U.S. Department of the Interior

Bureau of Ocean Energy Management

Gulf of Mexico OCS Region

OCS EIS/EA

BOEM 2017-009

Gulf of Mexico OCS 

Oil and Gas Lease Sales: 2017-2022

Gulf of Mexico Lease Sales 249, 250, 251, 252, 253, 

254, 256, 257, 259, and 261

Final Multisale Environmental Impact Statement

Volume III: Appendices and Keyword Index

U.S. Department of the Interior

Bureau of Ocean Energy Management Gulf of Mexico OCS Region

OCS EIS/EA

BOEM 2017-009

Gulf of Mexico OCS 

Oil and Gas Lease Sales: 2017-2022

Gulf of Mexico Lease Sales 249, 250, 251, 252, 253, 

254, 256, 257, 259, and 261

Final Multisale Environmental Impact Statement

Volume III: Appendices and Keyword Index

Author

Bureau of Ocean Energy Management

Gulf of Mexico OCS Region

Published by

New Orleans

March 2017

Table of Contents iii

TABLE OF CONTENTS

Volume I

Page

EXECUTIVE SUMMARY ..................................................................................................................... vii

LIST OF FIGURES................................................................................................................................liii

LIST OF TABLES................................................................................................................................lxiii

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

CONVERSION CHART ....................................................................................................................lxxiii

1 PURPOSE OF AND NEED FOR THE PROPOSED ACTIONS..................................................... 1-3

1.0 Introduction............................................................................................................................. 1-3

1.1 Purpose of the Proposed Actions........................................................................................... 1-5

1.2 Need for the Proposed Actions .............................................................................................. 1-5

1.3 OCS Oil and Gas Program Planning and Decision Process ................................................. 1-7

1.3.1 Prelease Process....................................................................................................... 1-7

1.3.1.1 Five-Year Program of Proposed OCS Lease Sales .................................. 1-8

1.3.1.2 Individual Lease Sale Consultation and Decision Process...................... 1-10

1.3.2 Gulf of Mexico Postlease Activities.......................................................................... 1-12

1.4 The Decision To Be Made.................................................................................................... 1-13

1.5 Regulatory Framework ......................................................................................................... 1-13

1.6 Other OCS Oil- and Gas-Related Activities ......................................................................... 1-15

1.7 Other Pertinent Environmental Reviews or Documentation ................................................ 1-18

1.8 Format and Organization of the Multisale EIS ..................................................................... 1-22

2 ALTERNATIVES INCLUDING THE PROPOSED ACTIONS......................................................... 2-3

2.0 Introduction............................................................................................................................. 2-3

2.1 Multisale NEPA Analysis ........................................................................................................ 2-4

2.2 Alternatives, Mitigating Measures, and Issues....................................................................... 2-5

2.2.1 What is the 2017-2022 Proposed Lease Sale Schedule?......................................... 2-5

2.2.2 What are the Alternatives that BOEM is Considering for Each Proposed 

Lease Sale? ............................................................................................................... 2-6

2.2.2.1 Alternative A—Regionwide OCS Lease Sale (The Preferred 

Alternative) ................................................................................................. 2-6

2.2.2.2 Alternative B—Regionwide OCS Lease Sale Excluding Available 

Unleased Blocks in the WPA Portion of the Proposed Lease Sale 

Area ............................................................................................................ 2-8

2.2.2.3 Alternative C—Regionwide OCS Lease Sale Excluding Available 

Unleased Blocks in the CPA/EPA Portions of the Proposed Lease 

Sale Area.................................................................................................... 2-9

2.2.2.4 Alternative D—Alternative A, B, or C, with the Option to Exclude 

Available Unleased Blocks Subject to the Topographic Features, 

Live Bottom (Pinnacle Trend), and/or Blocks South of Baldwin County, 

Alabama, Stipulations............................................................................... 2-10

2.2.2.5 Alternative E—No Action.......................................................................... 2-13
iv Gulf of Mexico Multisale EIS

2.2.3 What Other Alternatives and Deferrals have BOEM Considered but 

Not Analyzed in Detail?............................................................................................ 2-14

2.2.4 What Types of Mitigating Measures Does BOEM Apply? ....................................... 2-23

2.2.4.1 Proposed Lease Mitigating Measures (Stipulations) ............................... 2-24

2.2.4.2 Prelease Mitigating Measures (Stipulations) by Alternative .................... 2-28

2.2.4.3 Postlease Mitigating Measures ................................................................ 2-29

2.2.5 What are the Primary Topics and Resources Being Evaluated? ............................ 2-31

2.2.5.1 Issues to be Analyzed .............................................................................. 2-31

2.2.5.2 Issues Considered but Not Analyzed....................................................... 2-34

2.3 Comparison of Impacts by Alternative ................................................................................. 2-35

2.4 Summary of Impacts............................................................................................................. 2-37

2.4.1 Air Quality................................................................................................................. 2-37

2.4.2 Water Quality ........................................................................................................... 2-39

2.4.3 Coastal Habitats....................................................................................................... 2-39

2.4.3.1 Estuarine Systems (Wetlands and Seagrasses/Submerged 

Vegetation) ............................................................................................... 2-39

2.4.3.2 Coastal Barrier Beaches and Associated Dunes..................................... 2-40

2.4.4 Deepwater Benthic Communities ............................................................................ 2-41

2.4.5 Sargassum and Associated Communities............................................................... 2-41

2.4.6 Live Bottoms ............................................................................................................ 2-42

2.4.6.1 Topographic Features .............................................................................. 2-42

2.4.6.2 Pinnacles and Low-Relief Features ......................................................... 2-42

2.4.7 Fish and Invertebrate Resources............................................................................. 2-43

2.4.8 Birds ......................................................................................................................... 2-44

2.4.9 Protected Species.................................................................................................... 2-44

2.4.9.1 Marine Mammals...................................................................................... 2-44

2.4.9.2 Sea Turtles ............................................................................................... 2-45

2.4.9.3 Beach Mice............................................................................................... 2-46

2.4.9.4 Protected Birds......................................................................................... 2-46

2.4.9.5 Protected Corals....................................................................................... 2-47

2.4.10 Commercial Fisheries .............................................................................................. 2-47

2.4.11 Recreational Fishing ................................................................................................ 2-48

2.4.12 Recreational Resources........................................................................................... 2-48

2.4.13 Archaeological Resources ....................................................................................... 2-49

2.4.14 Human Resources and Land Use (Including Environmental Justice)..................... 2-50

2.4.14.1 Land Use and Coastal Infrastructure ....................................................... 2-50

2.4.14.2 Economic Factors..................................................................................... 2-50

2.4.14.3 Social Factors (Including Environmental Justice).................................... 2-51

3 IMPACT-PRODUCING FACTORS AND SCENARIO.................................................................... 3-3

3.0 Introduction............................................................................................................................. 3-3

3.1 Impact -Producing Factors and Scenario—Routine Operations............................................ 3-6

3.1.1 Resource Estimates and Timetables......................................................................... 3-6

3.1.2 Exploration and Delineation..................................................................................... 3-11

3.1.2.1 Geological and Geophysical Surveys ...................................................... 3-11

3.1.2.2 Exploration and Delineation Plans and Drilling........................................ 3-17

3.1.3 Offshore Development and Production.................................................................... 3-22

3.1.3.1 Development and Production Drilling....................................................... 3-22

3.1.3.2 Offshore Production Systems .................................................................. 3-29
Table of Contents v 

3.1.3.3 Infrastructure Emplacement/Structure Installation and Commissioning 

Activities ................................................................................................... 3-33

3.1.3.3.1 Pipelines ................................................................................ 3-37

3.1.3.3.2 Bottom-Area Disturbance ...................................................... 3-42

3.1.3.3.3 Sediment Displacement......................................................... 3-44

3.1.3.3.4 Navigation Channels ............................................................. 3-45

3.1.3.4 Infrastructure Presence............................................................................ 3-50

3.1.3.4.1 Anchoring............................................................................... 3-50

3.1.3.4.2 Space-Use Requirements ..................................................... 3-50

3.1.3.4.3 Structure Lighting .................................................................. 3-51

3.1.3.5 Workovers and Abandonments................................................................ 3-52

3.1.4 Transport.................................................................................................................. 3-53

3.1.4.1 Barges ...................................................................................................... 3-53

3.1.4.2 Oil Tankers ............................................................................................... 3-53

3.1.4.3 Service Vessels........................................................................................ 3-55

3.1.4.4 Helicopters................................................................................................ 3-56

3.1.5 Discharges and and Wastes.................................................................................... 3-58

3.1.5.1 Operational Wastes and Discharges Generated by OCS Oil- and 

Gas-Related Facilities .............................................................................. 3-58

3.1.5.1.1 Drilling Muds and Cuttings..................................................... 3-62

3.1.5.1.2 Produced Waters................................................................... 3-66

3.1.5.1.3 Well-Treatment, Workover, and Completion Fluids .............. 3-69

3.1.5.1.4 Production Solids and Equipment ......................................... 3-70

3.1.5.1.5 Bilge, Ballast, and Fire Water................................................ 3-71

3.1.5.1.6 Cooling Water........................................................................ 3-71

3.1.5.1.7 Deck Drainage....................................................................... 3-72

3.1.5.1.8 Treated Domestic and Sanitary Wastes................................ 3-72

3.1.5.1.9 Minor/Miscellaneous Discharges........................................... 3-73

3.1.5.2 Operational Wastes and Discharges Generated by Service Vessels ..... 3-73

3.1.5.3 Onshore Disposal of Waste and Discharge Generated Offshore or 

Onshore.................................................................................................... 3-74

3.1.5.3.1 Onshore Disposal of Wastes Generated from OCS Oiland Gas-Related Facilities .................................................... 3-74

3.1.5.3.2 Onshore Disposal and Storage Facilities Supporting 

OCS-Generated Operational Wastes.................................... 3-75

3.1.5.3.3 Discharges from Onshore Support Facilities......................... 3-76

3.1.6 Decommissioning and Removal Operations ........................................................... 3-76

3.1.6.1 Structure Age and Idle Iron ...................................................................... 3-79

3.1.6.2 Artificial Reefs........................................................................................... 3-81

3.1.7 Coastal Infrastructure............................................................................................... 3-81

3.1.7.1 Construction Facilities .............................................................................. 3-84

3.1.7.1.1 Platform Fabrication Yards.................................................... 3-84

3.1.7.1.2 Shipbuilding and Shipyards................................................... 3-84

3.1.7.1.3 Pipe-Coating Facilities and Yards ......................................... 3-85

3.1.7.2 Support Facilities and Transportation ...................................................... 3-86

3.1.7.2.1 Service Bases and Ports ....................................................... 3-86

3.1.7.2.2 Helicopter Hubs ..................................................................... 3-88

3.1.7.2.3 Tanker Port Areas ................................................................. 3-88

3.1.7.2.4 Barge Terminals .................................................................... 3-89

3.1.7.2.5 Pipeline Shore Facilities ........................................................ 3-89

3.1.7.2.6 Waste Disposal Facilities....................................................... 3-89

3.1.7.2.7 Natural Gas Storage Facilities............................................... 3-90
vi Gulf of Mexico Multisale EIS

3.1.7.3 Processing Facilities................................................................................. 3-90

3.1.7.3.1 Gas Processing Plants .......................................................... 3-90

3.1.7.3.2 Refineries............................................................................... 3-91

3.1.7.3.3 Onshore Liquefied Natural Gas Facilities.............................. 3-91

3.1.7.3.4 Petrochemical Plants............................................................. 3-92

3.1.8 Air Emissions ........................................................................................................... 3-92

3.1.8.1 Drilling....................................................................................................... 3-94

3.1.8.2 Production ................................................................................................ 3-94

3.1.8.3 Vessel Support Operations and Activities during Offshore Oil and 

Gas Activities............................................................................................ 3-94

3.1.8.4 Flaring and Venting .................................................................................. 3-95

3.1.8.5 Fugitive Emissions ................................................................................... 3-96

3.1.8.6 Greenhouse Gases .................................................................................. 3-96

3.1.8.7 Decommissioning..................................................................................... 3-96

3.1.9 Noise ........................................................................................................................ 3-96

3.1.10 New and Unusual Technology................................................................................. 3-99

3.2 Impact-Producing Factors and Scenario—Accidental Events ...........................................3-101

3.2.1 Oil Spills .................................................................................................................3-101

3.2.1.1 Past OCS Spills......................................................................................3-101

3.2.1.1.1. Trends in Reported Spill Volumes and Numbers................3-101

3.2.1.1.2 Coastal Spills.......................................................................3-106

3.2.1.1.3 Offshore Spills .....................................................................3-110

3.2.1.2 Characteristics of OCS Oil .....................................................................3-116

3.2.1.3 Transport and Fate of Offshore Spills....................................................3-117

3.2.1.4 Analysis of Offshore Spills ≥1,000 bbl ...................................................3-120

3.2.1.4.1 Overview of Spill Risk Analysis ...........................................3-120

3.2.1.4.2 Trajectory Modeling for Offshore Spills ≥1,000 bbl .............3-121

3.2.1.4.3 Estimated Number of Offshore Spills ≥1,000 bbl and 

Probability of Occurrence....................................................3-123

3.2.1.4.4 Most Likely Source of Offshore Spills ≥1,000 bbl ...............3-125

3.2.1.4.5 Most Likely Size of an Offshore Spill ≥1,000 bbl.................3-125

3.2.1.4.6 Length of Coastline Affected by Offshore Spills 

≥1,000 bbl ............................................................................3-125

3.2.1.4.7 Risk Analysis by Resource..................................................3-126

3.2.1.4.8 Likelihood of an Offshore Spill ≥1,000 bbl Occurring and 

Contacting Coastal and Offshore Areas..............................3-126

3.2.1.5 Analysis of Offshore Spills <1,000 bbl ...................................................3-127

3.2.1.5.1 Estimated Number of Offshore Spills <1,000 bbl and 

Total Volume of Oil Spilled..................................................3-127

3.2.1.5.2 Most Likely Source and Type of Offshore Spills 

<1,000 bbl............................................................................3-127

3.2.1.5.3 Most Likely Size of Offshore Spills <1,000 bbl....................3-127

3.2.1.5.4 Likelihood of an Offshore Spill <1,000 bbl Occurring and 

Contacting Coastal and Offshore Areas..............................3-127

3.2.1.6 Analysis of Coastal Spills.......................................................................3-128

3.2.1.6.1 Estimated Number and Most Likely Sizes of Coastal 

Spills ....................................................................................3-128

3.2.1.6.2 Likelihood of Coastal Spill Contact......................................3-128

3.2.2 Losses of Well Control...........................................................................................3-129

3.2.3 Accidental Air Emissions........................................................................................3-132

3.2.3.1 Hydrogen Sulfide and Sulfurous Petroleum...........................................3-132

3.2.4 Pipeline Failures.....................................................................................................3-134

3.2.5 Vessel and Helicopter Collisions ...........................................................................3-135
Table of Contents vii

3.2.6 Chemical and Drilling-Fluid Spills ..........................................................................3-137

3.2.7 Trash and Debris....................................................................................................3-138

3.2.8 Spill Response .......................................................................................................3-139

3.2.8.1 BSEE Spill-Response Requirements and Initiatives..............................3-139

3.2.8.1.1 Spill-Response Requirements.............................................3-139

3.2.8.1.2 Spill-Response Initiatives ....................................................3-141

3.2.8.2 Offshore Response, Containment, and Cleanup Technology ...............3-141

3.2.8.2.1 Mechanical Cleanup............................................................3-144

3.2.8.2.2 Spill Treating Agents ...........................................................3-147

3.2.8.2.3 In-situ Burning......................................................................3-150

3.2.8.2.4 Natural Dispersion...............................................................3-150

3.2.8.3 Onshore Response and Cleanup...........................................................3-151

3.3 Cumulative Impacts ............................................................................................................3-157

3.3.1 Cumulative OCS Oil and Gas Program Scenario..................................................3-157

3.3.1.1 Cumulative OCS Oil and Gas Program Projected Production...............3-159

3.3.1.2 Cumulative Geological and Geophysical Surveys .................................3-160

3.3.1.3 Cumulative Exploration and Delineation Plans and Drilling...................3-161

3.3.1.4 Cumulative Development and Production Drilling .................................3-161

3.3.1.5 Infrastructure Emplacement/Structure Installation and 

Decommissioning Activities....................................................................3-162

3.3.1.6 Infrastructure Presence..........................................................................3-163

3.3.1.7 Transport................................................................................................3-164

3.3.1.8 Discharges and Wastes .........................................................................3-165

3.3.1.9 Decommissioning and Removal Operations..........................................3-165

3.3.1.10 Coastal Infrastructure.............................................................................3-165

3.3.1.11 Air Emissions..........................................................................................3-165

3.3.2 Non-OCS Oil- and Gas-Related Impact-Producing Factors..................................3-166

3.3.2.1 State Oil and Gas Activity ......................................................................3-166

3.3.2.1.1 State Pipeline Infrastructure ................................................3-168

3.3.2.1.2 Artificial Reefs......................................................................3-168

3.3.2.2 Marine Vessel Activity ............................................................................3-169

3.3.2.3 Non-OCS Oil- and Gas-Related Wastes and Discharges .....................3-171

3.3.2.3.1 Potentially Polluting Shipwrecks..........................................3-171

3.3.2.3.2 Discharges Associated with Military Activities.....................3-172

3.3.2.3.3 Historical Chemical Weapon Disposal Areas......................3-173

3.3.2.3.4 Historical Industrial Waste Dumping Areas.........................3-174

3.3.2.3.5 Dredged Material Disposal..................................................3-174

3.3.2.3.6 Land-Based Discharges ......................................................3-177

3.3.2.3.7 Trash and Debris .................................................................3-177

3.3.2.4 Non-OCS Oil- and Gas-Related Spills...................................................3-178

3.3.2.5 Non-OCS Oil- and Gas- Related Air Emissions.....................................3-181

3.3.2.6 Other Non-OCS Oil- and Gas-Related Activities ...................................3-181

3.3.2.6.1 Military Warning and Water Test Areas ..............................3-181

3.3.2.6.2 Offshore Deepwater Ports and Nearshore Liquefied 

Natural Gas Terminals.........................................................3-182

3.3.2.6.3 Development of Gas Hydrates ............................................3-184

3.3.2.6.4 Renewable Energy and Alternative Use .............................3-185

3.3.2.6.5 Aquaculture..........................................................................3-187

3.3.2.6.6 OCS Sand Borrowing ..........................................................3-188

3.3.2.7 Noise from Non-OCS Oil- and Gas-Related Sources............................3-191
viii Gulf of Mexico Multisale EIS

3.3.2.8 Coastal Environments ............................................................................3-193

3.3.2.8.1 Sea-Level Rise and Subsidence .........................................3-193

3.3.2.8.2 Erosion.................................................................................3-196

3.3.2.8.3 Coastal Restoration Programs ............................................3-196

3.3.2.8.4 Saltwater Intrusion...............................................................3-203

3.3.2.8.5 Maintenance Dredging and Federal Channels....................3-204

3.3.2.9 Natural Events and Processes...............................................................3-206

3.3.2.9.1 Physical Oceanography.......................................................3-206

3.3.2.9.2 Natural Seeps ......................................................................3-207

3.3.2.9.3 Hurricanes ...........................................................................3-207

3.3.2.9.4 Climate Change...................................................................3-209

3.3.2.10 Mississippi River Hydromodification ......................................................3-209

3.3.2.11 Mississippi River Eutrophication ............................................................3-210

3.3.2.12 Hypoxia...................................................................................................3-211

3.3.2.13 Sedimentation.........................................................................................3-212
Table of Contents ix

Volume II 

Page

LIST OF FIGURES.............................................................................................................................. xxi

LIST OF TABLES...............................................................................................................................xxxi

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT AND IMPACT ANALYSIS....................... 4-3

4.0 Overview................................................................................................................................. 4-3

4.0.1 What Encompasses the Affected Environment for a Gulf of Mexico Lease Sale? ... 4-5

4.0.2 How are the Potential Environmental Consequences Determined? ......................... 4-6

4.0.2.1 Routine Activities........................................................................................ 4-9

4.0.2.2 Accidental Events....................................................................................... 4-9

4.0.2.3 Cumulative Impacts.................................................................................... 4-9

4.0.2.4 Incomplete or Unavailable Information .................................................... 4-10

4.0.2.5 Alternative A ............................................................................................. 4-11

4.0.2.6 Alternative B ............................................................................................. 4-11

4.0.2.7 Alternative C............................................................................................. 4-12

4.0.2.8 Alternative D............................................................................................. 4-12

4.0.2.9 Alternative E ............................................................................................. 4-12

4.1 Air Quality ............................................................................................................................. 4-13

