Gulf Coast and barrier islands (Mississippi Dept. of Marine 

Resources, 2007). The 21st Annual Mississippi Coastal Cleanup is scheduled to take place on 

October 17, 2009 (Mississippi Coastal Cleanup, 2009). The Alabama Coastal Cleanup is coordinated 

through the Alabama Department of Conservation and Natural Resources, State Lands Division, Coastal 

Section and the Alabama People Against a Littered State. Since joining the effort in 1987, and through 

2008, over 55,000 volunteers have removed 1,034,000 pounds of trash from 3,000 mi (4,828 km) of 

shoreline. The results of the 22nd Alabama Coastal Cleanup are not yet available. The 23rd Alabama 

Coastal Cleanup is scheduled for September 20, 2010 (Alabama People Against a Littered State, 2009). 

In 2006, 15.9 million residents and nonresidents 16 years and older participated in wildlife-associated 

recreation in the Gulf Coast States and spent approximately $4.3 billion on hunting, $9.5 billion on 

fishing, and $6.9 billion on wildlife watching activities (USDOI, FWS, and USDOC, Bureau of the 

Census, 2006). These figures are for the whole of each Gulf Coast State. The wildlife-associated 

recreation activities in the coastal counties/parishes presumably would constitute a small fraction of the 

total. 

The MMS has reexamined the analysis for recreational resources presented in the Multisale EIS and 

the Supplemental EIS, including activities associated with the new areas, based on the additional 

information presented above. No new significant information was discovered that would alter the impacts 

for recreational resources presented in the two documents; therefore, a new analysis of the potential 

impacts of proposed Lease Sale 213 on recreational resources is not required. The analysis and potential 

impacts detailed in the Multisale EIS and the Supplemental EIS still apply for proposed Lease Sale 213. 

4.2.14. Archaeological Resources 

Archaeological resources are any material remains of human life or activities that are at least 50 years 

of age and that are of archaeological interest (30 CFR 250.105). The Archaeological Resources 

Regulation (30 CFR 250.194) provides specific authority to each MMS Regional Director to require 

archaeological resource surveys, analyses, and reports. Surveys are required prior to any exploration or 

development activities on leases within areas determined to have a high potential for archaeological 

resources (NTL’s 2005-G07 and 2008-G20). 

The description of archaeological resources (prehistoric and historic) can be found in Chapter 3.3.4 of 

the Multisale EIS. A detailed impact analysis of the routine, accidental, and cumulative impacts of 

proposed Lease Sale 213 on archaeological resources can be found in Chapters 4.2.2.1.14, 4.4.13, and 

4.5.14 of the Multisale EIS, respectively. The following information is a summary of the impact analysis 

incorporated from the Multisale EIS. 

The greatest potential impact to archaeological resources as a result of proposed Lease Sale 213 

would result from direct contact between an offshore activity (platform installation, drilling rig 

emplacement, and dredging or pipeline project) and a prehistoric site located on the continental shelf or 

an historic shipwreck. The NTL for archaeological resource surveys in the GOM Region, NTL 2005-

G07, mandates a 300-m linespacing for areas having the potential for containing prehistoric sites on the 

continental shelf, 50-m linespacing for remote-sensing surveys of leases within the areas having high 

potential for historic shipwrecks in water depths 200 m (656 ft) or less, and 300-m linespacing of leases 

within the areas having high potential for historic shipwrecks in water depths greater than 200 m (656 ft). 

NTL 2008-G20 updates the list of lease blocks that have been designated as having a high potential for 
Environmental Assessment 55 

containing archaeological resources and directs the operator to refer to the MMS website for the most 

current archaeological survey requirements for lease blocks in the Gulf of Mexico. 

The archaeological survey and archaeological clearance of sites required prior to an operator 

beginning oil and gas activities on a lease are expected to be highly effective at identifying possible 

archaeological resources. Since the survey and clearance process reduces the potential for a damaging 

interaction between an impact-producing factor and an archaeological resource, there is a very small 

possibility of an OCS activity contacting an archaeological resource where surveys and analysis are 

completed. However, recent research on historic shipping routes suggests that the ultra-deepwater area of 

the Gulf of Mexico, from approximately 25° N. latitude to 27.5° N. latitude, were located along the 

historic Spanish trade route, which therefore increases the probability that a historic shipwreck could be 

located in this area (Lugo-Fernandez et al., 2007). Few lease blocks in this area currently require any sort 

of archaeological survey or assessment; therefore, the impacts to historic shipwrecks in these blocks may 

be greater. Should such contact occur, there would be damage to or loss of significant and/or unique 

archaeological information. Last year MMS awarded a study to conduct archival research in order to 

develop a strategy for identifying and recognizing such sites in ultra-deepwater. 

Spills, collisions, and blowouts are accidental events that can happen in association with a proposed 

activity in the Lease Sale 213 area. If an accidental event occurs as a result of one of these events, there 

could be an impact to archaeological resources. Oil spills have the potential to affect both prehistoric and 

historic archaeological resources. Impacts to historic resources would be limited to visual impacts and, 

possibly, physical impacts associated with spill cleanup operations. Impacts to prehistoric archaeological 

sites would be the result of hydrocarbon contamination of organic materials, which have the potential to 

date site occupation through radiocarbon dating techniques, as well as possible physical disturbance 

associated with spill cleanup operations. Since archaeological sites are protected under law, it is expected 

that any spill cleanup operations would be conducted in such a way as to cause little or no impacts to 

archaeological resources. Visual impacts to coastal historic sites would be temporary and reversible; 

however, should an oil spill directly contact a coastal prehistoric site, unique or significant archaeological 

information could be lost, and this impact would be irreversible. 

The cumulative analysis considers the effects of impact-producing factors related to proposed Lease 

Sale 213, OCS activities in the cumulative activity area, trawling, sport diving, commercial treasure 

hunting, seismic exploration in State waters, and tropical storms on archaeological resources. Specific 

types of impact-producing factors associated with OCS activities that are considered in this analysis 

include drilling rig and platform emplacement, pipeline emplacement, anchoring, oil spills, dredging, new 

onshore facilities, and ferromagnetic debris. Archaeological surveys are assumed to be highly effective in 

reducing the potential for an interaction between an impact-producing activity and archaeological 

resources. 

Onshore development associated with activities from this proposed lease sale could result in the direct 

physical contact between the construction of new onshore facilities or pipeline canals and previously 

unidentified historic or prehistoric sites. This direct physical contact with a historic site could cause 

physical damage to, or complete destruction of, information on the history of the region and the Nation. 

Direct physical contact with a prehistoric site could destroy fragile artifacts or site features and could 

disturb the site context. The result would be the loss of information on the prehistory of North America 

and the Gulf Coast region. Facilities that are projected to be constructed as a result of this proposed lease 

sale must receive approval from the pertinent Federal, State, county/parish, and/or communities. 

Protection of archaeological resources in these cases is expected to be achieved through the various 

approval processes involved. There is, therefore, no expected impact to onshore historic or prehistoric 

sites adjacent to the Lease Sale 213 area from onshore development. 

Recent hurricane activity in the GOM is certain to have impacted archaeological resources in shallow 

water. In January 2007, MMS awarded a study to investigate the impacts that recent storm activity may 

have had on historic shipwrecks in the Gulf of Mexico. Remote-sensing surveys for this study were 

completed in May 2007 and dive operations were completed in October 2007. A final report of findings 

is expected in December 2009. Preliminary analysis of the remote-sensing surveys indicates that at least 

3 of the 10 shipwrecks examined were affected by recent storm activity (PBS&J, in preparation). The 

results of this study would have no bearing on the lease sale but could assist in the interpretation of survey 

data collected by operators as part of their permit responsibilities. 

A search was conducted for new information on hurricane activity in the GOM, published since 

completion of the Multisale EIS; however, little new information was identified. Yet, it is almost certain 
56 Impact Analysis

that any shipwrecks within the path of Hurricanes Katrina or Rita in shallow water were impacted to some 

extent by these storms. In September 2005 the National Park Service (NPS) conducted a study of sites 

along the Gulf Coast that were impacted by Hurricane Katrina (USDOI, NPS, 2005). This assessment 

identified three types of damage that can occur to archaeological sites: tree throws; storm surge, scouring 

and erosion; and seabed shifting. On the OCS, the two primary types of damage would be associated 

with storm surge and seabed shifting. Damage from either of these activities could adversely affect both 

prehistoric and historic sites on the OCS. 

A recently published report, Archaeological and Biological Analysis of World War II Shipwrecks in 

the Gulf of Mexico: Artificial Reef Effect in Deep Water (Church et al., 2007), documents the results of a 

multidisciplinary study that focused on the biological and archaeological aspects of seven World War II 

era shipwrecks in the north-central portion of the Gulf of Mexico. The study was funded by MMS and 

NOAA-OE. 

Seven shipwrecks, including a German U-boat and five allied vessels, were investigated. The ships 

lie in water ranging from 122 to 1,981 m (400 to 6,500 ft) deep. The study found deep-sea wrecks act as 

artificial reefs, attracting far more species of plants and animals than expected. The finding indicates that 

oil and gas production platforms in deep water are likely to serve as hard surface, supporting hundreds of 

life forms. 