4.1.1 Description of the Affected Environment ................................................................. 4-16

4.1.2 Environmental Consequences................................................................................. 4-24

4.1.2.1 Routine Activities...................................................................................... 4-27

4.1.2.2 Accidental Events..................................................................................... 4-30

4.1.2.3 Cumulative Impacts.................................................................................. 4-33

4.1.2.3.1 Impacts Assessment ............................................................. 4-38

4.1.2.4 Incomplete or Unavailable Information .................................................... 4-51

4.1.2.5 Alternative A—Regionwide OCS Lease Sale (The Preferred 

Alternative) ............................................................................................... 4-52

4.1.2.6 Alternative B—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the WPA Portion of the Proposed 

Lease Sale Area....................................................................................... 4-52

4.1.2.7 Alternative C—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the CPA/EPA Portions of the Proposed 

Lease Sale Area....................................................................................... 4-53

4.1.2.8 Alternative D—Alternative A, B, or C, with the Option to Exclude 

Available Unleased Blocks Subject to the Topographic Features, 

Live Bottom (Pinnacle Trend), and/or Blocks South of Baldwin 

County, Alabama, Stipulations ................................................................. 4-53

4.1.2.9 Alternative E—No Action.......................................................................... 4-53

4.2 Water Quality........................................................................................................................ 4-53

4.2.1 Description of the Affected Environment ................................................................. 4-56

4.2.2 Environmental Consequences................................................................................. 4-58

4.2.2.1 Routine Activities...................................................................................... 4-58

4.2.2.2 Accidental Events..................................................................................... 4-63

4.2.2.3 Cumulative Impacts.................................................................................. 4-64

4.2.2.4 Incomplete or Unavailable Information .................................................... 4-67

4.2.2.5 Alternative A—Regionwide OCS Lease Sale (The Preferred 

Alternative) ............................................................................................... 4-67
x Gulf of Mexico Multisale EIS

4.2.2.6 Alternative B—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the WPA Portion of the Proposed 

Lease Sale Area....................................................................................... 4-68

4.2.2.7 Alternative C—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the CPA/EPA Portions of the Proposed 

Lease Sale Area....................................................................................... 4-68

4.2.2.8 Alternative D—Alternative A, B, or C, with the Option to Exclude 

Available Unleased Blocks Subject to the Topographic Features, 

Live Bottom (Pinnacle Trend), and/or Blocks South of Baldwin 

County, Alabama, Stipulations ................................................................. 4-69

4.2.2.9 Alternative E—No Action.......................................................................... 4-69

4.3 Coastal Habitats ................................................................................................................... 4-69

4.3.1 Estuarine Systems (Wetlands and Seagrass/Submerged Vegetation)................... 4-69

4.3.1.1 Description of the Affected Environment.................................................. 4-71

4.3.1.1.1 Wetlands................................................................................ 4-71

4.3.1.1.2 Submerged Aquatic Vegetation............................................. 4-74

4.3.1.2 Environmental Consequences ................................................................. 4-76

4.3.1.2.1 Routine Activities ................................................................... 4-76

4.3.1.2.2 Accidental Events .................................................................. 4-79

4.3.1.2.3 Cumulative Impacts ............................................................... 4-84

4.3.1.2.4 Incomplete or Unavailable Information.................................. 4-93

4.3.1.2.5 Alternative A—Regionwide OCS Lease Sale (The 

Preferred Alternative) ............................................................ 4-94

4.3.1.2.6 Alternative B—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the WPA Portion 

of the Proposed Lease Sale Area ......................................... 4-95

4.3.1.2.7 Alternative C—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the CPA/EPA 

Portions of the Proposed Lease Sale Area........................... 4-95

4.3.1.2.8 Alternative D—Alternative D—Alternative A, B, or C, 

with the Option to Exclude Available Unleased Blocks 

Subject to the Topographic Features, Live Bottom 

(Pinnacle Trend), and/or Blocks South of Baldwin County, 

Alabama, Stipulations............................................................ 4-96

4.3.1.2.9 Alternative E—No Action....................................................... 4-96

4.3.2 Coastal Barrier Beaches and Associated Dunes..................................................... 4-96

4.3.2.1 Description of the Affected Environment.................................................. 4-98

4.3.2.2 Environmental Consequences ...............................................................4-102

4.3.2.2.1 Routine Activities .................................................................4-102

4.3.2.2.2 Accidental Events ................................................................4-104

4.3.2.2.3 Cumulative Impacts .............................................................4-106

4.3.2.2.4 Incomplete or Unavailable Information................................4-112

4.3.2.2.5 Alternative A—Regionwide OCS Lease Sale (The 

Preferred Alternative) ..........................................................4-113

4.3.2.2.6 Alternative B—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the WPA Portion 

of the Proposed Lease Sale Area .......................................4-114

4.3.2.2.7 Alternative C—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the CPA/EPA 

Portions of the Proposed Lease Sale Area.........................4-114
Table of Contents xi

4.3.2.2.8 Alternative D—Alternative D—Alternative A, B, or C, 

with the Option to Exclude Available Unleased Blocks 

Subject to the Topographic Features, Live Bottom 

(Pinnacle Trend), and/or Blocks South of Baldwin County, 

Alabama, Stipulations..........................................................4-114

4.3.2.2.9 Alternative E—No Action.....................................................4-115

4.4 Deepwater Benthic Communities.......................................................................................4-115

4.4.1 Description of the Affected Environment ...............................................................4-121

4.4.1.1 Chemosynthetic Communities ...............................................................4-123

4.4.1.2 Deepwater Coral Communities ..............................................................4-127

4.4.2 Environmental Consequences...............................................................................4-129

4.4.2.1 Routine Activities....................................................................................4-129

4.4.2.2 Accidental Events...................................................................................4-133

4.4.2.3 Cumulative Impacts................................................................................4-137

4.4.2.4 Incomplete or Unavailable Information ..................................................4-140

4.4.2.5 Alternative A—Regionwide OCS Lease Sale (The Preferred 

Alternative) .............................................................................................4-141

4.4.2.6 Alternative B—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the WPA Portion of the Proposed 

Lease Sale Area.....................................................................................4-142

4.4.2.7 Alternative C—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the CPA/EPA Portions of the Proposed 

Lease Sale Area.....................................................................................4-143

4.4.2.8 Alternative D—Alternative A, B, or C, with the Option to Exclude 

Available Unleased Blocks Subject to the Topographic Features, 

Live Bottom (Pinnacle Trend), and/or Blocks South of Baldwin 

County, Alabama, Stipulations ...............................................................4-144

4.4.2.9 Alternative E—No Action........................................................................4-144

4.5 Sargassum and Associated Communities .........................................................................4-145

4.5.1 Description of the Affected Environment ...............................................................4-149

4.5.2 Environmental Consequences...............................................................................4-152

4.5.2.1 Routine Activities....................................................................................4-153

4.5.2.2 Accidental Events...................................................................................4-154

4.5.2.3 Cumulative Impacts................................................................................4-156

4.5.2.4 Incomplete or Unavailable Information ..................................................4-159

4.5.2.5 Alternative A—Regionwide OCS Lease Sale (The Preferred 

Alternative) .............................................................................................4-160

4.5.2.6 Alternative B—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the WPA Portion of the Proposed 

Lease Sale Area.....................................................................................4-160

4.5.2.7 Alternative C—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the CPA/EPA Portions of the Proposed 

Lease Sale Area.....................................................................................4-161

4.5.2.8 Alternative D—Alternative A, B, or C, with the Option to Exclude 

Available Unleased Blocks Subject to the Topographic Features, 

Live Bottom (Pinnacle Trend), and/or Blocks South of Baldwin 

County, Alabama, Stipulations ...............................................................4-161

4.5.2.9 Alternative E—No Action........................................................................4-161
xii Gulf of Mexico Multisale EIS

4.6 Live Bottom Habitats ..........................................................................................................4-161

4.6.1 Topographic Features and Associated Communities............................................4-163

4.6.1.1 Description of the Affected Environment................................................4-167

4.6.1.2 Environmental Consequences ...............................................................4-172

4.6.1.2.1 Routine Activities .................................................................4-172

4.6.1.2.2 Accidental Events ................................................................4-174

4.6.1.2.3 Cumulative Impacts .............................................................4-178

4.6.1.2.4 Incomplete or Unavailable Information................................4-180

4.6.1.2.5 Alternative A—Regionwide OCS Lease Sale (The 

Preferred Alternative) ..........................................................4-182

4.6.1.2.6 Alternative B—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the WPA Portion 

of the Proposed Lease Sale Area .......................................4-183

4.6.1.2.7 Alternative C—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the CPA/EPA 

Portions of the Proposed Lease Sale Area.........................4-183

4.6.1.2.8 Alternative D—Alternative A, B, or C, with the Option 

to Exclude Available Unleased Blocks Subject to the 

Topographic Features, Live Bottom (Pinnacle Trend), 

and/or Blocks South of Baldwin County, Alabama, 

Stipulations ..........................................................................4-184

4.6.1.2.9 Alternative E—No Action.....................................................4-184

4.6.2 Pinnacles and Low-Relief Features and Associated Communities.......................4-185

4.6.2.1 Description of the Affected Environment................................................4-190

4.6.2.2 Environmental Consequences ...............................................................4-196

4.6.2.2.1 Routine Activities .................................................................4-196

4.6.2.2.2 Accidental Events ................................................................4-199

4.6.2.2.3 Cumulative Impacts .............................................................4-203

4.6.2.2.4 Incomplete or Unavailable Information................................4-207

4.6.2.2.5 Alternative A—Regionwide OCS Lease Sale (The 

Preferred Alternative) ..........................................................4-208

4.6.2.2.6 Alternative B—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the WPA Portion 

of the Proposed Lease Sale Area .......................................4-209

4.6.2.2.7 Alternative C—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the CPA/EPA 

Portions of the Proposed Lease Sale Area.........................4-210

4.6.2.2.8 Alternative D—Alternative A, B, or C, with the Option 

to Exclude Available Unleased Blocks Subject to the 

Topographic Features, Live Bottom (Pinnacle Trend), 

and/or Blocks South of Baldwin County, Alabama, 

Stipulations ..........................................................................4-211

4.6.2.2.9 Alternative E—No Action.....................................................4-212

4.7 Fishes and Invertebrate Resources ...................................................................................4-213

4.7.1 Description of the Affected Environment ...............................................................4-216

4.7.2 Environmental Consequences...............................................................................4-221

4.7.2.1 Routine Activities....................................................................................4-221

4.7.2.2 Accidental Events...................................................................................4-226

4.7.2.3 Cumulative Impacts................................................................................4-227

4.7.2.4 Incomplete or Unavailable Information ..................................................4-231

4.7.2.5 Alternatives A, B, C, and D ....................................................................4-231

4.7.2.6 Alternative E—No Action........................................................................4-232
Table of Contents xiii

4.8 Birds....................................................................................................................................4-232

4.8.1 Description of the Affected Environment ...............................................................4-235

4.8.2 Environmental Consequences...............................................................................4-245

4.8.2.1 Routine Activities....................................................................................4-245

4.8.2.2 Accidental Events...................................................................................4-247

4.8.2.3 Cumulative Impacts................................................................................4-249

4.8.2.4 Incomplete or Unavailable Information ..................................................4-254

4.8.2.5 Alternative A—Regionwide OCS Lease Sale (The Preferred 

Alternative) .............................................................................................4-254

4.8.2.6 Alternative B—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the WPA Portion of the Proposed 

Lease Sale Area.....................................................................................4-256

4.8.2.7 Alternative C—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the CPA/EPA Portions of the Proposed 

Lease Sale Area.....................................................................................4-257

4.8.2.8 Alternative D—Alternative A, B, or C, with the Option to Exclude 

Available Unleased Blocks Subject to the Topographic Features, 

Live Bottom (Pinnacle Trend), and/or Blocks South of Baldwin 

County, Alabama, Stipulations ...............................................................4-258

4.8.2.9 Alternative E—No Action........................................................................4-259

4.9 Protected Species ..............................................................................................................4-259

4.9.1 Marine Mammals....................................................................................................4-265

4.9.1.1 Description of the Affected Environment................................................4-266

4.9.1.2 Environmental Consequences ...............................................................4-278

4.9.1.2.1 Routine Activities .................................................................4-279

4.9.1.2.2 Accidental Events ................................................................4-289

4.9.1.2.3 Cumulative Impacts .............................................................4-297

4.9.1.2.4 Incomplete or Unavailable Information................................4-303

4.9.1.2.5 Alternatives A, B, C, and D..................................................4-306

4.9.1.2.6 Alternative E—No Action.....................................................4-308

4.9.2 Sea Turtles.............................................................................................................4-308

4.9.2.1 Description of the Affected Environment................................................4-308

4.9.2.2 Environmental Consequences ...............................................................4-318

4.9.2.2.1 Routine Activities .................................................................4-319

4.9.2.2.2 Accidental Events ................................................................4-324

4.9.2.2.3 Cumulative Impacts .............................................................4-329

4.9.2.2.4 Incomplete or Unavailable Information................................4-334

4.9.2.2.5 Alternatives A, B, C, and D..................................................4-335

4.9.2.2.6 Alternative E—No Action.....................................................4-336

4.9.3 Beach Mice (Alabama, Choctawhatchee, Perdido Key, and St. Andrew).............4-336

4.9.3.1 Description of the Affected Environment................................................4-337

4.9.3.2 Environmental Consequences ...............................................................4-337

4.9.3.2.1 Routine Activities .................................................................4-338

4.9.3.2.2 Accidental Events ................................................................4-338

4.9.3.2.3 Cumulative Impacts .............................................................4-339

4.9.3.2.4 Incomplete or Unavailable Information................................4-340

4.9.3.2.5 Alternative A—Regionwide OCS Proposed Lease Sale 

(The Preferred Alternative)..................................................4-340

4.9.3.2.6 Alternative B—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the WPA Portion 

of the Proposed Lease Sale Area .......................................4-341
xiv Gulf of Mexico Multisale EIS

4.9.3.2.7 Alternative C—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the CPA/EPA 

Portions of the Proposed Lease Sale Area.........................4-341

4.9.3.2.8 Alternative D—Alternative A, B, or C, with the Option 

to Exclude Available Unleased Blocks Subject to the 

Topographic Features, Live Bottom (Pinnacle Trend), 

and/or Blocks South of Baldwin County, Alabama, 

Stipulations ..........................................................................4-342

4.9.3.2.9 Alternative E—No Action.....................................................4-342

4.9.4 Protected Birds.......................................................................................................4-342

4.9.4.1 Description of the Affected Environment................................................4-342

4.9.4.2 Environmental Consequences ...............................................................4-347

4.9.4.2.1 Routine Activities .................................................................4-348

4.9.4.2.2 Accidental Events ................................................................4-349

4.9.4.2.3 Cumulative Impacts .............................................................4-349

4.9.4.2.4 Incomplete or Unavailable Information................................4-350

4.9.4.2.5 Alternative A—Regionwide OCS Proposed Lease Sale 

(The Preferred Alternative)..................................................4-350

4.9.4.2.6 Alternative B—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the WPA Portion 

of the Proposed Lease Sale Area .......................................4-350

4.9.4.2.7 Alternative C—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the CPA/EPA 

Portions of the Proposed Lease Sale Area.........................4-351

4.9.4.2.8 Alternative D—Alternative A, B, or C, with the Option 

to Exclude Available Unleased Blocks Subject to the 

Topographic Features, Live Bottom (Pinnacle Trend), 

and/or Blocks South of Baldwin County, Alabama, 

Stipulations ..........................................................................4-351

4.9.4.2.9 Alternative E—No Action.....................................................4-351

4.9.5 Protected Corals ....................................................................................................4-351

4.9.5.1 Description of the Affected Environment................................................4-351

4.9.5.2 Environmental Consequences ...............................................................4-353

4.9.5.2.1 Routine Activities .................................................................4-354

4.9.5.2.2 Accidental Events ................................................................4-354

4.9.5.2.3 Cumulative Impacts .............................................................4-354

4.9.5.2.4 Alternatives A, B, and C ......................................................4-355

4.9.5.2.5 Alternative D—Alternative A, B, or C, with the Option 

to Exclude Available Unleased Blocks Subject to the 

Topographic Features, Live Bottom (Pinnacle Trend), 

and/or Blocks South of Baldwin County, Alabama, 

Stipulations ..........................................................................4-356

4.9.5.2.6 Alternative E—No Action.....................................................4-356

4.10 Commercial Fisheries.........................................................................................................4-356

4.10.1 Description of the Affected Environment ...............................................................4-358

4.10.2 Environmental Consequences...............................................................................4-360

4.10.2.1 Routine Activities....................................................................................4-360

4.10.2.2 Accidental Events...................................................................................4-361

4.10.2.3 Cumulative Impacts................................................................................4-362

4.10.2.4 Incomplete or Unavailable Information ..................................................4-365

4.10.2.5 Alternative A—Regionwide OCS Lease Sale (The Preferred 

Alternative) .............................................................................................4-365
Table of Contents xv 

4.10.2.6 Alternative B—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the WPA Portion of the Proposed 

Lease Sale Area.....................................................................................4-365

4.10.2.7 Alternative C—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the CPA/EPA Portions of the Proposed 

Lease Sale Area.....................................................................................4-366

4.10.2.8 Alternative D—Alternative A, B, or C, with the Option to Exclude 

Available Unleased Blocks Subject to the Topographic Features, 

Live Bottom (Pinnacle Trend), and/or Blocks South of Baldwin 

County, Alabama, Stipulations ...............................................................4-366

4.10.2.9 Alternative E—No Action........................................................................4-366

4.11 Recreational Fishing...........................................................................................................4-367

4.11.1 Description of the Affected Environment ...............................................................4-368

4.11.2 Environmental Consequences...............................................................................4-375

4.11.2.1 Routine Activities....................................................................................4-376

4.11.2.2 Accidental Events...................................................................................4-377

4.11.2.3 Cumulative Impacts................................................................................4-377

4.11.2.4 Incomplete or Unavailable Information ..................................................4-379

4.11.2.5 Alternative A—Regionwide OCS Lease Sale (The Preferred 

Alternative) .............................................................................................4-379

4.11.2.6 Alternative B—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the WPA Portion of the Proposed 

Lease Sale Area.....................................................................................4-380

4.11.2.7 Alternative C—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the CPA/EPA Portions of the Proposed 

Lease Sale Area.....................................................................................4-380

4.11.2.8 Alternative D—Alternative A, B, or C, with the Option to Exclude 

Available Unleased Blocks Subject to the Topographic Features, 

Live Bottom (Pinnacle Trend), and/or Blocks South of Baldwin 

County, Alabama, Stipulations ...............................................................4-381

4.11.2.9 Alternative E—No Action........................................................................4-381

4.12 Recreational Resources .....................................................................................................4-381

4.12.1 Description of the Affected Environment ...............................................................4-383

4.12.2 Environmental Consequences...............................................................................4-387

4.12.2.1 Routine Activities....................................................................................4-387

4.12.2.2 Accidental Events...................................................................................4-391

4.12.2.3 Cumulative Impacts................................................................................4-393

4.12.2.4 Incomplete or Unavailable Information ..................................................4-397

4.12.2.5 Alternative A—Regionwide OCS Lease Sale (The Preferred 

Alternative) .............................................................................................4-397

4.12.2.6 Alternative B—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the WPA Portion of the Proposed 

Lease Sale Area.....................................................................................4-398

4.12.2.7 Alternative C—Regionwide OCS Proposed Lease Sale Excluding 

Available Unleased Blocks in the CPA/EPA Portions of the Proposed 

Lease Sale Area.....................................................................................4-398

4.12.2.8 Alternative D—Alternative A, B, or C, with the Option to Exclude 

Available Unleased Blocks Subject to the Topographic Features, 

Live Bottom (Pinnacle Trend), and/or Blocks South of Baldwin 

County, Alabama, Stipulations ...............................................................4-399

4.12.2.9 Alternative E—No Action........................................................................4-399
xvi Gulf of Mexico Multisale EIS

4.13 Archaeological Resources..................................................................................................4-399

4.13.1 Description of the Affected Environment ...............................................................4-401

4.13.1.1 Prehistoric...............................................................................................4-401

4.13.1.2 Historic....................................................................................................4-403

4.13.2 Environmental Consequences...............................................................................4-406

4.13.2.1 Routine Activities....................................................................................4-406

4.13.2.2 Accidental Events...................................................................................4-408

4.13.2.3 Cumulative Impacts................................................................................4-410

4.13.2.4 Incomplete or Unavailable Information ..................................................4-413

4.13.2.5 Alternatives A, B, C, and D ....................................................................4-414

4.13.2.6 Alternative E—No Action........................................................................4-415

4.14 Human Resources and Land Use ......................................................................................4-415

4.14.1 Land Use and Coastal Infrastructure.....................................................................4-415

4.14.1.1 Description of the Affected Environment................................................4-418

4.14.1.1.1 Land Use .............................................................................4-418

4.14.1.1.2 Coastal Infrastructure ..........................................................4-422

4.14.1.2 Environmental Consequences ...............................................................4-424

4.14.1.2.1 Routine Activities .................................................................4-424

4.14.1.2.2 Accidental Events ................................................................4-426

4.14.1.2.3 Cumulative Impacts .............................................................4-429

4.14.1.2.4 Incomplete or Unavailable Information................................4-436

4.14.1.2.5 Alternative A—Regionwide OCS Lease Sale (The 

Preferred Alternative) ..........................................................4-437

4.14.1.2.6 Alternative B—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the WPA Portion 

of the Proposed Lease Sale Area .......................................4-438

4.14.1.2.7 Alternative C—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the CPA/EPA 

Portions of the Proposed Lease Sale Area.........................4-438

4.14.1.2.8 Alternative D—Alternative A, B, or C, with the Option 

to Exclude Available Unleased Blocks Subject to the 

Topographic Features, Live Bottom (Pinnacle Trend), 

and/or Blocks South of Baldwin County, Alabama, 

Stipulations ..........................................................................4-439

4.14.1.2.9 Alternative E—No Action.....................................................4-439

4.14.2 Economic Factors ..................................................................................................4-439

4.14.2.1 Description of the Affected Environment................................................4-440

4.14.2.2 Environmental Consequences ...............................................................4-443

4.14.2.2.1 Routine Activities .................................................................4-444

4.14.2.2.2 Accidental Events ................................................................4-446

4.14.2.2.3 Cumulative Impacts .............................................................4-447

4.14.2.2.4 Incomplete or Unavailable Information................................4-453

4.14.2.2.5 Alternative A—Regionwide OCS Lease Sale (The 

Preferred Alternative) ..........................................................4-454

4.14.2.2.6 Alternative B—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the WPA Portion 

of the Proposed Lease Sale Area .......................................4-457

4.14.2.2.7 Alternative C—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the CPA/EPA 

Portions of the Proposed Lease Sale Area.........................4-461
Table of Contents xvii

4.14.2.2.8 Alternative D—Alternative A, B, or C, with the Option 

to Exclude Available Unleased Blocks Subject to the 

Topographic Features, Live Bottom (Pinnacle Trend), 

and/or Blocks South of Baldwin County, Alabama, 

Stipulations ..........................................................................4-464

4.14.2.2.9 Alternative E—No Action.....................................................4-464

4.14.3 Social Factors (Including Environmental Justice)..................................................4-465

4.14.3.1 Description of the Affected Environment................................................4-466

4.14.3.2 Environmental Consequences ...............................................................4-471

4.14.3.2.1 Routine Activities .................................................................4-472

4.14.3.2.2 Accidental Events ................................................................4-473

4.14.3.2.3 Cumulative Impacts .............................................................4-474

4.14.3.2.4 Incomplete or Unavailable Information................................4-482

4.14.3.2.5 Alternative A—Regionwide OCS Lease Sale (The 

Preferred Alternative) ..........................................................4-483

4.14.3.2.6 Alternative B—Regionwide OCS Lease Sale Excluding 

Available Unleased Blocks in the WPA Portion of the 

Proposed Lease Sale Area .................................................4-484

4.14.3.2.7 Alternative C—Regionwide OCS Proposed Lease Sale 

Excluding Available Unleased Blocks in the CPA/EPA 

Portions of the Proposed Lease Sale Area.........................4-484

4.14.3.2.8 Alternative D—Alternative A, B, or C, with the Option 

to Exclude Available Unleased Blocks Subject to the 

Topographic Features, Live Bottom (Pinnacle Trend), 

and/or Blocks South of Baldwin County, Alabama, 

Stipulations ..........................................................................4-484

4.14.3.2.9 Alternative E—No Action.....................................................4-484

4.14.3.3 Environmental Justice Determination ....................................................4-485

4.15 Unavoidable Adverse Impacts of a Proposed Action.........................................................4-486

4.16 Irreversible and Irretrievable Commitment of Resources...................................................4-489

4.16.1 Coastal Habitats.....................................................................................................4-490

4.16.2 Biological Resources..............................................................................................4-490

4.16.2.1 Threatened and Endangered Species ...................................................4-490

4.16.2.2 Fish and Invertebrate Resources, Deepwater Benthic Communities, 

Commercial Fisheries, and Recreational Fishing ..................................4-490

4.16.3 Archaeological Resources .....................................................................................4-491

4.16.4 Oil and Gas Development......................................................................................4-491

4.16.5 Loss of Human and Animal Life.............................................................................4-491

4.17 Relationship Between the Short-term Use of Man’s Environment and the Maintenance 

and Enhancement of Long-term Productivity.....................................................................4-491

4.17.1 Short-Term Use......................................................................................................4-491

4.17.2 Relationship to Long-Term Productivity.................................................................4-493

5 CONSULTATION AND COORDINATION...................................................................................... 5-3

5.0 Introduction............................................................................................................................. 5-3

5.1 Coastal Zone Management Act.............................................................................................. 5-3

5.2 Endangered Species Act........................................................................................................ 5-4

5.3 Magnuson-Stevens Fishery Conservation and Management Act.......................................... 5-5

5.4 National Historic Preservation Act.......................................................................................... 5-5

5.5 Government-to-Government Tribal Consultation................................................................... 5-7
xviii Gulf of Mexico Multisale EIS

5.6 National Environmental Policy Act ......................................................................................... 5-8

5.6.1 Development of the Proposed Actions ...................................................................... 5-8

5.6.1.1 Notice of Intent to Prepare an EIS and Call for Information ...................... 5-8

5.6.1.2 Summary of Comments Received in Response to the Call 

for Information ............................................................................................ 5-9

5.6.1.3 Area ID Memorandum................................................................................ 5-9

5.6.2 Development of the Draft Multisale EIS................................................................... 5-10

5.6.2.1 Scoping..................................................................................................... 5-10

5.6.2.2 Summary of Scoping Comments ............................................................. 5-12

5.6.2.3 Additional Public Input Opportunities ....................................................... 5-15

5.6.2.4 Cooperating Agencies.............................................................................. 5-15

5.6.2.5 Distribution of the Draft Multisale EIS for Review and Comment ............ 5-16

5.6.3 Development of the Final Multisale EIS................................................................... 5-20

5.6.3.1 Major Differences Between the Draft and Final Multisale EISs ............... 5-20

5.6.3.2 Public Meetings ........................................................................................ 5-20

5.6.3.3 Comments Received on the Draft Multisale EIS and BOEM’s 

Responses................................................................................................ 5-21

6 REFERENCES CITED.................................................................................................................... 6-3

7 PREPARERS.................................................................................................................................. 7-3

8 GLOSSARY .................................................................................................................................... 8-3
Table of Contents xix 

Volume III 

Page 

LIST OF FIGURES ............................................................................................................................ xxi

LIST OF TABLES ............................................................................................................................ xxxi

APPENDICES 

Appendix A Postlease Permitting and Approval Processes ...................................................... A-3

Appendix B Commonly Applied Mitigating Measures ............................................................... B-3

Appendix C Cooperating Agency Memorandum of Agreement ................................................ C-3

Appendix D Proposed lease Mitigating Measures (Stipulations) .............................................. D-3

Appendix E Oil Spill Risk Analysis Figures ............................................................................... E-3

Appendix F Air Quality: WRF Model Performance ................................................................... F-1

Appendix G Air Quality: Emissions for the Cumulative and Visibility Impacts .......................... G-1 

Appendix H Air Quality: Cumulative and Visibility Impacts ...................................................... H-1

Appendix I Species Not Considered Further ............................................................................. I-3

Appendix J State Coastal Management Programs ................................................................... J-3

Appendix K Consultation Correspondence ............................................................................... K-3

Appendix L Responses to Public Comments on the Draft Multisale EIS ................................... L-3

KEYWORD INDEX ............................................................................................................. Keywords-3

List of Figures xxi

LIST OF FIGURES

Page

Figure 1-1. Proposed Regionwide Lease Sale Area Combining the Western, Central, and 

Eastern Planning Areas. ............................................................................................... 1-4 

Figure 1-2. Energy Use in the United States................................................................................... 1-6 

Figure 1-3. OCS Oil and Gas Program Development Process....................................................... 1-7 

Figure 1-4. Planning for the Five-Year Program. ............................................................................ 1-9 

Figure 1-5. Typical Planning Timeline for Regional OCS Oil and Gas Lease Sales. ................... 1-10

Figure 1-6. Supplemental Approach Showing the Tiering Relationships for Proposed Gulf 

of Mexico Lease Sales................................................................................................ 1-12 

Figure 1-7. BOEM’s Consultation Partners for Specific Federal Statutes and Regulations. ........ 1-14 

Figure 1-8. BOEM’s Integrated Approach for Incorporating Applied Science into 

Decisionmaking........................................................................................................... 1-16 

Figure 2-1. Proposed Regionwide Lease Sale Area, Encompassing the Available Unleased 

Blocks within All Three Planning Areas (a total of approximately 91.93 million ac 

with approximately 75.4 million ac available for lease as of January 2017)................. 2-7 

Figure 2-2. Proposed Lease Sale Area for Alternative B, Excluding the Available Unleased 

Blocks in the WPA (approximately 63.35 million ac with approximately 

49.6 million ac available for lease as of January 2017)................................................ 2-9 

Figure 2-3. Proposed Lease Sale Area for Alternative C, Excluding the Available Unleased 

Blocks in the CPA and EPA (approximately 28.58 million ac with approximately 

25.8 million ac available for lease as of January 2017).............................................. 2-10

Figure 2-4. Identified Topographic Features, Pinnacle Trend, and Blocks South of Baldwin 

County, Alabama, Stipulation Blocks in the Gulf of Mexico........................................ 2-11 

Figure 2-5. Example of Excluded Blocks under Alternative D. ..................................................... 2-12 

Figure 2-6. Federal OCS Blocks Subject to the Gulf Islands National Seashore’s Information 

to Lessees and Operators........................................................................................... 2-17 

Figure 2-7. Historical Structure Locations near Horn and Petit Bois Islands................................ 2-18 

Figure 2-8. Military Warning Areas and Eglin Water Test Areas in the Gulf of Mexico. ............... 2-26 

Figure 3-1. Total Oil and Gas Production (BOE) in the Gulf of Mexico in the Low and High 

Production Scenario by Water Depth for a Single Proposed Lease Sale 

(2017-2066)................................................................................................................... 3-7 

Figure 3-2. Offshore Subareas in the Gulf of Mexico...................................................................... 3-8 

Figure 3-3. Typical Timeline for Offshore Oil and Gas Drilling...................................................... 3-11

Figure 3-4. General Well Schematic.............................................................................................. 3-19

Figure 3-5. (A) Number of Exploration and Delineation Wells Drilled over the Course 

of a Proposed Action under Alternative A for 50 Years. (B, C) Location 

of Exploration Wells Drilled during the Entire 50-Year Period.................................... 3-21

Figure 3-6. (A) Number of Production Wells Drilled over the Course of a Proposed Action 

under Alternative A for 50 Years. (B, C) Total Number of Development and 

Production Wells Drilled in the Low and High Production Scenario by Water 

Depth for Alternative A................................................................................................ 3-27

Figure 3-7. Offshore Production Systems. .................................................................................... 3-29

Figure 3-8. Number of Production Structures and Service Vessels Operating over the 

Course of a Proposed Action under Alternative A for 50 Years. (B, C) Total 

Number of Platforms Installed in the Low and High Production Scenario by 

Water Depth. ............................................................................................................... 3-36

Figure 3-9. Gulfwide OCS Oil- and Gas-Related Service Bases and Major Waterways.............. 3-49

Figure 3-10. Boundaries for USEPA Regions 4 and 6. ................................................................... 3-59

Figure 3-11. Onshore Infrastructure. ............................................................................................... 3-83

Figure 3-12. OCS-Related Ports and Waterways in the Gulf of Mexico. ........................................ 3-87
xxii Gulf of Mexico Multisale EIS

Figure 3-13. Number of Oil Spills ≥1 bbl That Have Occurred in the Gulf of Mexico for the 

Period 2001 through 2015.........................................................................................3-102

Figure 3-14. Total Volume (bbl) of Oil Spilled in Gulf of Mexico Waters for Spills ≥1 bbl 

for the Period 2001 through 2015 .............................................................................3-103

Figure 3-15. Number of Platform and Pipeline-Related Oil Spills ≥1 bbl That Have Occurred 

in the Gulf of Mexico for the Period 2001 through 2015...........................................3-104

Figure 3-16. Total Volume of Spilled Oil for Platform and Pipeline-Related Oil Spills ≥1 bbl 

That Have Occurred in the Gulf of Mexico for the Period 2001 through 2015. ........3-105

Figure 3-17. The Oil Spill Risk Analysis Model Process. ..............................................................3-121

Figure 3-18. OCS Oil and Gas Production Between 2004 and 2015............................................3-160

Figure 3-19. Number of Production Structures Installed and Decommissioned in Past 

Programs and the Range of Future Projections that May Occur as a Result 

of All Past, Present, and Future Actions ...................................................................3-162

Figure 3-20. 2015 Gulf of Mexico Hypoxic Zone...........................................................................3-212

Figure 4-1. Gulf of Mexico Region with the Planning Areas, Nonattainment Areas, Air 

Quality Jurisdiction, and Class I and Sensitive Class II Areas. .................................. 4-15

Figure 4-2. Year 2011 Gulfwide Emission Inventory Results for Total Platform and 

Non-Platform Criteria Pollutant Emissions (TPY)....................................................... 4-22

Figure 4-3. Year 2011 Gulfwide Emission Inventory Results for Total Platform and 

Non-Platform Greenhouse Gas Emissions (TPY). ..................................................... 4-22

Figure 4-4. 2011 Criteria Pollutant Emissions (TPY) from Platform Sources............................... 4-23

Figure 4-5. 2011 Greenhouse Gases (TPY) from Platform Sources............................................ 4-23

Figure 4-6. Overview of the Gulf of Mexico Region’s Cumulative and Visibility Impacts 

Assessment................................................................................................................. 4-35

Figure 4-7. Geographic Domain of the “Air Quality Modeling in the Gulf of Mexico” Region 

Study. .......................................................................................................................... 4-36

Figure 4-8. Coastal Watersheds of the Upper Gulf of Mexico Showing the Magnitude 

of Saltwater (intertidal) Wetland Loss to Open Water, 2004 to 2009 ......................... 4-72

Figure 4-9. Seagrass Locations of the Northern Gulf of Mexico. .................................................. 4-75

Figure 4-10. Deepwater Coral Records from NOAA’s National Deep-Sea Coral and Sponge 

Database ...................................................................................................................4-116

Figure 4-11. Estimated Distribution of Known Deepwater Benthic Communities in the 

Gulf of Mexico as of 2015. ........................................................................................4-124

Figure 4-12. BOEM’s Water Bottom Seismic Anomaly Database Showing Grouped Anomaly 

Categories Thought Likely to Support Deepwater Benthic Communities and 

Those That Generally Do Not ...................................................................................4-125

Figure 4-13. Example of a Predictive Habitat Suitability Model for Selected Deepwater, 

Framework-Forming Scleractinian Corals ................................................................4-129

Figure 4-14. Sargassum Loop System..........................................................................................4-148

Figure 4-15. Pelagic Brown Algae in the Genus Sargassum........................................................4-149

Figure 4-16. Small Fishes in Sargassum.......................................................................................4-150

Figure 4-17. Lease Blocks Subject to the Topographic Features and Live Bottom (Pinnacle 

Trend) Stipulations....................................................................................................4-162

Figure 4-18. Ecological Representation of Common Features on Topographic Features 

in the Gulf of Mexico. ................................................................................................4-168

Figure 4-19. General Location of the Pinnacle Trend (A), Multibeam Bathymetry and Named 

Reef Areas (B), and an Exaggerated Vertical Relief Profile of Rough Tongue 

Reef (C). ..................................................................................................................4-193

Figure 4-20. Migration Routes for Trans-Gulf Migratory Birds in the Presence of an Eastern 

Continental High........................................................................................................4-239

Figure 4-21. Migration Routes for Trans-Gulf Migratory Birds in the Presence of a Bermuda 

High ...........................................................................................................................4-240

Figure 4-22. Spring Wood Thrush Partial Migratory Corridor in North America ...........................4-241
List of Figures xxiii

Figure 4-23. Fall Wood Thrush Partial Migratory Corridor in North America................................4-242

Figure 4-24. Platform Density and Spring Migration Routes for Trans-Gulf Migratory Birds........4-243

Figure 4-25. Gulf of Mexico Protected Species’ Critical Habitats. ................................................4-261

Figure 4-26. Gulf Islands National Seashore. ...............................................................................4-387

Figure 4-27. Photograph of Remaining OCS Structures taken from Petit Bois Island Looking 

South (Petit Bois Island is within the Gulf Islands National Seashore 

and is a National Park Service-designated wilderness area.)..................................4-389

Figure 4-28. Economic Land Use Patterns. ..................................................................................4-419

Figure 4-29. Historical Land Loss in Louisiana, 1932-2010..........................................................4-435

Figure 4-30. Moderate Scenario: Projected Land Loss in Louisiana. ..........................................4-435

Figure 4-31. Less Optimistic Scenario: Projected Land Loss in Louisiana..................................4-436

Figure 4-32. Population of BOEM’s Economic Impact Areas in the Gulf of Mexico. ....................4-467

Figure 4-33. Percentage of Poverty in Texas and Louisiana. .......................................................4-469

Figure 4-34. Percentage of Poverty in Mississippi, Alabama, and Florida. ..................................4-469

Figure 4-35. Percentage of Minority Populations in Texas and Louisiana....................................4-470

Figure 4-36. Percentage of Minority Populations in Mississippi, Alabama, and Florida...............4-471

Figure 5-1. Timeline for the Development of the Multisale EIS....................................................... 5-8 

Figure E-1. The Oil Spill Risk Analysis Domain.............................................................................. E-4 

Figure E-2. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days 

the Shoreline (counties and parishes) as a Result of Alternative A. ........................... E-4 

Figure E-3. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days 

the Shoreline (counties and parishes) as a Result of Alternative A. ........................... E-5 

Figure E-4. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days 

the Shoreline (counties and parishes) as a Result of Alternative B. ........................... E-5 

Figure E-5. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days 

the Shoreline (counties and parishes) as a Result of Alternative B. ........................... E-6 

Figure E-6. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days 

the Shoreline (counties and parishes) as a Result of Alternative C. ........................... E-6 

Figure E-7. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days 

the Shoreline (counties and parishes) as a Result of Alternative C. ........................... E-7 

Figure E-8. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days 

Nearshore (“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to 

outer jurisdiction) Polygons as a Result of the Low Case in Resource Estimates 

for Alternative A............................................................................................................ E-7 

Figure E-9. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days 

Nearshore (“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to 

outer jurisdiction) Polygons as a Result of the High Case in Resource Estimates 

for Alternative A............................................................................................................ E-8 

Figure E-10. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days 

Nearshore (“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to 

outer jurisdiction) Polygons as a Result of the Low Case in Resource Estimates 

for Alternative A............................................................................................................ E-8 

Figure E-11. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days 

Nearshore (“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to 

outer jurisdiction) Polygons as a Result of the High Case in Resource Estimates 

for Alternative A............................................................................................................ E-9 

Figure E-12. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days 

Nearshore (“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to 

outer jurisdiction) Polygons as a Result of the Low Case in Resource Estimates 

for Alternative B............................................................................................................ E-9 
xxiv Gulf of Mexico Multisale EIS

Figure E-13. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days 

Nearshore (“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to 

outer jurisdiction) Polygons as a Result of the High Case in Resource Estimates 

for Alternative B.......................................................................................................... E-10

Figure E-14. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days 

Nearshore (“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to 

outer jurisdiction) Polygons as a Result of the Low Case in Resource Estimates 

for Alternative B.......................................................................................................... E-10

Figure E-15. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days 

Nearshore (“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to 

outer jurisdiction) Polygons as a Result of the High Case in Resource Estimates 

for Alternative B.......................................................................................................... E-11

Figure E-16. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days 

Nearshore (“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to 

outer jurisdiction) Polygons as a Result of the Low Case in Resource Estimates 

for Alternative C.......................................................................................................... E-11

Figure E-17. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days 

Nearshore (“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to 

outer jurisdiction) Polygons as a Result of the High Case in Resource Estimates 

for Alternative C.......................................................................................................... E-12

Figure E-18. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days 

Nearshore (“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to 

outer jurisdiction) Polygons as a Result of the Low Case in Resource Estimates 

for Alternative C.......................................................................................................... E-12

Figure E-19. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days 

Nearshore (“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to 

outer jurisdiction) Polygons as a Result of the High Case in Resource Estimates 

for Alternative C.......................................................................................................... E-13