Wrecks in moderate depths gave researchers clear evidence of many rare and uncommon invertebrate 

species in close proximity to the wrecks and on the wrecks themselves. The number of species and 

individuals declined rapidly in proportion to distance away from the wrecks, showing that these wrecks 

form an attractive habitat for many kinds of marine life. Wrecks at these intermediate depths had 50 

percent more species than those in shallower water or deeper water. Shallower water wrecks, likely 

because of turbidity, and deeper water wrecks because of the extreme conditions of cold, darkness, and 

pressure, hosted a smaller number of species. 

The scientists reported, among other findings, that the diversity of fish species generally decreases 

with depth. At the shallower water wrecks, where corals were growing, reef fishes were present. At the 

deepest water wrecks, no corals were found nor were community structure and fish density significantly 

different over the wrecks as opposed to away from them. Therefore, scientists conclude that, in the 

deepest water, the upper levels of offshore platforms will attract considerable marine life, but the 

platforms are not likely to attract fish at their deepest levels. The marine archaeology part of the study 

positively confirmed the identity of three wrecks and found a relationship among water depth, ship size, 

and the size of the debris field. The state of preservation of the wrecks was correlated with water depth. 

No wreck was found to be contaminating or adversely affecting the area around them. 

The MMS has reexamined the analysis for archaeological resources presented in the Multisale EIS 

and the Supplemental EIS, based on the additional information presented above. No new significant 

information was discovered that would alter the impacts for archaeological resources presented in the two 

documents; therefore, a new analysis of the potential impacts of proposed Lease Sale 213 on 

archaeological resources is not required. The analysis and potential impacts detailed in the Multisale EIS 

and the Supplemental EIS still apply for proposed Lease Sale 213. 

4.2.15. Human Resources and Land Use 

4.2.15.1. Land Use and Coastal Infrastructure 

Land use and OCS-related coastal infrastructure in the analysis area are discussed in Chapters 

3.3.5.1.2 and 3.3.5.8 of the Multisale EIS and Chapter 4.1.16.1 of the Supplemental EIS and include the 

following: service bases, navigation channels, helicopter hubs, construction facilities, processing 

facilities, terminals, waste disposal and storage facilities, coastal pipelines, and coastal barging. A 

detailed impact analysis of the routine, accidental, and cumulative impacts of proposed Lease Sale 213 on 

land use and coastal infrastructure can be found in Chapters 4.2.2.1.15.1, 4.4.14.1, and 4.5.15.1 of the 

Multisale EIS and Chapters 4.1.16.1.2, 4.1.16.1.3, and 4.1.16.1.4 of the Supplemental EIS. The following 

is a summary of the impact analysis incorporated from the Multisale EIS and the Supplemental EIS. 

To date, no new information has been found that necessitates a change to the coastal infrastructure 

scenario presented in the Multisale EIS and the Supplemental EIS. Although the addition of the 181 

South Area slightly increased some of the activity scenario parameters (e.g., production) for a typical 

CPA proposed action, the relatively small increase was not enough to change the long-term (i.e., 40-year) 
Environmental Assessment 57 

forecasts of coastal infrastructure needs to support OCS activity. The impacts of Hurricanes Gustav and 

Ike to coastal infrastructure were minimal and only resulted in short-term disruptions to operations. Much 

of the coastal infrastructure information presented in the Multisale EIS and the Supplemental EIS was 

from the OCS-Related Infrastructure in the Gulf of Mexico Fact Book (The Louis Berger Group, Inc., 

2004). An update of the fact book is currently in progress, and MMS has reviewed a draft version of the 

report and the new information collected for each infrastructure type. No new information has been 

found that necessitates a change to the onshore scenario presented in the Multisale EIS; therefore, the 

coastal infrastructure projections and impact analyses used in the Multisale EIS and the Supplemental EIS 

are still considered to be the best available for Lease Sale 213. 

Proposed Lease Sale 213 would not require additional coastal infrastructure, with the exception of 

possibly one new gas processing facility and one new pipeline landfall, and would not alter the current 

land use of the analysis area. There may be some expansion at current facilities, but the land in the 

analysis area is sufficient to handle such development. There is also sufficient land to construct a new gas 

processing plant in the analysis area, if necessary in the future. 

The accidental events associated with Lease Sale 213 that would most likely impact coastal 

infrastructure and land use include oil spills, chemical spills, and vessel collisions. Both coastal or 

nearshore spills and vessel collisions could have short-term adverse effects on the operations of coastal 

infrastructure facilities, requiring cleanup of any oil or chemicals spilled. In general, the impacts from an 

accidental event are not likely to last long enough to have any impact on the overall land use in the GOM 

analysis area. 

Activities relating to the OCS Program and State production are expected to minimally affect the 

analysis area’s land use. Land use in the analysis area will evolve over time; most changes are likely to 

occur as a result of general regional growth rather than activities associated with the OCS Program and 

State production. Projected new coastal infrastructure by state as a result of the OCS Program is shown in 

Table 4-9 of the Multisale EIS. While it is possible that up to 14 new, greenfield gas processing facilities 

could be developed, it is much more likely that a large share of the natural gas processing capacity that 

will be needed in the industry will be located at existing facilities, using future investments for expansions 

and/or to replace depreciated capital equipment. It is likely that few (if any) new plants would be 

developed along the Central or Western GOM. Any changes to supporting infrastructure (mostly facility 

expansions, except for the 4-6 new pipeline shore facilities and any new, greenfield gas processing plants) 

are expected to be contained on available land. Most subareas in the analysis area have strong industrial 

bases and designated industrial parks to accommodate future growth in oil and gas businesses. 

As previously noted in the Multisale EIS and SEIS, Port Fourchon is expected to experience 

significant impacts to its land use from OCS-related expansion. For the near term, Port Fourchon would 

most likely be the primary support base to support activity in the 181 South Area. Because of the limited 

amount of land available at Port Fourchon, the port may face capacity constraints in the long term. 

Operators are also looking to diversify risk from shutdowns like those experienced after Hurricanes 

Katrina and Rita, and are therefore likely to look to other ports with deepwater access. As previously 

analyzed and noted in the Multisale EIS and SEIS, increased OCS-related usage from port clients is 

expected to significantly impact LA Highway 1 in Lafourche Parish. Also, increased demand of water by 

the OCS will further strain Lafourche Parish’s water system. It is assumed that the Louisiana Department 

of Natural Resources’ existing procedures to identify potential regulatory and restoration conflicts will 

continue to be utilized, including current requirements that any project proposed within 1⁄4 mi from either 

an active or proposed restoration project be reviewed to determine if it would interfere or have adverse 

effects on the restoration project (U.S. Dept. of the Army, COE, 2004). Therefore, new coastal 

infrastructure that may result from proposed Lease Sale 213 or the OCS Program would not interfere with 

active or proposed restoration projects. 

As stated in Chapter 4.1.2.1.7 of the Multisale EIS, MMS assumes that most new OCS pipelines will 

connect to existing pipelines in Federal and State waters, and result in few, if any, new pipeline landfalls. 

Up to one new pipeline landfall was projected as the result of proposed Lease Sale 213, and 32-47 new 

pipeline landfalls were projected as a result of the OCS Program from 2007 to 2046. 

The MMS recently analyzed historical data to validate past scenario projections, including projections 

of new pipeline landfalls (USDOI, MMS, 2007e). This analysis confirms MMS’s assumption that the 

majority of new pipelines constructed would connect to the existing infrastructure in Federal and State 

waters and that very few would result in new pipeline landfalls. Most pipeline landfalls in the GOM 

transport production resulting from more than one lease sale; therefore, an OCS pipeline landfall could 
58 Impact Analysis

rarely be attributed to a single lease sale. Multiple factors have influenced the decrease in the number of 

new pipeline landfalls. Therefore, MMS’s projection of up to one new pipeline landfall per lease sale 

may be too high. Although there will be some instances where new pipelines may need to be constructed, 

there is nothing to suggest any dramatic shifts in the trends in new landfalls given the current outlook for 

GOM development, particularly in coastal Louisiana. 

The term “pipeline shore facility” is a broad term describing the onshore location where the first stage 

of processing occurs for OCS pipelines carrying different combinations of oil, condensate, gas, and 

produced water. A pipeline shore facility may support one or several pipelines. In Chapter 4.1.2.1.5.1 of 

the Multisale EIS, no new pipeline shore facilities are projected as a result of proposed Lease Sale 213. 

As a result of the OCS Program, new shore facilities may be needed to support new larger oil pipeline 

landfalls. A total of 4-6 new pipeline shore facilities are projected as a result of the OCS Program. 