Figure E-20. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days 

and 30 Days State Offshore Waters as a Result of Alternative A, B, or C................ E-13

Figure F-1. Location of the “Air Quality Modeling in the Gulf of Mexico Region” Study 

with Class I Areas and Platform Locations .................................................................. F-3 

Figure F-2. Ozone Nonattainment Areas in the Southeastern U.S................................................ F-4 

Figure F-3. Overview of the “Air Quality Modeling in the Gulf of Mexico Region” Study Tasks .... F-6 

Figure F-4. WRF 36-km CONUS (d01), 12-km SE Regional (d02), and 4-km Gulf of Mexico 

Region (d03) Domains. ................................................................................................ F-9 

Figure F-5. BOEM Gulf of Mexico OCS Region WRF 36-km METSTAT Wind Direction 

Performance for 2012. ............................................................................................... F-18

Figure F-6. BOEM Gulf of Mexico OCS Region WRF 36-km METSTAT Wind Speed 

Performance for 2012. ............................................................................................... F-18

Figure F-7. BOEM Gulfof Mexico OCS Region WRF 36-km METSTAT Temperature 

Performance for 2012. ............................................................................................... F-19

Figure F-8. BOEM Gulf of Mexico OCS Region WRF 36-km METSTAT Humidity 

Performance for 2012. ............................................................................................... F-19

Figure F-9. BOEM Gulf of Mexico OCS Region WRF 12-km METSTAT Wind Direction 

Performance for 2012. ............................................................................................... F-20

Figure F-10. BOEM Gulf of Mexico OCS Region WRF 12-km METSTAT Wind Speed 

Performance for 2012. ............................................................................................... F-20

Figure F-11. BOEM Gulf of Mexico OCS Region WRF 12-km METSTAT Temperature 

Performance for 2012. ............................................................................................... F-21

Figure F-12. BOEM Gulf of Mexico OCS Region WRF 12-km METSTAT Humidity 

Performance for 2012. ............................................................................................... F-21
List of Figures xxv 

Figure F-13. BOEM Gulf of Mexico OCS Region WRF 4-km METSTAT Wind Direction 

Performance for 2012. ............................................................................................... F-22

Figure F-14. BOEM Gulf of Mexico OCS Region WRF 4-km METSTAT Wind Speed 

Performance for 2012. ............................................................................................... F-22

Figure F-15. BOEM Gulf of Mexico OCS Region WRF 4-km METSTAT Temperature 

Performance for 2012. ............................................................................................... F-23

Figure F-16. BOEM Gulf of Mexico OCS Region WRF 4-km METSTAT Humidity 

Performance for 2012. ............................................................................................... F-23

Figure F-17. Wind Rose Locations for Port Isabel, TX (PTIT), Calcasieu, LA (CAPL), 

Gulfport, MS (KGPT), and Naples, FL (NPSF).......................................................... F-24

Figure F-18. 2012 WRF Wind Rose (left) Compared to 2012 Observation Wind Rose 

from Gulfport, MS (right) in 4-km Domain.................................................................. F-25

Figure F-19. 2012 WRF Wind Rose (left) Compared to 2012 Observation Wind Rose 

from Naples, FL (right) in 4-km Domain..................................................................... F-26

Figure F-20. 2012 WRF Wind Rose (left) Compared to 2012 Observation Wind Rose 

from Port Isabel, TX (right) in 4-km Domain.............................................................. F-27

Figure F-21. 2012 WRF Wind Rose (left) Compared to 2012 Observation Wind Rose 

from Calcasieu, LA (right) in 4-km Domain................................................................ F-28

Figure F-22. Vertical Profile Soundings Comparing the 4-km WRF (blue lines) to Upper-Air 

Observations Data (red lines) for Brownsville, TX on August 3, 2012, and 

Key West, FL on January 4, 2012, at 00 UTC........................................................... F-30

Figure F-23. January 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain............... F-33

Figure F-24. February 2012 PRISM Precipitation and WRF Precipitation 4-km Domain.............. F-34

Figure F-25. March 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain.................. F-35

Figure F-26. April 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain. ................... F-36

Figure F-27. May 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain..................... F-37

Figure F-28. June 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain.................... F-38

Figure F-29. July 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain. ................... F-39

Figure F-30. August 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain. ............... F-40

Figure F-31. September 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain......... F-41

Figure F-32. October 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain............... F-42

Figure F-33. November 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain........... F-43

Figure F-34. December 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain........... F-44

Figure F-35. January 2012 TRMM Precipitation Average and Corresponding WRF Precipitation 

Average in the 12-km Domain. .................................................................................. F-46

Figure F-36. February 2012 TRMM Precipitation Average and Corresponding WRF 

Precipitation Average in the 12-km Domain. ............................................................. F-47

Figure F-37. March 2012 TRMM Precipitation Average and Corresponding WRF Precipitation 

Average in the 12-km Domain. .................................................................................. F-48

Figure F-38. April 2012 TRMM Precipitation Average and Corresponding WRF Precipitation 

Average in the 12-km Domain. .................................................................................. F-49

Figure F-39. May 2012 TRMM Precipitation Average and Corresponding WRF Precipitation 

Average in the 12-km Domain. .................................................................................. F-50

Figure F-40. June 2012 TRMM Precipitation Average and Corresponding WRF Precipitation 

Average in the 12-km Domain. .................................................................................. F-51

Figure F-41. July 2012 TRMM Precipitation Average and Corresponding WRF Precipitation 

Average in the 12-km Domain. .................................................................................. F-52

Figure F-42. August 2012 TRMM Precipitation Average and Corresponding WRF Precipitation 

Average in the 12-km Domain. .................................................................................. F-53

Figure F-43. September 2012 TRMM Precipitation Average and Corresponding WRF 

Precipitation Average in the 12-km Domain. ............................................................. F-54

Figure F-44. October 2012 TRMM Precipitation Average and Corresponding WRF Precipitation 

Average in the 12-km Domain. .................................................................................. F-55
xxvi Gulf of Mexico Multisale EIS

Figure F-45. November 2012 TRMM Precipitation Average and Corresponding WRF 

Precipitation Average in the 12-km Domain. ............................................................. F-56

Figure F-46. December 2012 TRMM Precipitation Average and Corresponding WRF 

Precipitation Average in the 12-km Domain. ............................................................. F-57

Figure F-47. Daily Precipitation Plots from WRF, PRISM, and TRMM on August 30, 2012.......... F-59

Figure F-48. Daily Precipitation Plots from WRF, PRISM, and TRMM Databases 

on June 25, 2012........................................................................................................ F-60

Figure G-1. Location of the “Air Quality Modeling in the Gulf of Mexico Region” Study, 

with Class I Areas and Platform Locations .................................................................. G-1 

Figure G-2. Ozone Nonattainment Areas in the Southeastern U.S................................................ G-2 

Figure G-3. Overview of the “Air Quality Modeling in the Gulf of Mexico Region” Study Tasks .... G-4 

Figure G-4. WRF 36-km CONUS (d01), 12-km SE Regional (d02), and 4-km Gulf of Mexico 

Region (d03) Domains Along With the PGM Grids. .................................................... G-6 

Figure G-5. 2012 Platform NOx Emissions Aggregated by Lease Block ...................................... G-11

Figure G-6. 2012 Platform VOC Emissions Aggregated by Lease Block..................................... G-12

Figure G-7. 2012 Platform PM2.5 Emissions Aggregated by Lease Block.................................... G-13

Figure G-8. 2012 Non-platform NOx Emissions ............................................................................ G-15

Figure G-9. 2012 Non-platform VOC Emissions........................................................................... G-16

Figure G-10. 2012 Non-platform PM2.5 Emissions.......................................................................... G-17

Figure G-11. Emission Estimates for all Planning Areas and Future Activities. ............................. G-27

Figure G-12. Combined Annual NOx Emissions. ............................................................................ G-27

Figure G-13. Combined Annual VOC Emissions............................................................................ G-28

Figure G-14. Combined Annual PM2.5 Emissions........................................................................... G-28

Figure G-15. BOEM OCS Planning Areas and Water Depths........................................................ G-29

Figure H-1. Location of the “Air Quality Modeling in the Gulf of Mexico Region” Study, 

with Class I Areas......................................................................................................... H-1 

Figure H-2. Ozone Nonattainment Areas in the Southeastern U.S................................................ H-3 

Figure H-3. Class I and Sensitive Class II Areas in the Study Region. .......................................... H-5 

Figure H-4. Overview of the “Air Quality Modeling in the Gulf of Mexico Region” Study Tasks .... H-6 

Figure H-5. Meteorological (WRF model) and PGM Modeling Domains Including the 36-km 

Horizontal Grid Resolution CONUS WRF Domain, 12-km Resolution Southeast 

Regional WRF and PGM Domains (d02), and 4-km Resolution Gulf of Mexico 

OCS Region WRF and PGM Domains (d03)............................................................... H-7 

Figure H-6. BOEM’s 12-km 2012 Base Case NOx Emissions Summary in Tons per Year 

by Source Category and State (Alabama, Florida, Louisiana, Mississippi, 

and Texas). ................................................................................................................ H-19

Figure H-7. BOEM 12-km 2012 Base Case VOC Emissions Summary in Tons per Year 

by Source Category and State (Alabama, Florida, Louisiana, Mississippi, 

and Texas). ................................................................................................................ H-20

Figure H-8. BOEM 12-km 2012 Base Case PM2.5 Emissions Summary in Tons per Year 

by Source Category and State (Alabama, Florida, Louisiana, Mississippi, 

and Texas). ................................................................................................................ H-21

Figure H-9. BOEM 12-km 2012 Base Case SO2 Emissions Summary in Tons per Year 

by Source Category and State (Alabama, Florida, Louisiana, Mississippi, 

and Texas). ................................................................................................................ H-22

Figure H-10. BOEM 12-km Future Year NOx Emissions Summary in Tons per Year by Source 

Category and State (Alabama, Florida, Louisiana, Mississippi, and Texas)............. H-23

Figure H-11. BOEM 12-km Future Year VOC Emissions Summary in Tons per Year by Source 

Category and State (Alabama, Florida, Louisiana, Mississippi, and Texas)............. H-24

Figure H-12. BOEM 12-km Future Year PM2.5 Emissions Summary in Tons per Year by Source 

Category and State (Alabama, Florida, Louisiana, Mississippi, and Texas)............. H-25

Figure H-13. BOEM 12-km Future Year SO2 Emissions Summary in Tons per Year by Source 

Category and State (Alabama, Florida, Louisiana, Mississippi, and Texas)............. H-26
List of Figures xxvii 

Figure H-14. Spatial Distribution of NOx, VOC, SO2, and PM2.5 Emissions (tons per year) 

from New OCS Oil and Gas Production Platforms under the Proposed Action........ H-29

Figure H-15. Spatial Distribution of Emissions (tons per year) of NOx, VOC, SO2, and PM2.5 

from BOEM’s OCS Additional Oil and Gas Support Vessels and Helicopters 

under the Proposed Action Scenario. ........................................................................ H-30

Figure H-16. Spatial Distribution of NOx, VOC, SO2, and PM2.5 Emissions (tons per year) 

from BOEM’s OCS Oil and Gas Platforms, Support Vessels, and Helicopters 

under the No Action Alternative in BOEM’s 4-km Domain. ....................................... H-31

Figure H-17. Spatial Distribution of NOx, VOC, SO2, and PM2.5 Emissions (tons per year) 

from All Other Marine Vessel Activity in the Gulf of Mexico under the Future Year 

Scenario in BOEM’s 4-km Domain. ........................................................................... H-32

Figure H-18. Spatial Distribution of NOx, VOC, SO2, and PM2.5 Emissions (tons per year) 

from Other Anthropogenic U.S. Sources for the Future Year Scenario within 

BOEM’s 4-km Domain................................................................................................ H-33

Figure H-19. Ozone Monitoring Sites Used in the Model Performance Evaluation: CASTNet 

Sites in the Southeastern U.S. and AQS Sites within the 4-km Modeling Domain .. H-42

Figure H-20. Speciated PM Monitoring Sites Used in the Model Performance Evaluation: 

CSN Network, IMPROVE Network, and SEARCH Network ..................................... H-44

Figure H-21. Monthly Normalized Mean Bias and Normalized Mean Error for Daily Maximum 

8-hour Average Ozone at AQS and CASTNet Monitoring Sites Located within 

the 4-km Modeling Domain and the 12-km Domain .................................................. H-50

Figure H-22. Fraction of Site-days during Each Month of 2012 with Observed Daily Maximum 

8-hour Ozone Exceeding 60, 65, or 70 ppb Over All Monitoring Sites in the 

4-km Domain.............................................................................................................. H-51

Figure H-23. Observed (blue) and Predicted Monthly Mean Daily Maximum 8-hour Average 

Ozone Over All Sites in the 4-km Modeling Domain. ................................................ H-52

Figure H-24. Scatter and Scatter Density Plots for Observed vs. Predicted Daily Maximum 

8-hour Ozone in Q2 and Q3 for All AQS Monitoring Sites in the 4-km Modeling 

Domain....................................................................................................................... H-53

Figure H-25. Normalized Mean Bias (NMB) for Daily Maximum 8-hour Ozone for Q2 (top) 

and Q3........................................................................................................................ H-54

Figure H-26. Time Series of Daily Maximum 8-hour Ozone at Monitoring Sites with Highest 

Design Values in Harris, Brazoria, and Galveston Counties, Texas, for Q2 

and Q3........................................................................................................................ H-56

Figure H-27. Time Series of Daily Maximum 8-hour Ozone at Monitoring Sites in the 

Baton Rouge Nonattainment Area: LSU and Carville for Q2 and Q3 ...................... H-56

Figure H-28. Time Series of Daily Maximum 8-hour Ozone at the ALC188 (AlabamaCoushatta, Texas) CASTNet Monitoring Site for Q2 and Q3 .................................... H-57

Figure H-29. PM Monitoring Sites in the Southeastern U.S. Domain............................................. H-59

Figure H-30. Soccer Plots of Total PM2.5 Mass Model Performance Across the IMPROVE, 

CSN SEARCH, and FRM Daily Monitoring Networks for Sites in the Southeastern 

U.S. Domain............................................................................................................... H-60

Figure H-31. Comparisons of Predicted with Observed Daily Average PM at CSN Network 

Sites in the Southeastern U.S. for Q2 and Q4 for Total PM2.5, Other PM2.5, 

and Sodium ................................................................................................................ H-61

Figure H-32. Comparisons of Observed vs. Predicted OC and EC (bottom) at SEARCH and 

CSN Network Sites in the Southeastern U.S............................................................. H-62

Figure H-33. Monthly Normalized Mean Bias and Normalized Mean Error for Hourly NO2 and 

Daily NOy at SEARCH Network Sites and AQS Sites in the 4-km Domain............... H-63

Figure H-34. Monthly Normalized Mean Bias and Normalized Mean Error for NO3 at SEARCH 

Network Monitoring Sites and AQS Sites and NO3 Deposition at NADP Sites 

in the Southeastern U.S............................................................................................. H-64
xxviii Gulf of Mexico Multisale EIS

Figure H-35. Monthly Normalized Mean Bias and Normalized Mean Error at Monitoring Sites 

in the 4-km Domain for SO2, SO4, and SO4 Deposition Measured at NADP Sites... H-66

Figure H-36. Annual Normalized Mean Bias for Hourly SO2 (based on 12-km resolution 

CAMx results)............................................................................................................. H-67

Figure H-37. Monthly Normalized Mean Bias and Normalized Mean Error for Daily Average 

NH4 at CSN and SEARCHNetwork Sites in the 4-km Modeling Domain. ................ H-68

Figure H-38. Monthly Normalized Mean Bias and Normalized Mean Error for Hourly CO 

at SEARCH Network Sites and AQS Sites ................................................................ H-69

Figure H-39. Class I and Sensitive Class II Areas for Which Incremental AQ/AQRV Impacts 

Were Calculated......................................................................................................... H-73

Figure H-40. Base Scenario Ozone Design Values (DVC), Future Year Ozone Design Values 

(DVF) and Their Differences (DVF – DVC) Calculated Using the MATS UAA 

Tool............................................................................................................................. H-87

Figure H-41. MATS UAA Future Year Ozone Design Values (DFV) Calculated After First 

Removing the Hourly Contributions from a Source Group and the Corresponding 

Contributions of the Source Group to DVF Calculated by Subtracting the DVFs 

Shown in the Left-hand Column from the “All Sources” DVF Shown in the Top 

Right-hand Corner of Figure H-40 ............................................................................. H-88

Figure H-42. Modeled 4th Highest MDA8 Ozone for the Base Year and Future Year Scenarios 

and Their Differences................................................................................................. H-89

Figure H-43. Contributions of Source Groups A, B, C, D, and E to Future Year All-sources 

4th Highest MDA8 ...................................................................................................... H-91

Figure H-44. Contributions from Source Group F (natural and non-US emission sources 

including boundary conditions) and Boundary Conditions Only, to Future Year 

All-sources 4th Highest MDA8. .................................................................................. H-92

Figure H-45. Current Year (DVC) and Future Year (DVF) Annual Average PM2.5 Design 

Values from the MATS Unmonitored Area Analysis and the Difference, 

DVF – DVC................................................................................................................. H-98

Figure H-46. Contributions of Source Groups A, B, C, D, and E to the Future Year All-sources 

Annual Average PM2.5 Concentration Based on the MATS Unmonitored Area 

Analysis ...................................................................................................................... H-99

Figure H-47. Modeled 8th Highest Daily Average PM2.5 Concentrations for the Base Year, 

Future Year, and the Future – Base Difference....................................................... H-101

Figure H-48. Contributions of Source Groups A, B, C, D, and E to the Future Year All-sources 

8th Highest Daily Average PM2.5 Concentration...................................................... H-102

Figure H-49. Contributions from Source Group F (natural and non-U.S. emission sources 

including boundary conditions) and Boundary Conditions Only to Future Year 

All-sources 8th Highest 24-hour PM2.5..................................................................... H-103

Figure H-50. Modeled Annual Average PM2.5 Concentrations for the Base Year, Future Year, 

and the Future – Base Difference............................................................................ H-104

Figure H-51. Contributions of Source Group A, B, C, D, and E to the Future Year All-sources 

Annual Average PM2.5 Concentration ...................................................................... H-105

Figure H-52. Contributions from Source Group F (natural and non-U.S. emission sources 

including boundary conditions) and Boundary Conditions Only to Future Year 

All-sources Annual Average PM2.5 ........................................................................... H-106

Figure H-53. Modeled 2nd Highest 24-hour Average PM10 Concentrations for the Base Year, 

Future Year, and the Future – Base Difference....................................................... H-107

Figure H-54. Contributions of Source Groups A, B, C, D, and E to the Future Year All-sources 

2nd Highest Daily Average PM10 Concentration...................................................... H-108

Figure H-55. Contributions from Source Group F (natural and non-U.S. emission sources 

including boundary conditions) and Boundary Conditions Only to Future Year 

All-sources 2nd Highest Daily Average PM10 Concentration.................................... H-109
List of Figures xxix

Figure H-56. Modeled 8th Highest 1-hour NO2 Concentrations for the Base Year, Future 

Year, and the Future – Base Difference .................................................................. H-110

Figure H-57. Contributions of Source Group A, B, C, D, and E to the Future Year All-sources 

8th Highest Daily Average NO2 Concentrations ...................................................... H-111

Figure H-58. Modeled Annual Average NO2 Concentrations for the Base Year, Future Year, 

and the Future – Base Difference............................................................................ H-112

Figure H-59. Contributions of Source Groups A, B, C, D, and E to the Future Year All-sources 

Annual Average NO2 Concentrations. ..................................................................... H-113

Figure H-60. Modeled 4th Highest Daily Maximum 1-hour SO2 Concentrations for the Base 

Year, Future Year, and the Future – Base Difference............................................. H-115

Figure H-61. Contributions of Source Group A, B, C, D, and E to the Future Year All-sources 

4th Highest Daily Maximum 1-hour SO2 Concentration .......................................... H-116

Figure H-62. Modeled Annual 2nd Highest Block 3-hour SO2 Concentrations for the Base 

Year, Future Year, and the Future – Base Difference............................................. H-117

Figure H-63. Contributions of Source Group A, B, C, D, and E to the Future Year All-sources 

2nd Highest 3-hour Block Average SO2 Concentration........................................... H-118

Figure H-64. Modeled Annual 2nd Highest Non-overlapping Running 8-hour Average CO 

Concentrations for the Base Year, Future Year, and the Future – Base Difference..... H119

Figure H-65. Modeled Annual 2nd Highest 1-hour Average CO Concentrations for the Base 

Year, Future Year, and the Future – Base Difference............................................. H-120