The MMS has reexamined the analysis for land use and coastal infrastructure presented in the 

Multisale EIS and the Supplemental EIS. Much of the coastal infrastructure information presented in the 

Multisale EIS and the Supplemental EIS was from the OCS-Related Infrastructure in the Gulf of Mexico 

Fact Book (The Louis Berger Group, Inc., 2004). An update of the fact book is currently in progress, and 

MMS has reviewed a draft version of the report and the new information collected for each infrastructure 

type. No new significant information was discovered that would alter the coastal infrastructure scenario 

or impacts for land use and coastal infrastructure presented in the Multisale EIS and the Supplemental 

EIS; therefore, a new analysis of the potential impacts of proposed Lease Sale 213 on land use and coastal 

infrastructure is not required. The analysis and potential impacts detailed in the Multisale EIS and the 

Supplemental EIS still apply for proposed Lease Sale 213. 

4.2.15.2. Demographics 

The description of the environment for demographics is described in Chapter 3.3.5.4 of the Multisale 

EIS and Chapter 4.1.16.2.1 of the Supplemental EIS. Detailed analysis of the routine, accidental, and 

cumulative impacts of proposed Lease Sale 213 on demographics is presented in Chapters 4.2.2.1.15.2, 

4.4.14.2, and 4.5.15.2 of the Multisale EIS, respectively and Chapters 4.1.16.2.2, 4.1.16.2.3, and 

4.1.16.2.4 of the Supplemental EIS. The following is a summary of the impact analysis from the 

Multisale EIS and the Supplemental EIS. A search was conducted for new information since completion 

of the Supplemental EIS that would affect the impact analyses. The MMS reviewed the 2008 Woods & 

Poole data that are now available and found no significant changes to the population and employment 

projections that would alter the impacts contained in the Multisale EIS and the Supplemental EIS (Woods 

& Poole Economics, Inc., 2008). 

Routine activities relating to proposed Lease Sale 213 are expected to affect minimally the analysis 

area’s land use, infrastructure, and demography. These impacts are projected to mirror employment 

effects that are estimated to be negligible to any one EIA (Figure 5). Baseline patterns and distributions 

of these factors, as described in Chapter 3.3.5.4 of the Multisale EIS and Chapter 4.1.16.2.1 of the 

Supplemental EIS, are expected to approximately maintain the same level. Changes in land use 

throughout the analysis area are expected to be contained and minimal. The OCS-related infrastructure is 

in place and will not change as a result of proposed Lease Sale 213. Current baseline estimates of 

population growth for the analysis area show a continuation of growth, but at a slower rate. 
Environmental Assessment 59 

Figure 5. Economic Impact Areas in the Gulf of Mexico. 

Accidental events associated with proposed Lease Sale 213 such as oil or chemical spills, blowouts, 

and vessel collisions would have no effects on the demographic characteristics of the Gulf coastal 

communities. 

The cumulative effects of human and natural activities in the coastal area have severely degraded the 

deltaic processes and shifted the coastal area from a condition of net land building to one of net landloss. 

As inland marshes and barrier islands erode or subside, without effective restoration efforts, the 

population in coastal communities in southern Louisiana is expected to shift to the more northern portions 

of the parishes and cause increasing populations in urban and suburban areas and declining populations in 

rural coastal areas (U.S. Dept. of the Army, COE, 2004). 

Cumulative activities related to the OCS Program are expected to affect minimally the analysis area’s 

demography. Baseline patterns and distributions of these factors, as described in Chapter 3.3.5.4.1 of the 

Multisale EIS and Chapter 4.1.16.2.4 of the Supplemental EIS, are not expected to change for the analysis 

area as a whole. The baseline population patterns are expected to change for the eight counties and 

parishes that were most negatively affected by the 2005 hurricane season (see Chapter 3.3.5.4 of the 

Multisale EIS for a discussion of these changes). Some regions within Louisiana EIA’s, Port Fourchon in 

particular, are expected to experience some impacts to population and their education system as a result of 

increased demand for OCS labor. As discussed in Chapter 4.2.2.1.15.2 of the Multisale EIS, proposed 

Lease Sale 213 is expected have an incremental contribution of less than 1 percent to the population level 

in any of the EIA’s. Given the low levels of population growth and the industrial expansion associated 

with proposed Lease Sale 213, the baseline age and racial distribution pattern and education status, is 

expected to continue through the year 2046. 

In the Supplemental EIS, MMS used data from Woods & Poole’s Complete Economic and 

Demographic Data Source (Woods & Poole Economics, Inc., 2007) for baseline population and 

employment estimates over the 40-year life of a typical proposed CPA lease sale. According to the 2007 

data, population, income, and employment were assumed to decline from 2005 to 2006 by 76 percent in 

St. Bernard Parish, Louisiana; 51 percent in Orleans Parish, Louisiana; 22 percent in Plaquemines Parish, 

Louisiana; 19 percent in Cameron Parish; Louisiana; 13 percent in Hancock County, Mississippi; and 11 

percent in Harrison County, Mississippi. In each case, these losses were less than those that were in the 

Woods & Poole 2006 data. The 2007 data also revised assumptions regarding counties and parishes that 

experienced population and employment gains because of Hurricane Katrina displacement: 9 percent in 

Pearl River County, Mississippi; 7 percent in Tangipahoa Parish, Louisiana; 5 percent in St. John the 

Baptist Parish, Louisiana; 5 percent in East Baton Rouge Parish, Louisiana; and 4 percent in St. Charles 
60 Impact Analysis

Parish, Louisiana from 2005 to 2006. In each case, these gains were less than those that were in the 2006 

data. 

As discussed in Chapter 4.1.1, the exploration and development activity scenarios used in the 

Supplemental EIS for a typical CPA sale remain unchanged and are used for the analysis of proposed 

Lease Sale 213. Consequently, the population projections for a typical proposed CPA sale in Table 4-28 

of the Multisale EIS did not change significantly for proposed Lease Sale 213. The MMS reanalyzed the 

high-case population impacts on a percentage basis for the three EIA’s that exhibited the highest impacts 

in the Multisale EIS and the Supplemental EIS (LA-2, LA-3, and LA-4) using the revised Woods & Poole 

data. With the exception of year 1 (2008) for LA-4, which declined slightly, the population impacts on a 

percentage basis for the three EIA’s are the same as reported in Table 4-29 of the Multisale EIS. Thus, 

the potential population impacts described in the Multisale EIS and the Supplemental EIS and 

summarized above apply for proposed Lease Sale 213. 

The Supplemental EIS presents additional information regarding population trends in the GOM 

region, particularly as it relates to the recovery from the 2005 hurricanes. More recent recovery 

information is provided below. However, this supplemental information does not in any way change the 

baseline population and employment projections used to analyze impacts of a typical CPA sale and the 

OCS Program, the methodologies used, or the conclusions presented in the Multisale EIS or the 

Supplemental EIS. 

The U.S. Census reported that, from July 2007 to July 2008, Louisiana marked a second year in a row 

of population in-migration, including over 13,500 more residents (LED, 2009). Overall, Louisiana’s 

population increased by almost 37,500 in the same time period, which is an increase of 0.9 percent. The 

Brookings Institution and the Greater New Orleans Community Data Center (GNOCDC) report that the 

New Orleans area continues to recover post-Katrina. The population of New Orleans grew by 1.9 percent 

between July and December 2008, bringing it to 73.7 percent of pre-Katrina levels (The Brookings 

Institution and GNOCDC, 2009). 

The MMS has reexamined the analysis for demographics presented in the Multisale EIS and the 

Supplemental EIS, based on the additional information presented above. No new significant information 

was discovered that would alter the impacts for demographics presented in the two documents; therefore, 

a new analysis of the potential impacts of proposed Lease Sale 213 on demographics is not required. The 

analysis and potential impacts detailed in the Multisale EIS and the Supplemental EIS still apply for 

proposed Lease Sale 213. 

4.2.15.3. Economic Factors 

The description of the current economic factors for the GOM analysis area can be found in Chapter 

3.3.5.5 of the Multisale EIS and Chapter 4.1.16.3 of the Supplemental EIS. A detailed impact analysis of 

the routine, accidental, and cumulative impacts of proposed Lease Sale 213 on economic factors can be 

found in Chapters 4.2.2.1.15.3, 4.4.14.3, and 4.5.15.3 of the Multisale EIS and Chapters 4.1.16.3.2, 

4.1.16.3.3, and 4.1.16.3.4 of the Supplemental EIS, respectively. The following is a summary of the 

impact analysis incorporated from the Multisale EIS and the Supplemental EIS. 

The new areas are located more than 100 mi (161 km) from the nearest coast and are not projected to 

increase the overall activity that would result from proposed Lease Sale 213; therefore, no additional 

impacts on recreation resources are projected as a result of the inclusion of the new acreage. 

A search was conducted for new information published since completion of the Supplemental EIS 

that would affect the impact analyses. The MMS reviewed the 2008 Woods & Poole data that is now 

available and found no significant changes to the population and employment projections that would alter 

the impact conclusions contained in the Multisale EIS and the Supplemental EIS (Woods & Poole 

Economics, Inc., 2008). Employment growth is expected to be widespread throughout the Southeast 

United States as the regional economy completes its recovery from Hurricane Katrina-related dislocations 

(Woods & Poole Economics, Inc., 2008). 