List of Tables xxxi 

LIST OF TABLES

Page

Table 2-1. Applicable Stipulations by Alternative .......................................................................... 2-29

Table 2-2. Alternative Comparison Matrix. .................................................................................... 2-36 

Table 3-1. Projected Oil and Gas in the Gulf of Mexico OCS. ........................................................ 3-7 

Table 3-2. Offshore Scenario Activities and Impact-Producing Factors Related to a Single 

Proposed Lease Sale for Alternative A, B, or C from 2017 through 2066. .................... 3-9 

Table 3-3. Estimated Exploration and Seismic Survey Activity Leading Up To and Following 

a Proposed Lease Sale in the Gulf of Mexico. ............................................................. 3-16

Table 3-4. Oil Transportation Scenario under Alternatives A, B, and C........................................ 3-37

Table 3-5. Existing Coastal Infrastructure Related to OCS Oil- and Gas-Related Activities 

in the Gulf of Mexico..................................................................................................... 3-38

Table 3-6. OCS Pipeline Landfalls Installed from 1996 to 2014. .................................................. 3-42

Table 3-7. Waterway Length, Depth, Traffic, and Number of Trips for 2012. ............................... 3-45

Table 3-8. Pollution-Related Incidents of Noncompliance (INCs) Issued Since 1986. ................. 3-61

Table 3-9. National Pollutant Discharge Elimination System Inspections from 1999 

through 2016................................................................................................................. 3-62

Table 3-10. Annual Volume of Produced Water Discharged by Depth (millions of bbl). ................ 3-68

Table 3-11. OCS Oil- and Gas-Related Service Bases................................................................... 3-86

Table 3-12. Spill Rates for Petroleum Spills ≥1,000 Barrels from OCS Platforms and Pipelines, 

1964 through 2010......................................................................................................3-106

Table 3-13. Historic Spill Source, Location, and Characteristics of a Maximum Spill for 

Coastal Waters (data extracted from USDHS, CG records, 2002-July 2015). ..........3-108

Table 3-14. Petroleum Spills ≥1,000 Barrels from United States OCS Platforms, 

1964-July 2016. ..........................................................................................................3-111

Table 3-15. Petroleum Spills ≥1,000 Barrels from United States OCS Pipelines, 

1964-July 2016. ..........................................................................................................3-113

Table 3-16. Properties and Persistence by Oil Component Group. ..............................................3-117

Table 3-17. Probability (percent chance) of a Particular Number of Offshore Spills 

≥1,000 Barrels Occurring as a Result of Either Facility or Pipeline Operations 

Related to Alternative A, B, or C.................................................................................3-122

Table 3-18. Mean Number and Sizes of Spills Estimated to Occur in OCS Offshore Waters 

from an Accident Related to Rig/Platform and Pipeline Activities Supporting Each 

Alternative Over a 50-Year Time Period. ...................................................................3-123

Table 3-19. Oil-Spill Occurrence Probability Estimates for Offshore Spills ≥1,000 Barrels 

Resulting from Each Alternative (2017-2066) and the Cumulative OCS Oil and 

Gas Program (2017-2086)..........................................................................................3-124

Table 3-20. Oil-Spill Occurrence Probability Estimates for Offshore Spills ≥10,000 Barrels 

Resulting from Each Alternative (2017-2066) and the Cumulative OCS Oil and 

Gas Program (2017-2086)..........................................................................................3-124

Table 3-21. Number and Volume of Chemical and Synthetic-Based Fluid Spills for 

10-49 Barrels and >50 Barrels in the Gulf of Mexico from 2007 through 2014. ........3-137

Table 3-22. Primary Cleanup Options Used during the Deepwater Horizon Response. ..............3-142

Table 3-23. Future Activity Projections Associated with the Cumulative OCS Oil and Gas 

Program (2017-2086), Including All Future Activities that are Projected to Occur 

from Past, Proposed, and Future Lease Sales. .........................................................3-158

Table 3-24. Cumulative G&G Surveying Activities Expected in the Gulf of Mexico 

(2017-2086). ...............................................................................................................3-161

Table 3-25. Future Oil Transportation Projections Associated with the Cumulative OCS Oil 

and Gas Program (2017-2086), Including All Future Transportation that is 

Projected to Occur from Past, Proposed, and Future Lease Sales...........................3-164
xxxii Gulf of Mexico Multisale EIS

Table 3-26. Number of Vessel Calls at U.S. Gulf Ports Between 2002 and 20111. .....................3-170

Table 3-27. Quantities of Dredged Materials Disposed of in Ocean Dredged-Material Disposal 

Sites Between 2004 and 2013....................................................................................3-176

Table 3-28. Average Annual Inputs of Petroleum Hydrocarbons to Coastal Waters of the 

Gulf of Mexico, 1990-1999. ........................................................................................3-179

Table 3-29. Average Annual Inputs of Petroleum Hydrocarbons to Offshore Waters of the 

Gulf of Mexico, 1990-1999. ........................................................................................3-180

Table 3-30. Projected OCS Sand Resource Needs for Planned Restoration Projects.................3-189

Table 3-31. Hurricane Landfalls in the Northern Gulf of Mexico from 1995 through 2016. ..........3-208

Table 3-32. Oil Spilled from Pipelines on the Federal OCS, 2002-2009.......................................3-209

Table 4-1. Air Quality Impact-Producing Factors That Are Reasonably Foreseeable. ................. 4-14

Table 4-2. National Ambient Air Quality Standards....................................................................... 4-17

Table 4-3. Nonattainment and Maintenance Areas in the Gulf of Mexico Region. ....................... 4-19

Table 4-4. Source Categories for Source Apportionment Calculations......................................... 4-37

Table 4-5. NAAQS and PSD Increments....................................................................................... 4-38

Table 4-6. Class I and Sensitive Class II Areas in Gulf Coast and Nearby States. ...................... 4-43

Table 4-7. Source Group for Incremental Impacts Analysis.......................................................... 4-45

Table 4-8. Water Quality Impact-Producing Factors That Are Reasonably Foreseeable............. 4-54

Table 4-9. Estuarine Systems Impact-Producing Factors That Are Reasonably Foreseeable..... 4-70

Table 4-10. Coastal Barrier Beaches and Associated Dunes Impact-Producing Factors That 

Are Reasonably Foreseeable....................................................................................... 4-97

Table 4-11. Deepwater Benthic Communities Impact-Producing Factors That are Reasonably 

Foreseeable................................................................................................................4-116

Table 4-12. Sargassum and Associated Communities Impact-Producing Factors That Are 

Reasonably Foreseeable............................................................................................4-145 

Table 4-13. Topographic Features Impact-Producing Factors That Are Reasonably 

Foreseeable................................................................................................................4-164

Table 4-14. Pinnacles and Low-Relief Features Impact-Producing Factors That Are 

Reasonably Foreseeable............................................................................................4-185

Table 4-15. Fish and Invertebrate Resources Impact-Producing Factors That Are Reasonably 

Foreseeable................................................................................................................4-215

Table 4-16. Birds Impact-Producing Factors That Are Reasonably Foreseeable.........................4-233

Table 4-17. Species within the Gulf of Mexico That Are Protected Under the Endangered 

Species Act and/or the Marine Mammal Protection Act.............................................4-260

Table 4-18. Protected Species Impact-Producing Factors That Are Reasonably Foreseeable. ..4-263

Table 4-19. Best Available Population Estimates for Marine Mammal Species in the Northern 

Gulf of Mexico.............................................................................................................4-267

Table 4-20. Commercial Fisheries Impact-Producing Factors That Are Reasonably 

Foreseeable................................................................................................................4-357

Table 4-21. Landings Revenues: Landings Revenue by Species and State. ..............................4-359

Table 4-22. Recreational Fishing Impact Producing Factors That Are Reasonably 

Foreseeable................................................................................................................4-367

Table 4-23. CPA and EPA Effort Data: Angler Trips in the Gulf of Mexico..................................4-369

Table 4-24. CPA and EPA Catch Data: Number of Fish Species Caught by Recreational 

Anglers from 2008 through 2013 in Louisiana, Mississippi, and Alabama 

Combined....................................................................................................................4-371

Table 4-25. CPA and EPA Catch Data: Fish Species Caught by Recreational Anglers 

from 2008 through 2013 in West Florida....................................................................4-372

Table 4-26. Texas Effort Data: Number of Angler Trips from 2011 through 2015. ......................4-373

Table 4-27. Texas Catch Data: Top Species Landed by Recreational Fishermen......................4-374

Table 4-28. Recreational Resources Impact-Producing Factors That Are Reasonably 

Foreseeable. ...............................................................................................................4-382
List of Tables xxxiii

Table 4-29. Recreational and Tourism Employment and Value-Added in BOEM's Economic 

Impact Areas in 2013. .................................................................................................4-383

Table 4-30. Archaeological Surveys and Resources Identified, 2009-2014. ................................4-404

Table 4-31. Land Use and Coastal Infrastructure Impact-Producing Factors That Are 

Reasonably Foreseeable............................................................................................4-417

Table 4-32. Comparison of the 1954 and 2015 Populations by State...........................................4-429

Table 4-33. Economic and Demographic Information for BOEM's Economic Impact Areas 

in 2015. .......................................................................................................................4-441

Table 4-34. Sales Volumes, Sales Values, and Revenues...........................................................4-443

Table 4-35. Cumulative Low: MAG-PLAN Industry Expenditure Impacts....................................4-449

Table 4-36. Cumulative High: MAG-PLAN Industry Expenditure Impacts. ..................................4-450

Table 4-37. Economic and Demographic Information for BOEM's Economic Impact Areas 

in 2050. .......................................................................................................................4-452

Table 4-38. Gulf of Mexico Single Low: MAG-PLAN Industry Expenditure Impacts....................4-454

Table 4-39. Gulf of Mexico Single High: MAG-PLAN Industry Expenditure Impacts...................4-456

Table 4-40. CPA/EPA Single Low: MAG-PLAN Industry Expenditure Impacts. ..........................4-458

Table 4-41. CPA/EPA Single High: MAG-PLAN Industry Expenditure Impacts. .........................4-460

Table 4-42. WPA Single Low: MAG-PLAN Industry Expenditure Impacts...................................4-462

Table 4-43. WPA Single High: MAG-PLAN Industry Expenditure Impacts..................................4-463

Table B-1. Commonly Applied or “Standard” Mitigating Measures. ............................................... B-5 

Table F-1. Nonattainment and Maintenance Areas in the Southeastern U.S. ............................... F-5 

Table F-2. BOEM’s Gulf of Mexico OCS Region WRF Domain Configuration. ............................. F-8 

Table F-3. BOEM Gulf of Mexico OCS Region WRF Dataset Model Levels. .............................. F-10

Table F-4. BOEM Gulf of Mexico OCS Region WRF Physics Options........................................ F-13

Table F-5. Meteorological Model Performance Benchmarks for Simple and Complex 

Conditions.................................................................................................................... F-14

Table G-1. Nonattainment and Maintenance Areas in the Southeastern U.S. ............................... G-3 

Table G-2. Gulf of Mexico Air Quality Modeling Study Source Categories..................................... G-7 

Table G-3. Base Case Offshore Oil and Gas Production Source Emissions Estimates 

for the GOM Western and Central/Eastern Planning Areas. ...................................... G-10

Table G-4. Future Year Production Platform Emission Factors.................................................... G-21

Table G-5. Summary of Vessel Characteristics. ........................................................................... G-23

Table G-6. Load Factors to be Used in the Future Year Projections............................................ G-24

Table G-7. Marine Vessel Emission Factors (g/kW-hr)................................................................. G-24

Table G-8. Emission Estimates for the Western, Central, and Eastern Planning Areas, 

All Depths, By Year and Pollutant. .............................................................................. G-25

Table H-1. Nonattainment and Maintenance Areas in the Southeastern U.S. ............................... H-4 

Table H-1. Gulf of Mexico OCS Region Air Quality Modeling Study Source Categories ............... H-9 

Table H-3. 2012 Fire Criteria Air Pollutant Emissions Summary by Fire Type for BOEM’s 

36-, 12-, and 4-km Domains........................................................................................ H-14

Table H-4. 2012 Base Case and Future Year Emissions Summary by State for BOEM’S 

12-km Domain (only Gulf Coast States: Alabama, Florida, Louisiana, Mississippi, 

and Texas)................................................................................................................... H-18

Table H-5. 2012 Base Case and Future Year Emissions Summary by Source Category 

for BOEM’s 4-km Domain............................................................................................ H-26

Table H-6. Changes in Emissions between the 2012 Base Case and Future Year Emissions 

(short tons per year) by Source Category for BOEM’s 4-km Domain......................... H-27

Table H-7. Source Categories for Source Apportionment Calculations........................................ H-34

Table H-8. Domain Grid Definitions for the WRF and CAMx/CMAQ Modeling. ........................... H-35

Table H-9. Vertical Layer Interface Definition for WRF Simulations and the Layer-collapsing 

Scheme for the CAMx/CMAQ Layers.......................................................................... H-36

Table H-10. CAMx Model Configuration.......................................................................................... H-39

Table H-11. Definitions of Model Performance Evaluation Statistical Metrics................................ H-45
xxxiv Gulf of Mexico Multisale EIS

Table H-12. Ozone and PM Model Performance Goals and Criteria.............................................. H-46

Table H-13. Model Performance Statistics at Different Observed Ozone Concentration 

Screening Thresholds Based on All Monitoring Sites in the 4-km Domain ................ H-55

Table H-14. NAAQS and PSD Increments...................................................................................... H-71

Table H-15. Source Group for Incremental Impacts Analysis......................................................... H-72

Table H-16. Class I and Sensitive Class II Areas in Gulf Coast and Nearby States. ..................... H-74

Table H-17. Current Year (DVC) and Future Year (DVF) Ozone Design Values at Ambient Air 

Monitoring Sites within the 4-km Modeling Domain from MATS................................. H-82

Table H-18. Ozone Current (DVC) and Future Year (DVF) Design Values and Reduction 

in DVF with Contributions from Individual Source Groups Removed. ........................ H-84

Table H-19. MATS Ozone Design Value Results for All Monitoring Sites Where Exclusion 

of Contributions from Source Group A or B is Sufficient to Reduce the Predicted 

Future Design Value (DVF) from Above the NAAQS to Below the NAAQS 

(all values in ppb)......................................................................................................... H-86

Table H-20. Current Year (DVC) and Future Year (DVF) 24-Hour PM2.5 Design Values 

for Monitoring Sites in the 4-km Modeling Domain from MATS.................................. H-93

Table H-21. 24-Hour PM2.5 Current (DVC) and Future Year (DVF) Design Values and 

Reduction in DVF with Contributions from Individual Source Groups Removed........ H-94

Table H-22. Current (DVC) and Projected Future (DVF) Annual Average PM2.5 Design Values 

for Monitoring Sites in the 4-km Modeling Domain ..................................................... H-95

Table H-23. Annual Average PM2.5 Future Year Design Values (DVF) and Change in DVF 

with Contributions from Individual Source Groups Removed ..................................... H-96

Table H-24. Maximum Source Group Contributions for PSD Pollutants at Class I and 

Sensitive Class II Areas in the 4-km Modeling Domain. ........................................... H-121

Table H-25. Source Group Contributions for PSD Pollutants at All Class I and Sensitive 

Class II Areas in the 4-km Modeling Domain............................................................ H-123

Table H-26. Incremental Visibility Impacts Relative to Natural Background Conditions 

from Source Group A................................................................................................. H-124

Table H-27. Incremental Visibility Impacts Relative to Natural Background Conditions 

from Source Group B................................................................................................. H-125

Table H-28. Cumulative Visibility Results for 20% Worst Visibility Days (W20%) at Class I 

Areas for Base (2012) Year (BY) and Future Year (FY) Scenarios with All 

Sources Included and with Contributions from Each Source Group Removed........ H-128

Table H-29. Differences in Cumulative Visibility Results for 20% Worst Visibility Days (W20%) 

at Class I Areas Between the Future Year (FY) and Base Year (BY) Scenarios 

and Contributions of Each Source Group to the Future Year Scenario Visibility...... H-130

Table H-30. Cumulative Visibility Results for 20% Best Visibility Days (B20%) at Class I 

Areas for Base (2012) Year (BY) and Future Year (FY) Scenarios with All 

Sources Included and with Contributions from Each Source Group Removed........ H-132

Table H-31. Differences in Cumulative Visibility Results for 20% Best Visibility Days (B20%) 

at Class I Areas Between the Future Year (FY) and Base Year (BY) Scenarios 

and Contributions of Each Source Group to the Future Year Scenario Visibility...... H-133

Table H-32. Deposition Analysis Threshold Values (kg/ha/yr) as Defined in the Federal Land 

Manager Guidance .................................................................................................... H-135

Table H-33. Incremental Deposition Impacts from Source Groups A and B at Class I and 

Sensitive Class II Areas in the 4-km Domain............................................................ H-135

Table H-34. Cumulative Nitrogen (N) and Sulfur (S) Deposition Impacts (kg/ha/yr) under 

the Base and Future Year Scenarios (shading indicates values exceeding 

the Critical Load threshold)........................................................................................ H-136

Table L-1. Public Comments and BOEM’s Response Matrix........................................................ L-14
APPENDIX A 

 

POSTLEASE PERMITTING AND APPROVAL PROCESSES

Postlease Permitting and Approval Processes A-3 

A POSTLEASE PERMITTING AND APPROVAL PROCESSES 

BOEM is responsible for managing the development of the Nation’s offshore energy and 

mineral resources in an environmentally and economically responsible way. The functions of BOEM 

include leasing, exploration and development plan administration, geological and geophysical 

permitting, environmental studies, NEPA analysis, resource evaluation, economic analysis, marine 

minerals, and renewable energy development. BOEM’s regulations for oil, gas, and sulphur lease 

operations are specified in 30 CFR parts 556, 550, 551 (except those aspects that pertain to drilling), 

and 554.

The BSEE is responsible for enforcing safety and environmental regulations. The functions 

of BSEE include all field operations, including permitting and research, inspections, offshore 

regulatory programs, oil-spill response, and training and environmental compliance functions. The 

BSEE’s regulations for oil, gas, and sulphur operations are specified in 30 CFR parts 250 and 254.

Measures to minimize potential impacts are an integral part of the OCS Program. These 

measures are implemented through lease stipulations, operating regulations, NTLs, and 

project-specific requirements or approval conditions that are applied to all plans for OCS oil- and 

gas-related activities (e.g., exploration and development plans, pipeline applications, and 

structure-removal applications). These measures address concerns such as endangered and 

threatened species, geologic and manmade hazards, military warning and ordnance disposal areas, 

archaeological sites, air quality, oil-spill response planning, chemosynthetic communities, artificial 

reefs, operations in hydrogen sulfide (H2S) prone areas, and shunting of drill effluents in the vicinity 

of biologically sensitive features. Refer to Appendix B (“Commonly Applied Mitigating Measures”) 

for more information on the mitigations that BOEM and BSEE could apply at the postlease stage. 

Standard mitigating measures in the Gulf of Mexico OCS include the following:

• limiting the size of explosive charges used for structure removals (NTL 

2010-G05);

• requiring placement of explosive charges at least 15 ft (5 m) below the mudline;

• requiring site-clearance procedures to eliminate potential snags to commercial 

fishing nets upon abandonment; 

• establishment of No Activity and Modified Activity Zones around high-relief live 

bottoms;

• requiring remote-sensing surveys to detect and avoid potential archaeological 

sites and biologically sensitive areas such as low-relief live bottoms, pinnacles, 

and chemosynthetic communities; and

• requiring coordination with the military to prevent multiuse conflicts between OCS 

and military activities.
A-4 Gulf of Mexico Multisale EIS

BOEM and BSEE issue NTLs to provide clarification, description, or interpretation of a 

regulation; guidelines on the implementation of a special lease stipulation or regional requirement; or 

convey administrative information. A detailed listing of current Gulf of Mexico OCS Region NTLs is 

available through BOEM’s and BSEE’s Gulf of Mexico OCS Region websites (http://www.boem.gov/

notices-to-lessees-and-operators/ and http://www.bsee.gov/Regulations-and-Guidance/Notices-toLessees-and-Operators/) or through the Region’s Public Information Office at 1-800-200-GULF.

Formal plans must be submitted to BOEM for review and approval before any projectspecific activities, except for ancillary activities (such as geological and geophysical activities or 

studies that model potential oil and hazardous substance spills), can begin on a lease. Conditions of 

approval are mechanisms to control or mitigate potential safety or environmental problems 

associated with proposed operations. Conditions of approval are based on BOEM’s technical and 

environmental evaluations of the proposed operations. Comments from Federal and State agencies 

(as applicable) are also considered in establishing conditions. Conditions may be applied to any 

OCS plan, permit, right-of-use of easement, or pipeline right-of-way grant.