Should proposed Lease Sale 213 occur, there would be only minor economic changes in the Texas, 

Louisiana, Mississippi, Alabama, and Florida EIA’s (Figure 5). Proposed Lease Sale 213 is expected to 

generate less than a 1 percent increase in employment in any of these subareas. This demand will be met 

primarily with the existing population and available labor force. Accidental events such as oil or 

chemical spills, blowouts, and vessel collisions could have modest, short-term adverse economic 

consequences. Negative, long-term economic and social impacts may be more substantial if fishing, 
Environmental Assessment 61 

shrimping, oystering, and/or tourism were to suffer or were to be perceived as having suffered because of 

the event. 

The OCS Program will produce only minor economic changes in most of the individual EIA’s. 

However, it is projected to substantially impact the Louisiana EIA’s LA-2 and LA-3, with OCS-related 

employment expected to peak at 23.8 percent and 9.8 percent of total employment, respectively. As 

examined and noted in the Multisale EIS and the Supplemental EIS, activities related to the OCS Program 

on a regional level are expected to significantly impact employment in Lafourche Parish, Louisiana, 

within EIA LA-3. Therefore, the population, housing, roads (LA Highway 1), water supply, schools, and 

hospitals in the parish will be affected and potentially strained. 

In the Supplemental EIS, MMS used data from Woods & Poole’s Complete Economic and 

Demographic Data Source (Woods & Poole Economics, Inc., 2007) for baseline population and 

employment estimates over the 40-year life of a typical proposed CPA lease sale. According the 2007 

data, population, income, and employment were assumed to decline from 2005 to 2006 by 76 percent in 

St. Bernard Parish, Louisiana; 51 percent in Orleans Parish, Louisiana; 22 percent in Plaquemines Parish, 

Louisiana; 19 percent in Cameron Parish; Louisiana; 13 percent in Hancock County, Mississippi; and 11 

percent in Harrison County, Mississippi. In each case, these losses were less than those that were in the 

Woods & Poole 2006 data. The 2007 data also revised assumptions regarding counties and parishes that 

experienced population and employment gains because of Hurricane Katrina displacement: 9 percent in 

Pearl River County, Mississippi; 7 percent in Tangipahoa Parish, Louisiana; 5 percent in St. John the 

Baptist Parish, Louisiana; 5 percent in East Baton Rouge Parish, Louisiana; and 4 percent in St. Charles 

Parish, Louisiana from 2005 to 2006. In each case, these gains were less than those that were in the 2006 

data. 

As discussed in Chapter 4.1.1, the exploration and development activity scenarios used in the 

Supplemental EIS for a typical CPA sale remain unchanged and are used for the analysis of proposed 

Lease Sale 213. Consequently, the employment projections for a typical proposed CPA sale in the 

Multisale EIS (Tables 4-30 and 4-31) are unchanged for Lease Sale 213. The MMS reanalyzed the highcase employment impacts on a percentage basis for the three economic impact areas (EIA’s) that 

exhibited the highest impacts in the Multisale EIS and the Supplemental EIS (LA-2, LA-3, and LA-4) 

using the new 2008 Woods & Poole data. As shown in Table 5 below, the employment impacts on a 

percentage basis for the three EIA’s are not substantially different from those reported in the Multisale 

EIS and the Supplemental EIS. Thus, the potential employment impacts described in the Multisale EIS 

and the Supplemental EIS and summarized above apply for proposed Lease Sale 213. 
62 Impact Analysis

Table 5 

 

Projected Employment Associated with Proposed Lease Sale 213 by Economic Impact Area 

Revised Baseline Employment 

Projections (in thousands)1

High Case CPA Proposed 

Action Employment 

Estimates2

Projected Employment 

Associated with Proposed 

Lease Sale 213 as Percent of 

Total Baseline Employment 

Calendar 

Year 

Model 

Year 

LA2 LA3 LA4 LA2 LA3 LA4 LA2 LA3 LA4 

2010 1 332.2 680.6 711.5 572 550 355 0.17% 0.08% 0.05% 

2011 2 336.4 690.7 718.6 1,507 1,477 998 0.45% 0.21% 0.14% 

2012 3 340.7 700.9 725.7 1,442 1,353 902 0.42% 0.19% 0.12% 

2013 4 345.0 711.2 732.9 1,486 1,394 938 0.43% 0.20% 0.13% 

2014 5 349.4 721.7 740.2 3,602 3,482 2,354 1.03% 0.48% 0.32% 

2015 6 353.9 732.4 747.6 1,719 1,589 1,065 0.49% 0.22% 0.14% 

2016 7 358.4 743.3 755.1 1,232 1,140 779 0.34% 0.15% 0.10% 

2017 8 363.0 754.3 762.7 1,080 921 617 0.30% 0.12% 0.08% 

2018 9 367.6 765.5 770.3 844 659 453 0.23% 0.09% 0.06% 

2019 10 372.4 776.9 778.1 909 701 487 0.24% 0.09% 0.06% 

2020 11 377.1 788.5 786.0 965 742 515 0.26% 0.09% 0.07% 

2025 16 402.1 849.3 826.7 1,210 916 647 0.30% 0.11% 0.08% 

2030 21 428.8 915.3 870.2 1,083 804 573 0.25% 0.09% 0.07% 

2035 26 457.4 986.9 916.3 1,059 766 552 0.23% 0.08% 0.06% 

2040 31 488.1 1,064.9 965.5 969 716 532 0.20% 0.07% 0.06% 

1

 Source: Woods & Poole Economics, Inc., 2008. 

2

 Source: Tables 4-31a and 4-31b of the Multisale EIS. 

The Supplemental EIS presents additional information regarding economic conditions in the GOM 

region, particularly as it relates to the recovery from the 2005 hurricanes. More recent recovery 

information is provided below. However, this supplemental information does not in any way change the 

baseline population and employment projections used to analyze impacts of a typical CPA sale and the 

OCS Program, the methodologies used, or the conclusions presented in the Multisale EIS or the 

Supplemental EIS. 

Louisiana’s economic performance was strong in 2008, despite the overall national slowdown. From 

December 2007 through November 2008, Louisiana’s total nonfarm employment grew by 6,800 jobs to 

1,947,600 jobs—an increase of 0.4 percent, which was greater than the rest of the South and the U.S. 

overall (LED, 2009). Manpower Inc. ranked three of Louisiana’s regions in the top 10 nationally for 

hiring projections for early 2009: Lafayette was first in the Nation; New Orleans came in sixth; and 

Shreveport/Bossier ranked eighth (LED, 2009). In contrast to the Nation, the greater New Orleans 

economy has grown, boosted by the large-scale building effort underway. The region’s unemployment is 

a relatively low 4.9 percent, far below the national rate. Unemployment claims nationwide rose 105 

percent in the last 6 months of 2008, while at the same time falling 5 percent and 28 percent in New 

Orleans and the region, respectively (The Brookings Institution and GNOCDC, 2009). 

However, the massive destruction from Hurricane Katrina remains widespread. Tens of thousands of 

residential, commercial, and institutional buildings remain damaged and unoccupied. In Orleans and St. 

Bernard Parishes, 69,727 and 15,188 residential addresses, respectively, were unoccupied as of 

September 2008 (The Brookings Institution and GNOCDC, 2009). There is still a shortage of affordable 

rental housing, and recent data indicates that rents increased 4 percent across the New Orleans metro area 

from 2008 to 2009, and they are now 52 percent higher than pre-Katrina (The Brookings Institution and 

GNOCDC, 2009). 

The MMS has reexamined the analysis for economic factors presented in the Multisale EIS and the 

Supplemental EIS, including activities associated with the new areas, based on the additional information 

presented above. No new significant information was discovered that would alter the impacts for 

economic factors presented in the two documents; therefore, a new analysis of the potential impacts of 
Environmental Assessment 63 

proposed Lease Sale 213 on economic factors is not required. The analysis and potential impacts detailed 

in the Supplemental EIS still apply for proposed Lease Sale 213. 

4.2.15.4. Environmental Justice 

The description of the environment for environmental justice can be found in Chapter 3.3.5.10 of the 

Multisale EIS. Detailed analysis of the routine, accidental, and cumulative impacts of proposed Lease 

Sale 213 on environmental justice can be found in Chapters 4.2.2.1.15.4, 4.4.14.4, and 4.5.15.4, 

respectively of the Multisale EIS and the Supplemental EIS. The following is a summary of the impact 

analysis from the Multisale EIS and the Supplemental EIS. 

The new areas are located more than 100 mi (161 km) from the nearest coast and are not projected to 

increase the overall activity that would result from proposed Lease Sale 213; therefore, the limited 

activity associated with the new areas will have few impacts and their location means that any impacts 

that may result are unlikely to be concentrated in an area that could disproportionately impact minority or 

low-income people. 

Because of the presence of an extensive and widespread support system for OCS and associated labor 

force, the effects of proposed Lease Sale 213 are expected to be widely distributed and, except in 

Louisiana, little felt. In general, the infrastructural needs generated by proposed Lease Sale 213 will be 

met by the existing support systems, and these effects will be negligible. In general, who will be hired 

and where new infrastructure might be located is impossible to predict. A new C-Port (multiservices port 

terminal facility) in Galveston may be developed and this would likely increase Texas’ share of the 

effects. However, this would occur in an already highly industrialized area so its effects would be 

primarily economic. For these reasons, impacts related to proposed Lease Sale 213 are expected to be 

economic and have a limited but positive effect on low-income and minority populations. Given the 

existing distribution of the industry and the limited concentrations of minority and low-income peoples, 

proposed Lease Sale 213 is not expected to have a disproportionate effect on these populations. 

Lafourche Parish, Louisiana, will experience the most concentrated effects of proposed Lease Sale 

213; however, because the parish is not heavily low-income or minority and because the effects of road 

traffic and port expansion will not occur in areas of low-income or minority concentration, these groups 

are not expected to be disproportionately affected. 

Proposed Lease Sale 213 would help to maintain ongoing levels of activity rather than expand them. 

Future changes in activity levels will most likely be caused by fluctuations in oil prices and imports, and 

not be due to activities related to proposed Lease Sale 213. Routine impacts associated with proposed 

Lease Sale 213 are not expected to have disproportionate high/adverse environmental or health effects on 

minority or low-income populations. 

With respect to accidental events, considering the low likelihood of an oil spill and the heterogeneous 

population distribution along the GOM region coasts, accidental spill events associated with proposed 

Lease Sale 213 are not expected to have disproportionate adverse environmental or health effects on 

minority or low-income people. 

In the GOM coastal area, the contribution of proposed Lease Sale 213 and the OCS Program to the 

cumulative effects of all activities and trends affecting environmental justice issues over the next 40 years 

is expected to be negligible to minor. The cumulative effects will be concentrated in coastal areas, and 

particularly, Louisiana. Most OCS Program effects are expected to be in the areas of job creation and the 

stimulation of the economy and are expected to make a small yet positive contribution to an area’s 

economy. The contribution of the cumulative OCS Program to the cumulative impacts of all factors 

affecting environmental justice is expected to be minor (USDOI, MMS, 2001); therefore, the incremental 

contribution of proposed Lease Sale 213 to the cumulative impacts would also be minor. 

A search was conducted for new information published since completion of the Multisale EIS and the 

Supplemental EIS. Analysis of the Federal Emergency Management Agency’s (FEMA) storm damage 

data shows that Hurricane Katrina’s impact was disproportionately borne by the region’s African 

American community, by people who rented their homes, and by the poor and unemployed. More than 

one-third of the region’s 1.7 million residents lived in areas that suffered flooding or moderate to 

catastrophic storm damage, according to FEMA. The majority of people living in damaged areas were in 

the City of New Orleans (over 350,000), with additional concentrations in suburban Jefferson Parish 

(175,000) and St. Bernard Parish (53,000) and along the Mississippi Coast (54,000). In the region as a 

whole, the disparities in storm damage are shown in the following comparisons (arranged in order of the 
64 Impact Analysis

degree of disparity): by race-damaged areas were 46 percent black, compared with 26 percent in 

undamaged areas; by housing tenure—46 percent of homes in damaged areas were occupied by renters, 

compared with 31 percent in undamaged communities; and by poverty and employment status—21 

percent of households had incomes below the poverty line in damaged areas, compared with 15 percent in 

undamaged areas, and 7.6 percent of persons in the labor force were unemployed in damaged areas 

(before the storm), compared to 6.0 percent in undamaged areas. These comparisons are heavily 

influenced by the experience of the City of New Orleans. Outside the city, there were actually smaller 

percentages of African American, poor, and unemployed residents in the damaged areas. Closer 

inspection of neighborhoods within New Orleans shows that some affluent white neighborhoods were 

hard hit, while some poor minority neighborhoods were spared. Yet, if the post-Katrina city were limited 

to the population previously living in areas that were undamaged by the storm—that is, if nobody were 

able to return to damaged neighborhoods—New Orleans would be at risk of losing more than 80 percent 

of its black population (Logan, 2007). 

The Multisale EIS and the Supplemental EIS state the following: “Evidence also suggests that a 

healthy offshore petroleum industry also indirectly benefits low-income and minority populations.” One 

MMS study in Louisiana found income inequality decreased during the oil boom and increased with the 

decline (Tolbert, 1995). The following updated information relates to this point. 

A follow-up study to Tolbert (1995) focuses on Abbeville, Louisiana, and appears to qualify the 

researcher’s earlier conclusions. One component of the second study (Tolbert 2006) looks at the 

consequences of a plant closure in Abbeville and finds that, in its wake, more employment opportunities 

existed within Abbeville than in the surrounding area because, in Abbeville, a growing oil and gas 

industry was creating alternative labor market opportunities. This finding suggests that a component of a 

community’s industrial composition that is a key source of sustainability in the face of economic 

fluctuations at one time may be the problem at a different time since Tolbert (2006) identifies the oil 

industry as a stabilizing force while Tolbert (1995) described it as the problem. The particular lesson in 

the Abbeville context is that shifts in manufacturing sectors of an economy can be sustained by strong 

business services and professional sectors, in this case sectors that are also part of the oil industry (1995). 

Multiple Internet searches of websites related to the subject of environmental justice found no new 

information regarding environmental justice issues that relate to offshore petroleum activities in the GOM 

region. Two ongoing MMS-sponsored socioeconomic studies include a substantial fieldwork in coastal 

Gulf areas from Texas through Alabama: “History of the Gulf of Mexico Offshore Petroleum Industry, 

Phase III: Deepwater Developments” and “Gulf Coast Communities and the Fabrication and 

Shipbuilding Industry: A Comparative Study.” These studies have generated no new information 

regarding environmental justice issues that relate to offshore petroleum activities in this area. 

The MMS has reexamined the analysis for environmental justice presented in the Multisale EIS and 

the Supplemental EIS, based on the additional information presented above. No new significant 

information was discovered that would alter the impacts for environmental justice presented in the two 

documents; therefore, a new analysis of the potential impacts of proposed Lease Sale 213 on 

environmental justice is not required. The analysis and potential impacts detailed in the Multisale EIS 

and the Supplemental EIS still apply for proposed Lease Sale 213. 
Environmental Assessment 65 

5. CONSULTATION AND COORDINATION 

5.1. SCOPING FOR THE ENVIRONMENTAL ASSESSMENT FOR THE CENTRAL 

PLANNING AREA’S PROPOSED LEASE SALE 213 

The MMS performs ongoing external and internal scoping in order to determine the breadth and depth 

necessary for environmental analysis. 

External Scoping: The scoping process for this EA was formally initiated on October 9, 2008, with 

the Federal Register notice announcing the preparation of an EA. In the notice, MMS requested that 

interested parties submit comments regarding any new information or issues that should be addressed in 

the EA. The comment period closed on July 23, 2007. One response was received from the Governor of 

Alabama. This comment was considered in the preparation of this EA. 

Scoping and coordination efforts continue throughout the lease sale process and have been conducted 

since the publication of the Supplemental EIS: 

• On July 24 and 26, 2007, public meetings were held to solicit comments regarding 

the Draft Supplemental EIS for EPA Lease Sale 224 in Pensacola, Florida, and 

Larose, Louisiana. 

• On August 27, 2007, MMS published a Notice of Intent to Prepare a Supplemental 

EIS (NOI) on proposed Lease Sale 208, which will offer for sale approximately 5.8 

million ac located in the southeastern part of the CPA (“181 South Area”). The SEIS 

will also address proposed oil and gas lease sales tentatively scheduled in 2009-2012 

for the CPA and WPA. In the NOI, MMS requested interested parties to submit 

comments regarding any new information or issues that should be addressed in the 

SEIS. The comment period for the NOI closed on October 11, 2007. 

Thirteen comment letters were received in response to the Federal Register notice announcing the 

availability of the Draft Supplemental EIS. Comments were received from Federal and State agencies, 

organizations, and the general public. The comments received included requests for oil-spill updates; 

compensatory mitigation for environmental and socioeconomic impacts; avoidance of impacts to 

migratory birds, sea turtles, marine mammals, commercial fishing, and benthic resources; infrastructure 

maintenance; and hurricane impacts. Alabama’s Department of Natural Resources commented on the 

Draft Supplemental EIS noting the Governor’s opposition to leasing within 15 mi (24 km) of Baldwin 

County and asking that MMS provide adequate protection for the biological communities and sensitive 

habitats offshore of Alabama. Louisiana responded to the Draft Supplemental EIS with an 11-page letter 

contending that MMS is not conducting meaningful and comprehensive analyses of potential effects and 

that MMS is not adhering to the conditions agreed upon in the settlement of Blanco vs. Burton. As 

required by 40 CFR 1503.4, all comments on the Draft Supplemental EIS were responded to in the Final 

Supplemental EIS. Where appropriate, MMS supplemented, improved, or modified its analyses in the 

Final Supplemental EIS to address Louisiana’s comments. Where requested information or analysis was 

already included in the Draft Supplemental EIS, the appropriate sections were referenced. 