Some BOEM-identified mitigating measures are implemented through cooperative 

agreements or coordination with the oil and gas industry and Federal and State agencies. These 

measures include NMFS’ Observer Program to protect marine mammals and sea turtles when OCS 

structures are removed using explosives, labeling of operational supplies to track sources of 

accidental debris loss, development of methods of pipeline landfall to eliminate impacts to barrier 

beaches, and semiannual beach cleanup events.

The following postlease approval processes apply to the proposed lease sale areas in the 

WPA, CPA, and EPA.

A.1 GEOLOGICAL AND GEOPHYSICAL SURVEY AUTHORIZATIONS

A geological and geophysical (G&G) permit must be obtained from BOEM prior to conducting 

off-lease geological or geophysical exploration or scientific research on unleased OCS lands or on 

lands under lease to a third party (30 CFR §§ 551.4(a) and (b)). Geological investigations include 

various seafloor sampling techniques to determine the geochemical, geotechnical, or engineering 

properties of the sediments.

Ancillary activities, or G&G exploration and development activities conducted on lease, are 

defined in 30 CFR § 250.105 and 30 CFR § 550.105 with regulations outlined in 30 CFR §§ 550.207 

through 550.210. Ancillary activities include geological and high-resolution geophysical, 

geotechnical, archaeological, biological, physical oceanographic, meteorological, socioeconomic, or 

other surveys; or various types of modeling studies. This Agency issued NTL 2009-G34, “Ancillary 

Activities,” to provide guidance and clarification on conducting ancillary activities in BOEM’s Gulf of 

Mexico OCS Region. Operators should notify the Gulf of Mexico OCS Region, Regional Supervisor, 

Office of Leasing and Plans, Plans Section, in writing 30 days in advance before conducting any of 

the following types of ancillary activities related to a G&G exploration or development G&G activity:
Postlease Permitting and Approval Processes A-5 

• involving the use of an airgun or airgun array anywhere in the GOM regardless of 

water depth;

• independent of water depth, involving the use of explosives as an energy source; 

and

• independent of water depth, including ocean-bottom cable surveys, node 

surveys, and time-lapse (4D) surveys.

Additionally, NTL 2009-G34 clarifies that the Gulf of Mexico OCS Region, Regional 

Supervisor, Office of Leasing and Plans, Plans Section, should be notified in writing 15 days in 

advance before conducting the following types of other ancillary activities:

• involving the use of an airgun or airgun array anywhere in the EPA of the GOM 

regardless of water depth and 200 m (656 ft) or greater for the rest of the GOM;

• involving bottom disturbance, independent of water depth, including oceanbottom cable surveys, node surveys, and time-lapse (4D) surveys; and

• a geotechnical evaluation involving piston/gravity coring or the recovery of 

sediment specimens by grab sampling or similar technique and/or any dredging 

or other ancillary activity that disturbs the seafloor (including deployment and 

retrieval of bottom cables, anchors, or other equipment).

This NTL also provides guidance for each type of ancillary activity, the type and level of 

BOEM review, and follow-up, post-survey report requirements. 

Shallow hazard assessments are required under 30 CFR §§ 550.214 and 50.244; NTL 

2008-G05, “Shallow Hazards Program,” explains the requirements for these surveys and their 

reports. Included in shallow hazard assessments is a structural and stratigraphic interpretation of 

seismic data to qualitatively delineate abnormal pressure zones, shallow free gas, seafloor 

instability, shallow waterflow, and gas hydrates.

Seismic surveys are performed to obtain information on surface and near-surface geology 

and on subsurface geologic formations. Low-energy, high-resolution seismic surveys collect data on 

surficial geology used to identify potential shallow geologic or manmade hazards (e.g., faults or 

pipelines) for engineering and site planning for bottom-founded structures. The high-resolution 

surveys are also used to identify environmental and archaeological resources such as low-relief live

bottom areas, pinnacles, chemosynthetic community habitat, and shipwrecks. High-energy, deeppenetration, common-depth-point (CDP) seismic surveys obtain data about geologic formations 

thousands of feet below the seafloor. The two-dimensional (2D) and three-dimensional (3D) CDP 

data are used to map structure features of stratigraphically important horizons in order to identify 

potential hydrocarbon traps. They can also be used to map the extent of potential habitat for 

chemosynthetic communities. In some situations, a set of 3D surveys can be run over a time 
A-6 Gulf of Mexico Multisale EIS

interval to produce a four-dimensional (4D), or “time-lapse,” survey that could be used to 

characterize production reservoirs.

BOEM’s predecessor completed the Geological and Geophysical Exploration for Mineral 

Resources on the Gulf of Mexico Outer Continental Shelf: Programmatic Environmental 

Assessment (G&G Programmatic EA) (USDOI, MMS, 2004). Upon receiving a complete G&G 

permit application, BOEM conducts a NEPA review that will result in a categorical exclusion, an EA, 

or an EIS in accordance with the G&G Programmatic EA’s conclusions, NEPA guidelines, and other 

applicable BOEM policies. When required under an approved coastal management program, 

proposed G&G permit activities must receive State concurrence prior to BOEM permit approval.

A.2 EXPLORATION AND DEVELOPMENT PLANS

To ensure compliance with the OCSLA, other laws, applicable regulations, and lease 

provisions, and to enable BOEM to carry out its functions and responsibilities, formal plans (30 CFR 

§§ 550.211 and 550.241) with supporting information must be submitted for review and approval by 

BOEM before an operator may begin exploration, development, or production activities on any lease. 

Supporting environmental information, archaeological reports, biological reports (monitoring and/or 

live-bottom survey), and other environmental data determined necessary must be submitted with an 

OCS plan. This information provides the basis for an analysis of both offshore and onshore impacts 

that may occur as a result of the activities. BOEM may require additional specific supporting 

information to aid in the evaluation of the potential environmental impacts of the proposed activities. 

BOEM can require an amendment of an OCS plan based on inadequate or inaccurate supporting 

information. The 30 CFR part 550 subpart B regulations were revised to update the information that 

must be submitted with OCS plans and were published in the Federal Register on August 30, 2005 

(Federal Register, 2005).

The OCS plans are reviewed by subject-matter experts that include, but are not limited to 

geologists, geophysicists, engineers, biologists, archaeologists, air quality specialists, water quality 

specialists, oil-spill specialists, NEPA coordinators, and/or environmental scientists. The plans and 

accompanying information are evaluated to determine whether any seafloor or drilling hazards are 

present; that air and water quality issues are addressed; that plans for hydrocarbon resource 

conservation, development, and drainage are adequate; that environmental issues and potential 

impacts are properly evaluated and mitigated; and that a proposed action is in compliance with 

NEPA, the Coastal Zone Management Act, BOEM’s operating regulations, and other requirements. 

Federal agencies, including FWS, NMFS, USEPA, U.S. Navy, U.S. Air Force, and USCG, may be 

consulted if the proposal has the potential to impact areas under their jurisdiction. Each Gulf Coast 

State has a designated CZM agency that takes part in the review process. The OCS plans are also 

made available to the general public for comment through BOEM’s Gulf of Mexico OCS Region’s 

Public Information Office.

In response to deepwater activities in the Gulf of Mexico, this Agency developed a 

comprehensive strategy to address NEPA compliance and environmental issues in the deepwater 
Postlease Permitting and Approval Processes A-7 

areas. A key component of that strategy was the completion of a Programmatic EA to evaluate the 

potential effects of deepwater technologies and operations (USDOI, MMS, 2000). As a supplement 

to the Programmatic EA, this Agency prepared a series of technical papers that provide a summary 

description of the different types of structures that may be employed in the development and 

production of hydrocarbon resources in the deepwater areas of the GOM (Regg et al., 2000). 

Information in the Programmatic EA and technical papers were used in the preparation of this 

Multisale EIS.

On the basis of BOEM’s reviews of the OCS plan, the findings of the proposal-specific 

environmental review, EA, or EIS, and other applicable BOEM studies and NEPA documents, the 

OCS plan is approved or disapproved by BOEM, or modified and resubmitted for further analyses 

and decision. Although few OCS plans are ultimately disapproved, many must be amended prior to 

approval to fully comply with BOEM’s operating regulations and requirements or other Federal laws, 

to address reviewing agencies’ concerns, or to avoid potential hazards or impacts to environmental 

resources.

Exploration Plans

An exploration plan (EP) must be submitted to BOEM for review and approval before any 

exploration activities, except for preliminary activities (such as hazard surveys or geophysical 

surveys), can begin on a lease. The EP describes exploration activities, drilling rig or vessel,

proposed drilling and well-testing operations, environmental monitoring plans, and other relevant 

information, and it includes a proposed schedule of the exploration activities. Guidelines and 

environmental information requirements for lessees and operators submitting an EP are addressed 

in 30 CFR § 550.211 and are further explained in NTL 2008-G05, “Shallow Hazards Program,” and 

NTL 2009-G27, “Submitting Exploration Plans and Development Operations Coordination 

Documents.” The NTL 2008-G04 provides guidance on information requirements and establishes 

the contents for OCS plans required by 30 CFR part 550 subpart B. The NTL 2015-BOEM-N01, 

“Information Requirements for Exploration Plans, Development and Production Plans, and 

Development Operations Coordination Documents on the OCS for Worst Case Discharge and 

Blowout Scenarios,” effective January 14, 2015, supersedes NTL 2010-N06. The NTL 2009-G27 

clarifies guidance for submitting OCS plans to BOEM’s Gulf of Mexico OCS Region.

After receiving an EP, BOEM determines if the plan is complete and adequate before 

technical and environmental reviews. BOEM evaluates the proposed exploration activities for 

potential impacts relative to geohazards and manmade hazards (including existing pipelines), 

archaeological resources, endangered species, sensitive biological features, water and air quality, 

oil-spill response, State CZMA requirements, and other uses (e.g., military operations) of the OCS. 

The EP is reviewed for compliance with all applicable laws and regulations.

A site-specific environmental review (SSER) is generated and completed for each plan. As a 

result of the SSER, a determination is made whether a categorical exclusion can be applied or 

whether additional NEPA analysis in the form of an EA or EIS will be prepared for the proposed 
A-8 Gulf of Mexico Multisale EIS

activity. Categorical exclusions are "a category of actions which do not individually or cumulatively 

have a significant effect on the human environment and for which, therefore, neither an 

environmental assessment nor an environmental impact statement is required" (40 CFR § 1508.4). 

In the event an action cannot be categorically excluded, the decision to prepare an EA will be made 

by the Regional Supervisor, Leasing and Environment or the Chief, Environmental Division. The 

SSER is based on the best available information, which may include the geophysical report (for 

determining the potential for the presence of deepwater benthic communities); archaeological report; 

air emissions data; waste and discharge data; live-bottom survey and report; biological monitoring 

plan; and recommendations by the affected State(s), DOD, FWS, NMFS, and/or internal BOEM 

offices. As part of the review process, each EP must contain a certification of consistency and the 

necessary data and information for the State to determine that the proposed activities comply with 

the enforceable policies of the States’ approved Coastal Management Plan (CMP) and that such 

activities will be conducted in a manner that is consistent with the CMP (16 U.S.C. § 1456(c)(3)(A) 

and 15 CFR § 930.76).

If the EP is approved, and prior to conducting drilling operations, the operator is required to 

submit and obtain approval for an Application for Permit to Drill (APD) (refer to Wells under Permits 

and Applications below).

Operations Plans

In 1992, this Agency formed an internal Deepwater Task Force to address technical issues 

and regulatory concerns relating to deepwater (>1,000 ft; 305 m) operations and projects utilizing 

subsea technology. Based on the Deepwater Task Force’s recommendation, an NTL (2000-N06) 

was at first developed that was incorporated into 30 CFR part 550 subpart B. The revisions to 

subpart B were finalized August 30, 2005, and it requires operators to submit a Deepwater 

Operations Plan (DWOP) for all operations in deep water (400 m [1,312 ft] or greater) and all 

projects using subsea technology. DeepStar, an industry-wide cooperative workgroup focused on 

deepwater regulatory issues and critical technology development issues, worked closely with this 

Agency’s Deepwater Task Force to develop the initial guidelines for the DWOP. The DWOP 

requirement was established to address regulatory issues and concerns that were not addressed in 

the Agency’s then-existing regulatory framework, and it is intended to initiate an early dialogue 

between BSEE and industry before major capital expenditures on deepwater and subsea projects 

are committed. Deepwater technology has been evolving faster than BSEE’s ability to revise OCS 

regulations; the DWOP was established through the NTL process, which provides for a more timely 

and flexible approach to provide guidance on regulatory requirements and keep pace with the 

expanding deepwater operations and subsea technology.

The DWOP is intended to address the different functional requirements of production 

equipment in deep water, particularly the technological requirements associated with subsea 

production systems, and the complexity of deepwater production facilities. The DWOP provides 

BSEE with information specific to deepwater equipment issues to demonstrate that a deepwater 

project is being developed in an acceptable manner as mandated in the OCSLA, as amended, and 
Postlease Permitting and Approval Processes A-9 

BSEE’s operating regulations at 30 CFR part 250. The BSEE reviews deepwater development 

activities from a total system perspective, emphasizing operational safety, environmental protection, 

and conservation of natural resources. The DWOP process is a phased approach that parallels the 

operator’s state of knowledge about how a field will be developed. A DWOP outlines the design, 

fabrication, and installation of the proposed development/production system and its components. A 

DWOP will include structural aspects of the facility (i.e., fixed, floating, or subsea); station-keeping 

(includes mooring system); wellbore, completion, and riser systems; safety systems; product 

removal or offtake systems; and hazards and operability of the production system. The DWOP 

provides BSEE with the information to determine that the operator has designed and built sufficient 

safeguards into the production system to prevent the occurrence of significant safety or 

environmental incidents. The DWOP, in conjunction with other permit applications, provides BSEE 

the opportunity to assure that the production system is suitable for the conditions in which it will 

operate.

This Agency recently completed a review of several industry-developed, recommended 

practices that address the mooring and risers for floating production facilities. The recommended 

practices address such things as riser design, mooring system design (station-keeping), and hazard 

analysis. Hazard analyses allow BSEE to be assured that the operator has anticipated emergencies 

and is prepared to address them, either through their design or through the operation of the 

equipment in question. The BSEE released these clarifications of its requirements in NTL’s: NTL 

2009-G03, “Synthetic Mooring Systems”; NTL 2009-G11, “Accidental Disconnect of Marine Drilling 

Risers”; and NTL 2009-G13, “Guidelines for Tie-downs on OCS Production Platforms for Upcoming 

Hurricane Seasons.”

Conservation Reviews

One of BOEM and BSEE’s primary responsibilities is to ensure development of economically 

producible reservoirs according to sound resource conservation, engineering, and economic 

practices as cited in 30 CFR §§ 550.202(c), 550.203, 550.210, 550.296, 550.297, 550.298, 550.299, 

250.204, and 250.205. Operators should submit the necessary information as part of their EP, initial 

and supplemental development operations and coordination documents (DOCDs) or development 

and production plans (DPPs), and Conservation Information Document. Conservation reviews are 

performed to ensure that economic reserves are fully developed and produced, and that there is no 

harm to the ultimate recovery.

Development Operations and Coordination Documents and Development and Production 

Plans

Before any development operations can begin on a lease in a proposed lease sale area, a 

DOCD/DPP must be submitted to BOEM for review and decision. A DOCD/DPP describes the 

proposed development activities, drilling activities, platforms or other facilities, proposed production 

operations, environmental monitoring plans, and other relevant information; and it includes a 

proposed schedule of development and production activities. Requirements for lessees and 
A-10 Gulf of Mexico Multisale EIS

operators submitting a DOCD/DPP are addressed in 30 CFR §§ 550.241 and 550.242, and 

information guidelines for DOCDs/DPPs are provided in NTLs 2008-G04, 2009-G27, and 2010-N06.

After receiving a DOCD/DPP, BOEM performs technical and environmental reviews. BOEM 

evaluates the proposed activity for potential impacts relative to geohazards and manmade hazards 

(including existing pipelines), archaeological resources, endangered species, sensitive biological 

features, water and air quality, oil-spill response, State CMPs requirements, and other uses (e.g., 

military operations) of the OCS. The DOCD/DPP is reviewed for compliance with all applicable laws 

and regulations.

A SSER is generated and completed for each DOCD/DPP. As a result of the SSER, a 

determination is made whether a categorical exclusion can be applied or whether additional NEPA 

analysis in the form of an EA or EIS will be prepared for the proposed activity. The environmental 

review is based on the best available information, which may include the geophysical report (for 

determining the potential for the presence of deepwater benthic communities); archaeological report; 

air emissions data; waste and discharge data, live-bottom survey and report; biological monitoring 

plan; and recommendations by the affected State(s), DOD, FWS, NMFS, and/or internal BOEM 

offices.

As part of the review process, each DOCD/DPP must contain a certification of consistency 

and the necessary data and information for the State to determine that the proposed activities 

comply with the enforceable policies of the States’ approved CMP and that such activities will be 

conducted in a manner that is consistent with the CMP (16 U.S.C. § 1456(c)(3)(A) and 15 CFR § 

930.76).

New or Unusual Technologies

Technologies continue to evolve to meet the technical, environmental, and economic 

challenges of deepwater development. New or unusual technologies (NUTs) may be identified by 

the operator in its EP, DWOP, and DOCD/DPP or through BOEM’s plan review processes. Some of 

the technologies proposed for use by the operators are actually extended applications of existing 

technologies and interface with the environment in essentially the same way as well-known or 

conventional technologies. These technologies are reviewed by BOEM for alternative compliance or 

departures that may trigger additional environmental review. Some examples of new technologies 

that do not affect the environment differently and that are being deployed in the OCS Program are 

synthetic mooring lines, subsurface safety devices, and multiplex subsea controls.

Some new technologies differ from established technologies in how they function or interface 

with the environment. These include equipment or procedures that have not been installed or used 

in Gulf of Mexico OCS waters. Having no operational history, they have not been assessed by 

BOEM through technical and environmental reviews. New technologies may be outside the 

framework established by BOEM’s regulations and, thus, their performance (safety, environmental 

protection, efficiency, etc.) has not been addressed by BOEM. The degree to which these new 
Postlease Permitting and Approval Processes A-11

technologies interface with the environment and the potential impacts that may result are considered 

in determining the level of NEPA review that would be initiated.

BOEM has developed a NUTs’ matrix to help facilitate decisions on the appropriate level of 

engineering and environmental review needed for a proposed technology. Technologies will be 

added to the NUTs’ matrix as they emerge, and technologies will be removed from the matrix as 

sufficient experience is gained in their implementation. From an environmental perspective, the 

matrix characterizes new technologies into three categories: technologies that may affect the 

environment; technologies that do not interact with the environment any differently than 

“conventional” technologies; and technologies about which BOEM does not have sufficient 

information to determine their potential impacts to the environment. In this latter case, BOEM will 

seek to gain the necessary information from operators or manufacturers regarding the technologies 

to make an appropriate determination on potential effects on the environment.

Alternative Compliance and Departures

The BSEE’s project-specific engineering safety review ensures that equipment proposed for 

use is designed to withstand the operational and environmental conditions in which it would operate. 

When an OCS operator proposes the use of new or unusual technology or procedures not 

specifically addressed in established BSEE regulations, the operations are evaluated for alternative 

compliance or departure determination. Any new technologies or equipment that represents an 

alternative compliance or departure from existing BSEE regulations must be fully described and 

justified before they would be approved for use. For BSEE and BOEM to grant alternative 

compliance or departure approval, the operator must demonstrate an equivalent or improved degree 

of protection as specified in 30 CFR § 250.141 and 30 CFR § 550.141. Comparative analysis with 

other approved systems, equipment, and procedures is one tool that BSEE uses to assess the 

adequacy of protection provided by alternative technology or operations. Actual operational 

experience is necessary with alternative compliance measures before BSEE would consider them as 

proven technology.

Emergency Plans

Criteria, models, and procedures for shutdown operations and the orderly evacuation of 

platforms and rigs for an impending hurricane have been in place in the Gulf of Mexico OCS for 

more than 30 years. (Such emergency plans are different from the oil-spill response plans described 

later in this chapter.) Operating experience from extensive drilling activities and more than 

4,000 platforms during the 50-plus years of the Gulf of Mexico OCS Program have demonstrated the 

effectiveness and safety of securing wells and evacuating a facility in advance of severe weather 

conditions. Preinstallation efforts, historical experience with similar systems, testing, and the actual 

operating experience (under normal conditions and in response to emergency situations) are used to 

formulate the exact time needed to secure the wells and production facility and to evacuate it as 

necessary. Operators develop site-specific curtailment, securing, and evacuation plans that vary in 

complexity and formality by operator and type of activity. In general terms, all plans are intended to 

make sure the facility (or well) is secured in advance of an impending storm or developing 
A-12 Gulf of Mexico Multisale EIS

emergency. The operating procedures developed during the engineering, design, and 

manufacturing phases of the project, coupled with the results (recommended actions) from hazard 

analyses performed, are used to develop the emergency action and curtailment plans. Evacuation 

and production curtailment must consider a combination of factors, including the well status (drilling, 

producing, etc.) and the type and mechanics of wellbore operations. These factors are analyzed 

onsite through a decisionmaking process that involves onsite facility managers. The emphasis is on 

making real-time, situation-specific decisions and forecasting based on available information. 