On October 9, 2008, MMS published a Notice of Preparation of an EA on proposed Lease Sale 213 in 

the Federal Register. In the notice, MMS requested interested parties to submit comments regarding any 

new information or issues that should be addressed in the EA. One comment was received from the State 

of Louisiana. In the letter, the State expressed concern about the environmental impacts to Louisiana 

caused by mineral exploration and production activities on the OCS. The letter requested that the EA 

address previously identified shortcomings in MMS’s NEPA documents by providing up-to-date 

scientific analyses of OCS impacts to coastal Louisiana. The letter called the practice of tiering EA’s off 

earlier NEPA documents scientifically unacceptable, and it stated that the practice does not meet the legal 

burden of considering the environmental impacts of the proposed Federal action. As the Council on 

Environmental Quality allows, this EA tiers off prior NEPA documents to enable it to focus on new 

information. 

Internal Scoping: Internal scoping is an ongoing activity for all environmental projects and NEPA 

documents. Part of internal scoping involves reviewing resource estimates and oil-spill modeling results 
66 Consultation and Coordination

used in the preparation of the Multisale EIS and the Supplemental EIS to determine if they are still valid. 

The MMS GOM Region’s Office of Resource Evaluation reviewed the oil and gas resource projections 

and associated activities for CPA Lease Sale 213 and confirmed that they remain within the range of 

those projected by MMS for a “typical CPA lease sale.” The MMS Headquarters’ Oil-Spill Risk Analysis 

(OSRA) group confirmed that results from the OSRA model summarized in the Multisale EIS and the 

Supplemental EIS and presented in a separate MMS report (USDOI, MMS, 2007i) are still valid for the 

proposed lease sale. 

Internal scoping also requires MMS subject matter experts/analysts and NEPA coordinators to 

continuously update their knowledge base and incorporate three primary informational components into 

their analyses: 

(1) recent studies/reports; 

(2) monitoring results; and 

(3) related cumulative-impact data. 

The MMS’s analysts and coordinators take an active role in the preparation, execution, and peer 

review of studies and reports developed under MMS’s Environmental Studies Program. In addition, 

some analysts provide expertise and are involved in additional studies and analyses conducted by other 

Federal/State agencies and universities concerning GOM issues and interests. The information obtained 

from these studies, as well as other relevant, non-MMS research, was considered by each subject matter 

expert in their assessment for this EA. Appendix C of the Multisale EIS lists the GOM Region’s studies 

published from 2003 to 2006. Technical summaries for these studies and more recent studies are 

available on the MMS Internet website (http://www.gomr.mms.gov/homepg/regulate/environ/techsumm/

rec_pubs.html). Appendix C in the Supplemental EIS lists the MMS-funded hurricane research and 

studies. 

Cumulative analyses are prepared by MMS subject matter experts that consider activities that could 

occur and may adversely affect GOM resources, including proposed Lease Sale 213, prior and future 

OCS lease sales, State oil and gas activities, and other governmental and private projects and activities. 

The MMS analysts are often responsible for reviewing GOM activities not associated with oil and gas 

operations. All information gained from cumulative analyses was considered by MMS analysts in their 

assessments for this EA. 

5.2. CONSULTATION AND COORDINATION CALENDAR

A complete description of all consultation and coordination activities and meetings is included in 

Chapter 5 of the Multisale EIS and the Supplemental EIS. A brief summary of these events follows: 

Multisale EIS Process

March 7, 2006 The NOI for the proposed 2007-2012 CPA and WPA lease sales was published 

in the Federal Register. A 45-day comment period was provided; it closed on 

April 21, 2006. Additional public notices were distributed via newspaper 

notices, mailed notices, and the Internet. The MMS received 65 scoping letters 

in response to the NOI, which are summarized in Chapter 5.3.1 of the Multisale 

EIS. 

March 28-30, 2006 

April 6, 2006 

The MMS held scoping meetings in Houston, Texas; Harahan, Louisiana; 

Mobile, Alabama; and Tallahassee, Florida, to receive comments on the Draft 

EIS for the proposed 2007-2012 CPA and WPA lease sales. A summary of 

comments presented at the scoping meetings is provided in Chapter 5.3.1 of the 

Multisale EIS. 
Environmental Assessment 67 

April 28, 2006 The Call for Information and Nominations (Call) for the proposed 2007-2012 

lease sales was published in the Federal Register. A 30-day comment period 

was provided; it closed on May 30, 2006. The MMS received five comment 

letters in response to the Call, which are summarized in Chapter 5.3.3 of the 

Multisale EIS. 

December 5-7, 2006 The MMS held public hearings in Houston, Texas; New Orleans and Larose, 

Louisiana; Panama City, Florida; and Mobile, Alabama, to receive comments 

on the Draft Multisale EIS for CPA Lease Sales 205, 206, 208, 213, 216, and 

222, and WPA Lease Sales 204, 207, 210, 215, and 218. There were no 

speakers at the Houston, Mobile and Larose hearings. One individual 

presented comments at the New Orleans hearing and 26 at the Larose hearing. 

The comments are summarized in Chapter 5.5 of the Multisale EIS. 

December 12, 2006 The EFH programmatic consultation was initiated and completed for the 2007-

2012 lease sales, including Lease Sale 213. The NMFS’s Southeast Regional

Office concurred by letter dated December 12, 2006, that the information 

presented in the Draft Multisale EIS satisfies the EFH consultation procedures 

outlined in 50 CFR 600.920, and as specified in our March 17, 2000, findings. 

Provided MMS proposed mitigations, previous EFH conservation 

recommendations, and the standard lease stipulations and regulations are 

followed as proposed, NMFS agrees that impacts to EFH and associated 

fishery resources resulting from activities conducted under the 2007-2012 lease 

sales would be minimal. Therefore, unless future changes to the proposed 

2007-2012 lease sales are proposed or new information becomes available, no 

further EFH consultation is required for the 2007-2012 lease sales. 

June 28, 2007 The FWS and MMS have consulted informally per FWS guidance. A draft 

copy of the Biological Assessment, prepared by MMS, was submitted as 

requested by FWS (USDOI, MMS, 2007j). On June 28, 2007, MMS received 

oral confirmation from FWS that the consultation will remain informal; 

therefore there will be no new mitigations or Terms and Conditions from FWS. 

The final Biological Assessment and a request for a Letter of Concurrence 

were submitted to Louisiana Field Office of FWS on August 3, 2007. The 

FWS submitted a Letter of Concurrence dated September 14, 2007. 

June 29, 2007 The NMFS BO was signed on June 29, 2007, and has been received by MMS. 

The BO concludes that the proposed lease sales and associated activities in the 

GOM in the 2007-2012 OCS Leasing Program, including Lease Sale 213, are 

not likely to jeopardize the continued existence of threatened and endangered 

species under NMFS jurisdiction, or destroy or adversely modify designated 

critical habitat. The NMFS’s Southeast Regional Office issued an Incidental 

Take Statement on sea turtle species, which contains reasonable and prudent 

measures with implementing terms and conditions to help minimize take. 

Supplemental EIS Process

September 10, 2007 The Call and NOI were published in the Federal Register. The general area of 

the Call only covers the 181 South Area. A 30-day comment period was 

provided for the Call; it closed on October 10, 2007. A 45-day comment 

period was provided for the NOI; it closed on October 25, 2007. The MMS 

received several comment letters in response to the Call and/or the NOI, which 

are summarized Chapter 5.4 of the Supplemental EIS. 
68 Consultation and Coordination

October 9-11, 2007 The MMS held formal scoping meetings in Houston, Texas; Larose and Baton 

Rouge, Louisiana; and Mobile, Alabama. Scoping provides those with an 

interest in the OCS Program an opportunity to provide comments on the 

proposed actions. 

May 13-15, 2008 The MMS held public hearings in Larose and Baton Rouge, Louisiana, and 

Mobile, Alabama, to solicit comments on the Draft Supplemental EIS. 

Attendees at the hearings included representatives from State and local 

governments, interest groups, industry, and the general public. All hearing 

comments received on the Draft Supplemental EIS were considered in the 

preparation of the Final Supplemental EIS. The comments presented at each of 

the public hearings are summarized in Section 5.6 of the Supplemental EIS. 

August 3, 2007 The final Biological Assessment and a request for a Letter of Concurrence 

were submitted to FWS on August 3, 2007. The FWS submitted a Letter of 

Concurrence dated September 14, 2007 (USDOI, FWS, 2007c). The FWS 

concurred with the MMS determination that proposed actions of the 2007-2012 

OCS Leasing Program were not likely to adversely affect the 

threatened/endangered species or designated critical habitat under FWS 

jurisdiction. Sea turtles are under FWS jurisdiction when on a nesting beach. 

The biological assessments prepared by MMS analyzed a typical year of OCS 

activity rather than a typical lease sale and did not exclude the 181 South Area. 

Therefore, concurrence letters will be requested annually from NMFS and 

FWS to determine whether or not the information and analyses in the 

biological assessments and the associated consultations under the ESA are still 

valid. The MMS requested the annual concurrence letters in November 2008. 

Concurrence letters were received from NMFS and the FWS, dated 

December 1, 2008, and December 5, 2008, respectively. 

CPA Lease Sale 213 EA Process

October 9, 2008 On October 9, 2008, MMS published the Call for Information/Notice of 

Preparation of the Lease Sale 213 EA (Call/NOP) in the Federal Register. A 

30-day comment period was provided for the Call; it closed on November 10, 

2008. The MMS requested comments regarding any new information or issues 

that the EA should address by the end of the comment period. A 30-day 

comment period was provided for the NOP; it closed on November 10, 2008. 

The MMS received one comment letter in response to the NOP. The Louisiana 

Department of Natural Resources (LDNR) offered comments requesting a full 

analysis of environmental and hurricane vulnerability matters, requesting upto-date scientific analyses of OCS impacts to coastal Louisiana and expressing 

the need to study sociological and economic impacts of OCS service industries 

moving from one state to another or farther inland after major storm events. 

The LDNR also requested that MMS provide up-to-date, on-the-ground 

impacts analyses and incorporate the analyses in the EA. 
Environmental Assessment 69 

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American Petroleum Institute (API). 2006. Bulletin 2TD, Guidelines for tie-downs on offshore 

production facilities for the hurricane season, first edition. Internet website: http://www.api.org/

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Anderson, C.M. and R.P. LaBelle. 2000. Update of comparative occurrence rates for offshore oil spills. 

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Barras, J.A. 2006. Land area change in coastal Louisiana after the 2005 hurricanes: A series of three 

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Interior, Geological Survey, National Wetlands Research Center, Lafayette, LA. 

Barras, J.A., S. Beville, D. Britsch, S. Hartley, S. Hawes, J. Johnston, P. Kemp, Q. Kinler, A. Martucci, J. 

Porthouse, D. Reed, K. Roy, S. Sapkota, and J. Suhayda. 2003. Historical and projected coastal 

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Louisiana coast. Internet website: http://www.peoplelandandwater.gov/usgs/usgs_02-20-07_usgsreports-latest.cfm. Accessed July 10, 2007. 

U.S. Dept. of the Interior. Geological Survey. 2007d. Gulf of Mexico and southeast tidal wetlands. 

Internet website: http://coastal.er.usgs.gov/wetlands/. Accessed June 27, 2007. 

U.S. Dept. of the Interior. Geological Survey. 2007e. USGS Publications Warehouse. Internet website: 

http://pubs.er.usgs.gov/usgspubs. Accessed June 27, 2007. 
Environmental Assessment 77 

U.S. Dept. of the Interior. Geological Survey. 2008. Coastal change hazards: Hurricanes and extreme 

storms: Hurricane Ike; pre- and post-storm photo comparisons—introduction. Internet website: 

http://coastal.er.usgs.gov/hurricanes/ike/photo-comparisons/index.html. Accessed January 2009. 

U.S. Dept. of the Interior. Minerals Management Service. 2001. Outer continental shelf oil & gas 

leasing program: 2002-2007—draft environmental impact statement. 2 vols. U.S. Dept. of the 

Interior, Minerals Management Service, Herndon, VA. OCS EIS/EA 2001-079. 

U.S. Dept. of the Interior. Minerals Management Service. 2003. Exploration activities in the Eastern 

sale area: Eastern Planning Area, Gulf of Mexico OCS—programmatic environmental assessment. 

U.S. Dept. of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, 

LA. OCS EIS/EA MMS 2003-008. 202 pp. 

U.S. Dept. of the Interior. Minerals Management Service. 2006. Investigations of chemosynthetic 

communities on the lower continental shelf of the Gulf of Mexico. Ongoing study co-funded by U.S. 

Dept. of the Interior, Minerals Management Service and U.S. Dept. of Commerce, NOAA, Office of 

Ocean Exploration. Internet website for the study profile: http://www.gomr.mms.gov/homepg/

regulate/environ/ongoing_studies/gm/GM-05-03.html. Internet website for the Alvin cruise from 

May 7-June 2, 2006: http://oceanexplorer.noaa.gov/explorations/06mexico/welcome.html. 

U.S. Dept. of the Interior. Minerals Management Service. 2007a. Gulf of Mexico OCS oil and gas lease 

sales: 2007-2012; Western Planning Area Sales 204, 207, 210, 215, and 218; Central Planning Area 

Sales 205, 206, 208, 213, 216, and 222—final environmental impact statement. 2 vols. U.S. Dept. of 

the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS 

EIS/EA MMS 2007-018. 

U.S. Dept. of the Interior. Minerals Management Service. 2007b. Outer continental shelf oil and gas 

leasing program, 2007-2012. U.S. Dept. of the Interior, Minerals Management Service, Washington, 

DC. 

U.S. Dept. of the Interior. Minerals Management Service. 2007c. Outer continental shelf oil and gas 

leasing program: 2007-2012—final environmental impact statement. 2 vols. U.S. Dept. of the 

Interior, Minerals Management Service, Herndon, VA. OCS EIS/EA MMS 2007-003. 

U.S. Dept. of the Interior. Minerals Management Service. 2007d. Gulf of Mexico OCS oil and gas 

scenario examination: Exploration and development activity. U.S. Dept. of the Interior, Minerals 

Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Report MMS 2007-052. 

14 pp. 

U.S. Dept. of the Interior. Minerals Management Service. 2007e. Gulf of Mexico OCS oil and gas 

scenario examination: Pipeline landfalls. U.S. Dept. of the Interior, Minerals Management Service, 

Gulf of Mexico OCS Region, New Orleans, LA. OCS Report MMS 2007-053. 5pp. 

U.S. Dept. of Interior. Minerals Management Service. 2007f. Petroleum spills of one barrel or greater 

from Federal Outer Continental Shelf facilities resulting from damages caused by 2005 Hurricanes 

Katrina and Rita including post-hurricane seepage through June 2007. Internet website: http://

www.mms.gov/incidents/PDFs/HurrKatrinaRitaSpillageRev30Jul2007.pdf. Accessed July 30, 2007. 

U.S. Dept. of the Interior. Minerals Management Service. 2007g. Estimated petroleum spillage from 

facilities associated with Federal Outer Continental Shelf (OCS) oil and gas activities resulting from 

damages caused by Hurricanes Rita and Katrina in 2005. U.S. Dept. of the Interior, Minerals 

Management Service, Herndon, VA. Internet website: http://www.mms.gov/incidents/PDFs/

HurrKatrinaRitaSpillageRev25July2007Final.pdf. Accessed August 1, 2007. 

U.S. Dept. of the Interior. Minerals Management Service. 2007h. Minerals Management Service marks 

hurricane season 2007. News Release, August 30, 2007. U.S. Dept. of the Interior, Minerals 

Management Service, Gulf of Mexico Region, New Orleans, LA. Internet website: http://

www.gomr.mms.gov/homepg/whatsnew/newsreal/2007/070530.pdf. 

U.S. Dept. of the Interior. Minerals Management Service. 2007i. Oil-spill risk analysis: Gulf of Mexico 

Outer Continental Shelf (OCS) lease sales, Central Planning Area and Western Planning Area, 2007-
78 References

2012 and Gulfwide OCS Program, 2007-2046. U.S. Dept. of the Interior, Minerals Management 

Service, Washington, DC. OCS Report MMS 2007-040. 

U.S. Dept. of the Interior. Minerals Management Service. 2007j. Biological assessment, USFWS 

consultation, Gulf of Mexico OCS oil and gas lease sales: 2007-2012. U.S. Dept. of the Interior, 

Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. 

U.S. Dept. of the Interior. Minerals Management Service. 2008a. Gulf of Mexico OCS oil and gas lease 

sales: 2009-2012; Central Planning Area Sales 208, 213, 216, and 222; Western Planning Area Sales 

210, 215, and 218—final supplemental environmental impact statement. U.S. Dept. of the Interior, 

Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS EIS/EA MMS 

2008-041. 

U.S. Dept. of the Interior. Minerals Management Service. 2008b. Petroleum spills of one barrel and 

greater from federal outer continental shelf facilities resulting from damages caused by 2005 

Hurricanes Katrina and Rita including post-hurricane seepage through December 2007. Revised 

June 23, 2008. U.S. Dept. of the Interior, Minerals Management Service, Herndon, VA. Internet 

website: http://www.mms.gov/incidents/PDFs/HurrKatrinaRitaSpillageRev23June2008Comb(2.

U.S. Dept. of the Interior. Minerals Management Service. 2009a. Spills >50 barrels. Internet website: 

http://www.mms.gov/incidents/SigPoll2009.htm. Updated October 19, 2009. 

U.S. Dept. of the Interior. Minerals Management Service. 2009b. Site-specific environmental 

assessment for initial exploration plan, Dalmatian South Prospect, De Soto Canyon Blocks 90, 91, 

and 134 (Murphy Exploration and Production Company—USA). U.S. Dept. of the Interior, Minerals 

Management Service, Gulf of Mexico OCS Region, New Orleans, LA. 86 pp. 