Details of the shut-in criteria and various alerts are addressed on a case-by-case basis, as explained 

below.

Plans for shutting in production from the subsea wells are addressed as part of the 

emergency curtailment plan. The plan specifies the various alerts and shutdown criteria linked to 

both weather and facility performance data, with the intent to have operations suspended and the 

wells secured in the event of a hurricane or emergency situation. Ensuring adequate time to safely 

and efficiently suspend operations and secure the well is a key component of the planning effort. 

Clearly defined responsibilities for the facility personnel are part of the successful implementation of 

the emergency response effort.

For a severe weather event such as a hurricane, emergency curtailment plans would 

address the criteria and structured procedures for suspending operations and ultimately securing the 

wellbore(s) prior to weather conditions that could exceed the design operating limitations of the 

drilling or production unit. For drilling operations, the plan might also address procedures for 

disconnecting and moving the drilling unit off location after the well has been secured, should the 

environmental conditions exceed the floating drilling unit’s capability to maintain station. Curtailment 

of operations consists of various stages of “alerts” indicating the deterioration of meteorological, 

oceanographic, or wellbore conditions. Higher alert levels require increased monitoring, the 

curtailment of lengthy wellbore operations, and, if conditions warrant, the eventual securing of the 

well. If conditions improve, operations could resume based on the limitations established in the 

contingency plan for the known environmental conditions. The same emergency curtailment plans 

would be implemented in an anticipated or impending emergency situation, such as the threat of a 

terrorist attack.

Neither BSEE nor USCG mandates that an operator must evacuate a production facility for a 

hurricane; it is a decision that rests solely with the operator. The USCG does require the submittal 

of an emergency evacuation plan that addresses the operator’s intentions for evacuation of 

nonessential personnel, egress routes on the production facility, lifesaving and personnel safety 

devices, firefighting equipment, etc. As activities move farther from shore, it may become safer to 

not evacuate the facility because helicopter operations become inherently more risky with greater 

flight times. Severe weather conditions also increase the risks associated with helicopter operations. 

The precedent for leaving a facility manned during severe weather is established in the North Sea 

and other operating basins.
Postlease Permitting and Approval Processes A-13

Redundant, fail-safe, automatic shut-in systems located inside the wellbore and at the sea 

surface, and in some instances at the seafloor, are designed to prevent or minimize pollution. These 

systems are designed and tested to ensure proper operation should a production facility or well be 

catastrophically damaged. Testing occurs at regular intervals with predetermined performance limits 

designed to ensure functioning of the systems in case of an emergency.

After the Deepwater Horizon explosion, oil spill, and cleanup, the testing requirements for 

well control systems came under immediate scrutiny in the DOI Secretary’s Increased Safety 

Measures for Energy Development on the Outer Continental Shelf (Safety Measures Report), which 

was delivered on May 27, 2010 (USDOI, 2010). The Safety Measures Report included a 

recommendation of a program for immediate recertification of blowout preventers (BOPs). As stated 

above, the new regulatory section at 30 CFR § 250.451(i) requires that, if a blind-shear ram or 

casing shear ram is activated in a well control situation where the pipe is sheared, the BOP stack 

must be retrieved, fully inspected, and tested.

A.3 PERMITS AND APPLICATIONS

After the approval of an EP or DOCD/DPP, the operator submits applications for specific 

activities to BOEM for approval. These applications include those for drilling wells; well-test flaring; 

temporary well abandonment; installing a well protection structure, production platforms, satellite 

structures, subsea wellheads and manifolds, and pipelines; installation of production facilities; 

commencing production operations; platform removal and lease abandonment; and pipeline 

decommissioning.

Wells

The BSEE requirements for the drilling of wells can be found at 30 CFR part 250 subpart D. 

Lessees are required to take precautions to keep all wells under control at all times. The lessee 

must use the best available and safest technology to enhance the evaluation of abnormal pressure 

conditions and to minimize the potential for uncontrolled well flow.

Prior to conducting drilling operations, the operator is required to submit and obtain approval 

for an Application for Permit to Drill (APD). The APD requires detailed information (including project 

layout at a scale of 1:24,000, design criteria for well control and casing, specifications for blowout 

preventers, a mud program, cementing program, directional drilling plans, etc.) to allow for BOEM’s 

evaluation of operational safety and pollution-prevention measures. The APD is reviewed for 

conformance with the engineering requirements and other technical considerations.

The BSEE is responsible for conducting technical and safety reviews of all drilling, workover, 

and production operations on the OCS. These detailed analyses determine if the lessee’s proposed 

operation is in compliance with all regulations and all current health, safety, environmental, and 

classical engineering standards.
A-14 Gulf of Mexico Multisale EIS

The BSEE regulations at 30 CFR §§ 250.1710-1717 address the requirements for 

permanent abandonment of a well on the OCS. A permanent abandonment includes the isolation of 

zones in the open wellbore, plugging of perforated intervals, plugging the annular space between 

casings (if they are open), setting a surface plug, and cutting and retrieving the casing at least 15 ft 

(5 m) below the mudline. All plugs must be tested in accordance with the regulations. There are no 

routine surveys of permanently abandoned well locations. If a well were found to be leaking, BOEM 

would require the operator of record to perform an intervention to repair the abandonment. If a well 

is temporarily abandoned at the seafloor, an operator must provide BSEE with an annual report 

summarizing plans to permanently abandon the well or to bring the well into production.

Platforms and Structures

The BSEE does a technical review of all proposed structure designs and installation 

procedures. All proposed facilities are reviewed for structural integrity. These detailed engineering 

reviews entail an evaluation of all operator proposals for fabrication, installation, modification, and 

repair of all mobile and fixed structures. The lessee must design, fabricate, install, use, inspect, and 

maintain all platforms and structures on the OCS to assure their structural integrity for the safe 

conduct of operations at specific locations. Applications for platform and structure approval are filed 

in accordance with 30 CFR § 250.901. Design requirements are presented in detail at 30 CFR §§ 

250.904 through 250.909. The lessee evaluates characteristic environmental conditions associated 

with operational functions to be performed. Factors such as waves, wind, currents, tides, 

temperature, and the potential for marine growth on the structure are considered. In addition, 

pursuant to 30 CFR §§ 250.902 and 250.903, a program has been established by BSEE to assure 

that new structures meeting the conditions listed under 30 CFR § 250.900(c) are designed, 

fabricated, and installed using standardized procedures to prevent structural failures. This program 

facilitates review of such structures and uses third-party expertise and technical input in the 

verification process through the use of a Certified Verification Agent. After installation, platforms and 

structures are required to be periodically inspected and maintained under 30 CFR § 250.912.

Pipelines

Regulatory processes and jurisdictional authority concerning pipelines on the OCS and in 

coastal areas are shared by several Federal agencies, including DOI, the Department of 

Transportation (DOT), the COE, the Federal Energy Regulatory Commission, and USCG. Aside 

from the enforcement of pipeline regulations, these agencies have the responsibility of overseeing 

and regulating the following areas: the placement of structures on the OCS and pipelines in areas 

that affect navigation; the certification of proposed projects involving the transportation or sale of 

interstate natural gas, including OCS gas; and the right of eminent domain exercised by pipeline 

companies onshore. In addition, the DOT is responsible for promulgating and enforcing safety 

regulations for the transportation in interstate commerce of natural gas, liquefied natural gas, and 

hazardous liquids by pipeline. This includes, for the most part, offshore pipelines on State lands 

beneath navigable waters and on the OCS that are operated by transmission companies. The 

regulations are contained in 49 CFR parts 191 through 193 and 195. In a Memorandum of 

Understanding between the DOT and DOI dated December 10, 1996, each party’s respective 
Postlease Permitting and Approval Processes A-15

regulatory responsibilities are outlined. The DOT is responsible for establishing and enforcing 

design, construction, operation, and maintenance regulations, and for investigating accidents for all 

OCS transportation pipelines beginning downstream of the point at which operating responsibility 

transfers from a producing operator to a transporting operator. The DOI’s responsibility extends 

upstream from the transfer point described above.

The BSEE is responsible for regulatory oversight of the design, installation, modification, 

repair, and decommissioning of OCS producer-operated oil and gas pipelines. The BSEE’s 

operating regulations for pipelines, found at 30 CFR part 250 subpart J, are intended to provide safe 

and pollution-free transportation of fluids in a manner that does not unduly interfere with other users 

of the OCS. Pipeline applications may be for on-lease pipelines or right-of-way pipelines that cross 

other lessees’ leases or unleased areas of the OCS. Pipeline permit applications to BSEE include 

the pipeline location drawing, profile drawing, safety schematic drawing, pipe design data, a shallow 

hazard survey report, and an archaeological report, if applicable.

The BSEE evaluates the design and proposed route of all OCS pipelines. Proposed pipeline 

routes are evaluated for potential seafloor or subsea geologic hazards and other natural or 

manmade seafloor or subsurface features or conditions (including other pipelines) that could have 

an adverse impact on the pipeline or that could be adversely impacted by the proposed operations. 

Routes are also evaluated for potential impacts on archaeological resources and biological 

communities. A NEPA review is conducted in accordance with applicable policies and guidelines. 

BOEM prepares an EA on all pipeline right-of-ways that go ashore. For Federal consistency, 

applicants must comply with the regulations as clarified in NTL 2007-G20, “Coastal Zone 

Management Program Requirements for OCS Right-of-way Pipeline Applications.” All Gulf Coast 

States require consistency review of right-of-way pipeline applications as described in the clarifying 

NTL. The design of the proposed pipeline is evaluated for an appropriate cathodic protection system 

to protect the pipeline from the effects of external corrosion on the pipe; an external pipeline coating 

system to prolong the service life of the pipeline; measures to protect the inside of the pipeline from 

the detrimental effects, if any, of the fluids being transported; proposed maximum allowable 

operating pressure and hydrostatic test pressure of the line; inclusion and settings of all safety 

devices required by regulation; and protection of other pipelines crossing the proposed route. Such 

an evaluation includes the following: (1) reviewing the calculations used by the applicant in order to 

determine whether the applicant properly considered such elements as the grade of pipe to be used, 

the wall thickness of the pipe, de-rating factors (the practice of operating a component well inside its 

normal operating limits to reduce the rate at which the component deteriorates) related to the 

submerged and riser portions of the pipeline, the pressure rating of any valves or flanges to be 

installed in the pipeline, the pressure rating of any other pipeline(s) into which the proposed line 

might be tied, and the required pressure to which the line must be tested before it is placed in 

service; (2) protective safety devices such as pressure sensors and remotely operated valves, the 

physical arrangement of those devices proposed to be installed by the applicant for the purposes of 

protecting the pipeline from possible overpressure conditions and for detecting and initiating a 

response to abnormally low-pressure conditions; and (3) the applicant’s planned compliance with 

regulations requiring that pipelines installed in water depths less than 200 ft (61 m) be buried to a 
A-16 Gulf of Mexico Multisale EIS

depth of at least 3 ft (1 m) (30 CFR § 250.1003). In addition, pipelines crossing fairways require a 

COE permit and may be required to be buried greater than 3 ft (1 m). 

Operators are required to periodically inspect pipeline routes. Monthly overflights are 

conducted to inspect pipeline routes for leakage. When a pipeline requires a repair, a repair plan 

notification and repair completion report must be submitted to BSEE for review and acceptance.

Applications for pipeline decommissioning must also be submitted for BSEE review and 

approval. Decommissioning applications are evaluated to ensure they will render the pipeline inert 

and/or to minimize the potential for the pipeline becoming a source of pollution by flushing and 

plugging the ends and to minimize the likelihood that the decommissioned line will become an 

obstruction to other users of the OCS by filling it with water and burying the ends.

In addition, BOEM’s Marine Minerals Program and Coastal Zone Management Coordinators, 

BSEE’s Pipelines Section, and the State of Louisiana’s Office of Coastal Management and Coastal 

Protection and Restoration Authority are working closely to ensure that sediment resources on the 

OCS are made available for restoration projects by requiring the removal of decommissioned 

pipelines. BOEM is also coordinating with BSEE’s Pipeline Section, the State of Louisiana, and 

applicants with regards to rerouting the proposed pipelines when an application is submitted for 

emplacement to avoid the sediment resources if at all possible.

A.4 INSPECTION AND ENFORCEMENT

The OCSLA authorizes and requires BSEE to provide for both an annual scheduled 

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

OCS. The inspections are to assure compliance with all regulatory constraints that allowed 

commencement of the operation.

The primary objective of an initial inspection is to assure proper installation of mobile drilling 

units and fixed structures, and proper functionality of their safety and pollution prevention equipment. 

After operations begin, additional announced and unannounced inspections are conducted. 

Unannounced inspections are conducted to foster a climate of safe operations, to maintain a BSEE 

presence, and to focus on operators with a poor performance record. These inspections are also 

conducted after a critical safety feature has previously been found defective. Poor performance 

generally means that more frequent, unannounced inspections may be conducted on a violator’s 

operation.

The annual inspection examines all safety equipment designed to prevent blowouts, fires, 

spills, or other major accidents. These annual inspections involve the inspection for installation and 

performance of all facilities’ safety-system components.

The inspectors follow the guidelines as established by the regulations, API RP 14C, and the 

specific BSEE-approved plan. The BSEE inspectors perform these inspections using a national 
Postlease Permitting and Approval Processes A-17

checklist called the Potential Incident of Noncompliance list. This list is a compilation of yes/no 

questions derived from all regulated safety and environmental requirements.

The BSEE administers an active civil penalties program (30 CFR part 250 subpart N). A civil 

penalty in the form of substantial monetary fines may be issued against any operator that commits a 

violation that may constitute a threat of serious, irreparable, or immediate harm or damage to life, 

property, or the environment. The BSEE may make recommendations for criminal penalties if a 

willful violation occurs. In addition, the regulation at 30 CFR § 250.173(a) authorizes suspension of 

any operation in the Gulf of Mexico region if the lessee has failed to comply with a provision of any 

applicable law, regulation, or order or provision of a lease or permit. Furthermore, the Secretary 

may invoke his authority under 30 CFR § 550.185(c) to cancel a nonproductive lease with no 

compensation. Exploration and development activities may be canceled under 30 CFR §§ 550.182 

and 550.183.

A.5 POLLUTION PREVENTION, OIL-SPILL RESPONSE PLANS, AND FINANCIAL 

RESPONSIBILITY

Pollution Prevention

Pollution prevention is addressed through proper design and requirements for safety 

devices. The BSEE regulations at 30 CFR § 250.401 require that the operator take all necessary 

precautions to keep its wells under control at all times. The lessee is required to use the best 

available and safest drilling technology in order to enhance the evaluation of conditions of abnormal 

pressure and to minimize the potential for the well to flow or kick. Redundancy is required for critical 

safety devices that will shut off flow from the well if loss of control is encountered.

In addition, BSEE’s regulations at 30 CFR part 250 subparts E, F, and H require that the 

lessee assure the safety and protection of the human, marine, and coastal environments during 

completion, workover, and production operations. All production facilities, including separators, 

treaters, compressors, headers, and flowlines are required to be designed, installed, tested, 

maintained, and used in a manner that provides for efficiency, safety of operations, and protection of 

the environment. Wells, particularly subsea wells, include a number of sensors that help in detecting 

pressures and the potential for leaks in the production system. Safety devices are monitored and 

tested frequently to ensure their operation, should an incident occur. To ensure that safety devices 

are operating properly, BSEE incorporates the API RP 14C into the operating regulations. The API 

RP 14C incorporates the knowledge and experience of the oil and gas industry regarding the 

analysis, design, installation, and testing of the safety devices used to prevent pollution. The API 

RP 14C presents proven practices for providing these safety devices for offshore production 

platforms. Proper application of these practices, along with good design, maintenance, and 

operation of the entire production facility, should provide an operationally safe and pollution-free 

production platform.

Also, BSEE’s regulations at 30 CFR part 250 subpart J require that pipelines and associated 

valves, flanges, and fittings be designed, installed, operated, and maintained to provide safe and 
A-18 Gulf of Mexico Multisale EIS

pollution-free transportation of fluids in a manner that does not unduly interfere with other uses on 

the OCS.

The BSEE regulation at 30 CFR § 250.300(a) requires that lessees not create conditions that 

will pose an unreasonable risk to public health, life, property, aquatic life, wildlife, recreation, 

navigation, commercial fishing, or other uses of the ocean during offshore oil and gas operations. 

The lessee is required to take measures to prevent the unauthorized discharge of pollutants into the 

offshore waters. Control and removal of pollution is the responsibility and at the expense of the 

lessee. Immediate corrective action in response to an unauthorized release is required. All 

hydrocarbon-handling equipment for testing and production, such as separator and treatment tanks, 

is required to be designed, installed, and operated to prevent pollution. Maintenance and repairs 

that are necessary to prevent pollution are required to be taken immediately. Drilling and production 

facilities are required to be inspected daily or at intervals approved or prescribed by BSEE’s District 

Field Operations Supervisor to determine if pollution is occurring.

Operators are required to install curbs, gutters, drip pans, and drains on platform and rig 

deck areas in a manner necessary to collect all greases, contaminants, and debris not authorized for 

discharge. The rules also explicitly prohibit the disposal of equipment, cables, chains, containers, or 

other materials into offshore waters. Portable equipment, spools or reels, drums, pallets, and other 

loose items must be marked in a durable manner with the owner’s name prior to use or transport 

over offshore waters. Smaller objects must be stored in a marked container when not in use. 

Operational discharges such as produced water and drilling muds and cuttings are regulated by the 

USEPA through the National Pollutant Discharge Elimination System permit program for new and 

existing discharges and sources (40 CFR part 435 subpart A). The BSEE may restrict the rate of 

drilling fluid discharge or prescribe alternative discharge methods. No petroleum-based substances, 

including diesel fuel, may be added to the drilling mud system without prior approval of BSEE’s

District Field Operations Supervisor.

Oil-Spill Response Plans

The BSEE regulations at 30 CFR part 254 require that all owners and operators of oilhandling, storage, or transportation facilities located seaward of the coastline submit an oil-spill 

response plan (OSRP) for approval. The term “coastline” means the line of ordinary low water along 

that portion of the coast that is in direct contact with the open sea and the line marking the seaward 

limit of inland waters. The term “facility” means any structure, group of structures, equipment, or 

device (other than a vessel), which is used for one or more of the following purposes: exploring for; 

drilling for; producing; storing; handling; transferring; processing; or transporting oil. A mobile 

offshore drilling unit is classified as a facility when engaged in drilling or downhole operations.

The regulation at 30 CFR § 254.2 requires that an OSRP must be submitted and approved 

before an operator can use a facility. The BSEE can grant an exception to this requirement during 

BSEE’s review of an operator’s submitted OSRP. In order to be granted this exception during this 

time period, an owner/operator must certify in writing to BSEE that it is capable of responding to a 
Postlease Permitting and Approval Processes A-19 

“worst-case” spill or the substantial threat of such a spill. To continue operations, the facility must be 

operated in compliance with the approved OSRP or BSEE-accepted “worst-case” spill certification. 

Owners or operators of offshore pipelines are required to submit an OSRP for any pipeline that 

carries oil, condensate, or gas with condensate; pipelines carrying essentially dry gas do not require 

an OSRP. Current OSRPs are required for abandoned facilities until they are physically removed or 

dismantled.

The OSRP describes how an operator intends to respond to an oil spill. The OSRP may be 

site-specific or regional (30 CFR § 254.3). The term “regional” means a spill response plan that 

covers multiple facilities or leases of an owner or operator, including affiliates, which are located in 

the same BSEE Gulf of Mexico region. The subregional plan concept is similar to the regional 

concept, which allows leases or facilities to be grouped together for the purposes of (1) calculating 

response times, (2) determining quantities of response equipment, (3) conducting oil-spill trajectory 

analyses, (4) determining worst-case discharge scenarios, and (5) identifying areas of special 

economic and environmental importance that may be impacted and the strategies for their 

protection. The number and location of the leases and facilities allowed to be covered by a 

subregional OSRP will be decided by BSEE on a case-by-case basis considering the proximity of 

the leases or facilities proposed to be covered. The NTL 2012-N06 includes guidance on the 

preparation and submittal of regional OSRPs.