U.S. Dept. of the Interior. National Park Service. 2005. November 2005 archeology e-gram. Internet 

website: http://www.nps.gov/archeology/pubs/egrams/0511.pdf. Accessed July 30, 2007. 

U.S. Environmental Protection Agency. 2001. Coastal condition report—EPA-620/R-01/005. Internet 

website: http://www.epa.gov/owow/oceans/nccr/downloads.html. Accessed August 24, 2009. 

U.S. Environmental Protection Agency. 2005. Coastal condition report II—EPA-620/R-03/002. Internet 

website: http://www.epa.gov/owow/oceans/nccr/2005/downloads.html/. Accessed August 24, 2009. 

U.S. Environmental Protection Agency. 2007a. National Estuary Program coastal condition report. U.S. 

Environmental Protection Agency, Office of Water, Office of Research and Development, 

Washington, DC. EPA-842/B-06/001. Internet website: http://www.epa.gov/owow/oceans/nepccr/. 

Accessed February 1, 2008. 

U.S. Environmental Protection Agency. 2007b. USEPA Region 6 NPDES OCS General Permit No. 

GMG290000. Internet website: http://www.epa.gov/earth1r6/6en/w/offshore/permit10012007.pdf

Accessed April 28, 2009. 

U.S. Environmental Protection Agency. 2007c. Oil & gas NPDES permits in the Southeast Region 4. 

Internet website: http://www.epa.gov/Region4/water/permits/oil&gas.html. Accessed July 3, 2007. 

U.S. Environmental Protection Agency. 2007d. Offshore and oil & gas NPDES permits, Region 6. 

Internet website: http://www.epa.gov/Arkansas/6en/w/offshore/home.htm. Accessed July 2, 2007. 

U.S. Environmental Protection Agency. 2008a. National Pollutant Discharge Elimination System 

(NPDES), vessel discharges, final vessel general permit. 5 pp. Internet website: http://

cfpub.epa.gov/npdes/home.cfm?program_id=350. Accessed April, 20, 2009; last updated 

December 15, 2008. 

U.S. Environmental Protection Agency. 2008b. Coastal condition report III—EPA/842-R-08-002. 

Internet website: http://www.epa.gov/owow/oceans/nccr/ Accessed February, 27, 2009. 

U.S. Environmental Protection Agency. 2009a. EPA factsheet, new ozone standard. Internet website: 

http://www.epa.gov/air/ozonepollution/pdfs/2008_03_factsheet.pdf. 
Environmental Assessment 79 

U.S. Environmental Protection Agency. 2009b. 8-hour ozone nonattainment state/area/county report. As 

of March 12, 2009. Internet website: http://www.epa.gov/oar/oaqps/greenbk/gncs.html. 

U.S. Environmental Protection Agency. 2009c. Particulate matter (PM-2.5) nonattainment 

state/area/county report. As of March 12, 2009. Internet website: http://www.epa.gov/oar/oaqps/

greenbk/qnay.html

Veil, J.A., M.G. Puder, D. Elcock, and R.J. Redweik, Jr. 2004. A white paper describing produced water 

from production of crude oil, natural gas, and coal bed methane. Prepared by Argonne National 

Laboratory, Argonne, IL, for the U.S. Department of Energy, National Energy Technology 

Laboratory, Contract W-31-109-Eng-38. 79 pp. Internet website: 

http://www.ead.anl.gov/pub/dsp_detail.cfm?PubID=1715. 

Veil, J., T.A. Kimmell, and A.C. Rechner. 2005. Characteristics of produced water discharged to the 

Gulf of Mexico hypoxic zone. U.S. Dept. of Energy, National Energy Technology Laboratory. 

Velando, A., I. Munilla, and P.M. Leyenda. 2005. Short-term indirect effects of the ‘Prestige’ oil spill on 

European shags: Changes in availability of prey. Marine Ecology Progress Series 302:263-274. 

Vittor, B.A. 2007. SAV and wetlands status and trends in coastal Alabama. Gulf of Mexico Alliance 

Regional Restoration Coordination Team Workshop, Spanish Fort, AL. Internet website: http://

www2.nos.noaa.gov/gomex/restoration/workshops/workshops.html. 

Weaver, D.C., G.D. Dennis III, and K.J. Sulak. 2001. Northeastern Gulf of Mexico coastal and marine 

ecosystem program: Community structure and trophic ecology of demersal fishes on the Pinnacles 

Reef tract; final synthesis report. U.S. Dept. of the Interior, Geological Survey, USGS BSR-2001-

0008 and Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA, OCS Study 

MMS-2002-034. 92 pp. + apps. 

Wells, C. 2008. Scientists: Gustav did damage to wetlands. Article in Baton Rouge Advocate by staff 

writer A. World. (September 7, 2008). Internet website: http://www.2theadvocate.com/news/

27959449.html. 

Wilson, D.L., J.N. Fanjoy, and R.S. Billings. 2004. Gulfwide emission inventory study for the regional 

haze and ozone modeling efforts: Final report. U.S. Dept. of the Interior, Minerals Management 

Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study 2004-072. 273 pp. 

Wilson, D.L., J.N. Fanjoy, and R.S. Billings. 2007. Gulfwide emission inventory study for the regional 

haze and ozone modeling efforts: Final report. U.S. Dept. of the Interior, Minerals Management 

Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study 2007-067. 149 pp. 

Woods & Poole Economics, Inc. 2007. The 2007 complete economic and demographic data source 

(CEDDS) on CD-ROM. 

Woods & Poole Economics, Inc. 2008. The 2008 complete economic and demographic data source 

(CEDDS) on CD-ROM. 

Zimmer, B., L. Duncan, R.B. Aronson, K.J.P. Deslarzes, D. Deis, M. Robbart, W.F. Precht, L. Kaufman, 

B. Shank, E. Weil, J. Field, D.J. Evans, and L. Whaylen. In preparation. Long-term monitoring at 

the East and West Flower Garden Banks, 2004-2008. Volume I: Technical report. U.S. Dept. of the 

Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. 
Environmental Assessment 81 

7. PREPARERS 

Supervisors 

Gary D. Goeke, Chief, Environmental Assessment Section 

Robert Martinson, NEPA/CZM Unit Supervisor, Senior Environmental Scientist 

NEPA Coordination 

Bruce Baird, GOMR NEPA Coordinator, Senior Environmental Scientist 

Keely Hite, Headquarters’ NEPA Coordinator, Environmental Specialist 

Analysts and Professional Staff 

Patrick Adkins, Information Management Specialist 

Dave Ball, Marine Archaeologist 

Robert Cameron, Meteorologist 

Sindey Chaky, Social Scientist 

Carole L. Current, Physical Oceanographer 

Donald (Tre) W. Glenn III, Protected Species Biologist 

Mike Gravois, Geographer 

Larry M. Hartzog, Environmental Scientist 

Nancy M. Kornrumpf, Program Analyst 

Daniel (Herb) Leedy, Supervisor, Biological Sciences Unit 

Harry Luton, Social Scientist 

Margaret Metcalf, Physical Scientist 

Deborah H. Miller, Technical Publications Editor 

Tara Montgomery, Supervisor, Mapping and Automation Unit 

Carol Roden, Protected Species Biologist 

Catherine A. Rosa, Environmental Assessment Program Specialist 

Casey Rowe, Senior Environmental Scientist 

James Sinclair, Marine Biologist 

Kristen L. Strellec, Economist 
The Department of the Interior Mission

As the Nation's principal conservation agency, the Department of the Interior has responsibility 

for most of our nationally owned public lands and natural resources. This includes fostering 

sound use of our land and water resources; protecting our fish, wildlife, and biological diversity; 

preserving the environmental and cultural values of our national parks and historical places; 

and providing for the enjoyment of life through outdoor recreation. The Department assesses 

our energy and mineral resources and works to ensure that their development is in the best 

interests of all our people by encouraging stewardship and citizen participation in their care. 

The Department also has a major responsibility for American Indian reservation communities 

and for people who live in island territories under U.S. administration. 

The Minerals Management Service Mission 

As a bureau of the Department of the Interior, the Minerals Management Service's (MMS) 

primary responsibilities are to manage the mineral resources located on the Nation's Outer 

Continental Shelf (OCS), collect revenue from the Federal OCS and onshore Federal and Indian 

lands, and distribute those revenues. 

Moreover, in working to meet its responsibilities, the Offshore Minerals Management Program 

administers the OCS competitive leasing program and oversees the safe and environmentally 

sound exploration and production of our Nation's offshore natural gas, oil and other mineral 

resources. The MMS Minerals Revenue Management meets its responsibilities by ensuring the 

efficient, timely and accurate collection and disbursement of revenue from mineral leasing and 

production due to Indian tribes and allottees, States and the U.S. Treasury. 

The MMS strives to fulfill its responsibilities through the general guiding principles of: (1) being 

responsive to the public's concerns and interests by maintaining a dialogue with all potentially 

affected parties and (2) carrying out its programs with an emphasis on working to enhance the 

quality of life for all Americans by lending MMS assistance and expertise to economic 

development and environmental protection.