The Emergency Response Action Plan within the OSRP serves as the core of BSEErequired OSRPs. In accordance with 30 CFR part 254, the Emergency Response Action Plan 

requires identification of (1) the qualified individual and the spill-response management team, (2) the 

spill-response operating team, (3) the oil-spill cleanup organizations under contract for response, 

and (4) the Federal, State, and local regulatory agencies that an owner/operator must notify or that 

they must consult with to obtain site-specific environmental information when an oil spill occurs. The 

OSRP is also required to include an inventory of appropriate equipment and materials, their 

availability, and the time needed for deployment, as well as information pertaining to dispersant use, 

in-situ burning, a worst-case discharge scenario, contractual agreements, training and drills, 

identification of potentially impacted environmental resources and areas of special economic 

concern and environmental importance, and strategies for the protection of these resources and 

areas. The response plan must provide for response to an oil spill from the facility, and the operator 

must immediately carry out the provisions of the plan whenever an oil spill from the facility occurs. 

The OSRP must be in compliance with the National Contingency Plan and the Area Contingency 

Plan(s). The operator is also required to carry out the training, equipment testing, and periodic drills 

described in the OSRP. All BSEE-approved OSRPs must be reviewed at least every 2 years. In 

addition, revisions must be submitted to BSEE within 15 days whenever

• a change occurs that appreciably reduces an owner/operator’s response 

capabilities;

• a substantial change occurs in the worst-case discharge scenario or in the type 

of oil being handled, stored, or transported at the facility;
A-20 Gulf of Mexico Multisale EIS

• there is a change in the name(s) or capabilities of the oil-spill removal 

organizations cited in the OSRP; or

• there is a change in the applicable Area Contingency Plans.

As a result of the Deepwater Horizon explosion and oil spill, although BSEE is not requiring 

the submission of revised OSRPs at this time, BSEE will provide guidance regarding additional 

information that operators should submit regarding spill response and surface containment in light of 

the “worst-case” discharge calculations that are now required by the regulations and as clarified in 

NTL 2010-N06, “Information Requirements for Exploration Plans, Development and Production 

Plans, and Development Operations Coordination Documents on the OCS,” which became effective 

on June 18, 2010. This NTL provides clarification of the regulations requiring a lessee or operator to 

submit supplemental information for new or previously submitted EPs, DPPs, or DOCDs. The 

required supplemental information includes the following: (1) a description of the blowout scenario 

as required by 30 CFR §§ 550.213(g) and 550.243(h); (2) a description of their assumptions and 

calculations used in determining the volume of the worst-case discharge required by 30 CFR § 

550.219(a)(2)(iv) (for EPs) or 30 CFR § 550.250(a)(2)(iv) (for DPPs and DOCDs); and (3) a 

description of the measures proposed that would enhance the ability to prevent a blowout, to reduce 

the likelihood of a blowout, and to conduct effective and early intervention in the event of a blowout, 

including the arrangements for drilling relief wells and any other measures proposed. The early 

intervention methods could actually include the surface and subsea containment resources that 

BSEE announced in NTL 2010-BSEE-N10, “Statement of Compliance with Applicable Regulations 

and Evaluation of Information Demonstrating Adequate Spill Response and Well Containment 

Resources,” which states that BSEE will begin reviewing to ensure that the measures are adequate 

to promptly respond to a blowout or other loss of well control.

Additionally, to address new improved containment systems, NTL 2010-N10 became 

effective on November 8, 2010. This NTL applies only to operators conducting operations using 

subsea or surface BOPs on floating facilities. It clarifies the regulations that lessees and operators 

must submit a certification statement signed by an authorized company official with each application 

for a well permit, indicating that they will conduct all of their authorized activities in compliance with 

all applicable regulations, including the Increased Safety Measures Regulations (Federal Register, 

2010). The NTL also informs lessees that BSEE will be evaluating whether or not each operator has 

submitted adequate information demonstrating that it has access to and can deploy surface and 

subsea containment resources that would be adequate to promptly respond to a blowout or other 

loss of well control. Although the NTL does not provide that operators submit revised OSRPs that 

include this containment information at this time, operators were notified of BSEE’s intention to 

evaluate the adequacy of each operator to comply in the operator’s current OSRP; therefore, there is 

an incentive for voluntary compliance.

The following requirements are implemented according to BSEE’s regulations at 30 CFR 

parts 250 and 254:
Postlease Permitting and Approval Processes A-21

• requires immediate notification for spills >1 bbl—all spills require notification to 

USCG, and BSEE receives notification from USCG of all spills ≥1 bbl;

• conducts investigations to determine the cause of a spill;

• assesses civil and criminal penalties, if needed;

• oversees spill source control and abatement operations by industry;

• sets requirements and reviews and approves OSRPs for offshore facilities;

• conducts unannounced drills to ensure compliance with OSRPs;

• requires operators to ensure that their spill-response operating and management 

teams receive appropriate spill-response training;

• conducts inspections of oil-spill response equipment;

• requires industry to show financial responsibility to respond to possible spills; and

• provides research leadership to improve the capabilities for detecting and 

responding to an oil spill in the marine environment.

BOEM receives and reviews the worst-case discharge and blowout scenarios information 

submitted for EPs, DPPS, and DOCDs on the OCS. BOEM also has regulatory requirements 

addressing site-specific OSRPs and spill response information. As required by BOEM at 30 CFR §§ 

550.219 and 550.250, operators are required to provide BOEM with an OSRP that is prepared in 

accordance with 30 CFR part 254 subpart B with their proposed exploration, development, or 

production plan for the facilities that they will use to conduct their activities; or to alternatively 

reference their approved regional OSRP by providing the following information:

• a discussion of the approved OSRP;

• the location of the primary oil-spill equipment base and staging area;

• the name of the oil-spill equipment removal organization(s) for both equipment 

and personnel;

• the calculated volume of the worst-case discharge scenario in accordance with 

30 CFR § 254.26(a) and a comparison of the worst-case discharge scenario in 

the approved regional OSRP with the worst-case discharge calculated for these 

proposed activities; and

• a description of the worst-case discharge to include the trajectory information, 

potentially impacted resources, and a detailed discussion of the spill response 

proposed to the worst-case discharge in accordance with 30 CFR §§ 254(b)-(d).

All OSRPs are reviewed and approved by BSEE, whether submitted with a BOEMassociated plan or directly to BSEE in accordance with 30 CFR part 254. Hence, BOEM relies 
A-22 Gulf of Mexico Multisale EIS

heavily upon BSEE’s expertise to ensure that the OSRP complies with all pertinent laws and 

regulations, and demonstrates the ability of an operator to respond to a worst-case discharge. The 

operator is also required to carry out the training, equipment testing, and periodic drills described in 

the OSRP. Since 1989, BSEE has conducted government initiated unannounced exercises that

provide an economically feasible mechanism for agencies to comply with the requirements defined 

in 30 CFR part 254. In 2014, BSEE carried out seven table-top, government-initiated unannounced 

exercises and two deployment government-initiated unannounced exercises (USDOI, BSEE, 2014). 

Equipment deployment exercises most often take place in waterways adjacent to where the 

equipment is stored, but they may be moved if the exercise requires it. Typical deployment 

exercises last only a few hours and rarely longer than a day (USDOI, BSEE, official communication, 

2015). Site-specific OSRPs are required to be submitted to BOEM with a proposed exploration, 

development, or production plan, and BOEM’s regulations require that an operator must have an 

approved OSRP prior to BOEM’s approval of an operator-submitted exploration, development, or 

production plan.

Several NTLs and guidance documents have been issued by BOEM and BSEE that clarify 

additional oil-spill requirements since the occurrence of the Deepwater Horizon explosion, oil spill, 

and response. The following is a summary of that information.

Worst-Case Discharge and Blowout Scenario Information

NTL 2015-BOEM-N01

BOEM issued NTL 2015-BOEM-N01, “Information Requirements for Exploration Plans, 

Development and Production Plans, and Development Operations Coordination Documents on the 

OCS for Worst Case Discharge and Blowout Scenarios”. This NTL became effective on January 4, 

2015, and explains the procedures for the lessee or operator to submit worst-case discharge and 

blowout scenario information for new or previously submitted EPs, DPPs, or DOCDs. This NTL 

supersedes NTL 2010-N06, “Information Requirements for Exploration Plans, Development and 

Production Plans, and Development Operations Coordination Documents on the OCS.” The 

required information to be submitted for new EPs, DPPs, and DOCDs or as a supplement to a 

previously submitted plan includes the following: (1) a blowout scenario as required by 30 CFR §§

550.213(g) and 550.243(h); (2) a description of their assumptions and calculations used in 

determining the volume of the worst-case discharge required by 30 CFR § 550.219(a)(2)(iv) (for 

EPs) or 30 CFR § 550.250(a)(2)(iv) (for DPPs and DOCDs); and (3) a description of the measures 

proposed that would enhance the ability to prevent a blowout, to reduce the likelihood of a blowout, 

and to conduct effective and early intervention in the event of a blowout, including the arrangements 

for drilling relief wells and any other measures proposed.

BOEM also issued NTL 2015-BOEM-N01, “Frequently Asked Questions Information Sheet 

for Information Requirements for Exploration Plans, Development and Production Plans, and 

Development Operations Coordination Documents on the OCS for Worst Case Discharge and 

Blowout Scenarios”. This Frequently Asked Questions information sheet provides guidance 

intended to assist an operator’s compliance with the worst-case discharge and blowout scenario 
Postlease Permitting and Approval Processes A-23

information requirements pursuant to NTL 2015-BOEM-N01 and also provides information regarding 

BOEM’s review of the submitted information.

NTL 2013-BSEE-N02

The BSEE issued NTL 2013-BSEE-N02, “Significant Change to Oil Spill Response Plan 

Worst Case Discharge Scenario.” This NTL clarifies what BSEE considers a significant change in a 

worst-case discharge scenario, which requires that a revision to an OSRP be submitted. The 

guidance issued by this NTL states that a significant change in worst-case discharge may occur 

when calculating a new worst-case discharge based upon the following:

• the addition of a new facility installation or well;

• a modification to an existing facility; or

• a change in any assumptions and calculations used to determine the prior 

estimated worst-case discharge.

The NTL 2013-BSEE-N02 identifies the process an owner or operator of a facility should 

utilize to determine whether the newly calculated worst-case discharge represents a significant 

change. The BSEE considers a change in worst-case discharge as significant and thus requiring 

revision when the process identifies the need for additional onshore or offshore response equipment 

beyond what is included in an approved OSRP. Although information to make this determination is 

submitted to BOEM and forwarded to BSEE with a proposed exploration, development, or 

production plan, pursuant to NTL 2013-BSEE-N02, the 15-day timeframe for notification of a 

significant change will be enforced by BSEE as beginning no later than the date that the operator 

submitted an Application for Permit to Drill to BSEE.

Typically, for OSRP revisions, once BSEE approves an OSRP, it must be reviewed at least 

every 2 years, and modifications must be submitted in accordance with 30 CFR § 254.30(a). If no 

modifications are deemed necessary, the owner or operator must inform BSEE in writing that there 

are no changes. A separate revision to an OSRP must be submitted to BSEE within 15 days when 

the following conditions are met:

• there is a change that significantly reduces operator response capabilities;

• a significant change occurs in the worst-case discharge or in the type of oil being 

handled, stored, or transported at a facility;

• there is a change in the names or capabilities of the oil-spill removal 

organizations cited in the plan; or

• there is a significant change to the Area Contingency Plan.
A-24 Gulf of Mexico Multisale EIS

NTL 2012-BSEE-N06

The BSEE also issued NTL 2012-BSEE-N06, “Guidance to Owners and Offshore Facilities 

Seaward of the Coast Line Concerning Regional Oil Spill Response Plans.” This NTL, which was 

effective on August 10, 2012, provides clarification, guidance, and information concerning the 

preparation and submittal of a regional OSRP for owners and operators of oil handling, storage, or 

transportation facilities, including pipelines located seaward of the coastline. A regional OSRP is 

defined as a spill response plan covering multiple facilities or leases of an owner, or operator, or 

their affiliates, which are located in the same BSEE region. Site-specific OSRPs submitted with 

BOEM exploration, development, or production plans can either be prepared using the 30 CFR part 

254 regulations or the guidance outlined in NTL 2012-BSEE-N06.

Some of the clarifications and encouraged practices identified in NTL 2012-BSEE-N06 are 

based upon lessons learned from the Deepwater Horizon oil-spill response. This NTL indicates that 

BSEE’s review of OSRPs would also be based, in part, upon information obtained during the 

Deepwater Horizon oil-spill response. For example, during the Deepwater Horizon oil-spill response, 

it was discovered that the total estimated de-rated recovery capacity for all equipment listed in the 

OSRP overestimated the amount of oil that could be removed from the water. The NTL 2012-BSEEN06 therefore states that the OSRP should be developed considering (1) a fully developed response 

strategy that includes the identification of the available dedicated recovery equipment as well as the 

actual operating characteristics of the systems associated with each skimmer and (2) the use of new 

technology and response systems that will increase the effectiveness of mechanical recovery tactics.

The NTL 2012-BSEE-N06 is designed to encourage owners and operators of offshore 

facilities to include innovative offshore oil-spill response techniques, particularly for a continuous 

high-rate spill. This NTL includes requirements for the submittal of information regarding subsea 

containment equipment and subsea dispersant application among other provisions. This NTL also 

encourages the inclusion of options that would improve spill-response capabilities such as:

• using remote-sensing techniques as a tool for safe night operations to increase 

oil-spill detection and to improve thickness determinations for ascertaining the 

effectiveness of response strategies;

• increasing spill-response operational time by reducing transit times to disposal 

locations and decontamination equipment;

• identifying sources for supplies and materials, such as fire boom and 

dispersants, that can support a response to an uncontrolled spill lasting longer 

than 30 days or for the duration of the spill response; and

• the use and specification of primary and secondary communications technology 

and software for coordinating and directing spill-response operations systems 

and/or providing a common operating picture to all spill management and 

response personnel, including the Federal On-Scene Coordinator and 

participating Federal and State government officials.
Postlease Permitting and Approval Processes A-25

NTL 2012-BSEE-N07

The BSEE issued NTL 2012-BSEE-N07, “Oil Discharge Written Follow-up Reports.” This 

NTL addresses the oil discharge reports (30 CFR § 254.46(b)(2)) that are required to be submitted

by a responsible party to BSEE for spills >1 bbl within 15 days after a spill has been stopped or 

ceased. The responsible party is encouraged to report cause, location, volume, remedial action 

taken, sea state, meteorological conditions, and the size and appearance of the slick.

NTL 2010-N10

The Bureau of Ocean Energy Management, Regulation and Enforcement issued NTL 

2010-N10, “Statement of Compliance with Applicable Regulations and Evaluation of Information 

Demonstrating Adequate Spill Response and Well Containment Resources,” which became effective 

on November 8, 2010. This NTL applies only to operators conducting operations using subsea or 

surface BOPs on floating facilities. It explains that lessees and operators submit a statement signed 

by an authorized company official with each application for a well permit indicating that they will 

conduct all of their authorized activities in compliance with all applicable regulations, including the 

Increased Safety Measures Regulations (Federal Register, 2010). The NTL also informs lessees 

that BOEM will be evaluating whether or not each operator has submitted adequate information 

demonstrating that it has access to and can deploy surface and subsea containment resources that 

would be adequate to promptly respond to a blowout or other loss of well control. The NTL notifies 

the operator that BOEM intends to evaluate the adequacy of each operator to comply in the 

operator’s current OSRP; therefore, there is an incentive for voluntary compliance. The NTL lists the 

type of information that BOEM would review as follows:

• subsea containment and capture equipment, including containment domes and 

capping stacks;

• subsea utility equipment, including hydraulic power, hydrate control, and 

dispersant injection equipment;

• riser systems;

• remotely operated vehicles;

• capture vessels;

• support vessels; and

• storage facilities.

Spill Response Initiatives

For more than 25 years, BSEE and its predecessors have maintained a comprehensive longterm research program to improve oil-spill response knowledge and technologies. The major focus 

of the program is to improve the methods and technologies used for oil-spill detection, containment, 

treatment, recovery, and cleanup. The BSEE Oil Spill Response Research program is a cooperative 
A-26 Gulf of Mexico Multisale EIS

effort bringing together funding and expertise from research partners in State and Federal 

government agencies, industry, academia, and the international community. The projects funded 

cover numerous spill response-related issues such as chemical treating agents; in-situ burning of oil; 

research conducted at BSEE’s Oil Spill Response Test Facility (Ohmsett) located in Leonardo, New 

Jersey; behavior of oil; decisionmaking support tools; mechanical containment; and remote sensing.

A few of BSEE’s research contracts that highlight the varied types of research funded include

the following: 

• “Leveraging Offshore Hydrocarbon Risk Assessment Models and Datasets to 

Support the Evaluation and Ranking of Worst Case Discharge Scenarios” 

(Project Number 1046) – The objective of this project is to develop a set of 

methodologies and algorithms, and a computer model for the comparison and 

ranking of different spill scenarios to determine which one has the greater 

potential for damage to the environment or result in other significant impacts and 

should be classified as the worst-case discharge.

• “Scientifically Based Field Tools for Predicting Dispersant Effectiveness and 

Usage Rates” (Project Number 1043) – This project will bridge the gap between 

laboratory methodology and field analysis by incorporating the modified 1-liter 

Baffled Flask Test and fluorescence probe for determining dispersant 

effectiveness in the field.

• “Technology Readiness Level (TRL) Definitions for Oil Spill Response 

Technologies and Equipment” (Project Number 1042) – The objective of this 

study is to establish a uniform and objective means to determine the level of 

maturity of a new technology and when it is ready for use in the field.

• “HC-Sentinel: An AUV Glider for High Endurance Subsea Hydrocarbon 

Detection” (Project Number 1041) – The objective of this study is to develop and 

test a next generation in-situ mass spectrometer payload that operates on an 

autonomous underwater vehicle glider for real-time subsea hydrocarbon 

detection and classification and that can be designed to operate for long-term 

subsea inspection, monitoring, and incident response.

More information on these and the other awarded and completed research projects can be 

found on BSEE’s website at http://www.bsee.gov/Technology-and-Research/Research/. 

Incident Reporting

The Minerals Management Service (MMS) (BOEM’s predecessor) revised operator incident 

reporting requirements in a final rule effective July 17, 2006 (Federal Register, 2006). The incident 

reporting rule defines what incidents must be reported, includes incidents that have the potential to 

be serious, and requires the reporting of standard information for both oral and written reports. As 

part of the incident reporting rule, BOEM’s regulations at 30 CFR § 250.188(a)(6) require an 
Postlease Permitting and Approval Processes A-27

operator to report all collisions that result in property or equipment damage greater than $25,000. 

“Collision” is defined as the act of a moving vessel (including an aircraft) striking another vessel or 

striking a stationary vessel or object (e.g., a boat striking a drilling rig or platform).

Financial Responsibility

The responsible party for covered offshore facilities must demonstrate oil-spill financial 

responsibility, as required by 30 CFR part 553. These regulations implement the oil-spill financial 

responsibility requirements of Title I of the Oil Pollution Act of 1990, as amended. Penalties for 

noncompliance with these requirements are covered at 30 CFR § 553.51 and in NTL 2008-N05, 

“Guidelines for Oil Spill Financial Responsibility for Covered Facilities.” A covered offshore facility, 

as defined in 30 CFR § 553.3, is any structure and all of its components (including wells completed 

at the structure and the associated pipelines), equipment, pipeline, or device (other than a vessel or 

other than a pipeline or deepwater port licensed under the Deepwater Port Act of 1974) used for 

exploring, drilling, or producing oil, or for transporting oil from such facilities. The BSEE ensures that 

each responsible party has sufficient funds for removal costs and damages resulting from the 

accidental release of liquid hydrocarbons into the environment for which the responsible party is 

liable.

A.6 AIR EMISSIONS

The OCSLA (43 U.S.C. § 1334(a)(8)) requires the Secretary of the Interior to promulgate and 

administer regulations that comply with the National Ambient Air Quality Standards, pursuant to the 

Clean Air Act (42 U.S.C. §§ 7401 et seq.), to the extent that authorized activities significantly affect 

the air quality of any State. Under provisions of the Clean Air Act Amendments of 1990, the USEPA 

Administrator has jurisdiction and, in consultation with the Secretary of the Interior and the 

Commandant of the Coast Guard, established the requirements to control air pollution in OCS areas 

of the Pacific, Atlantic, Arctic, and eastward of 87.5° W. longitude in the Gulf of Mexico. Air quality in 

the OCS area westward of 87.5° W. longitude in the Gulf of Mexico is under BOEM’s jurisdiction.

For OCS air emission sources located east of 87.5° W. longitude and within 25 mi (40 km) of 

the States’ seaward boundaries, the requirements are the same as would be applicable if the source 

were located in the corresponding onshore area. The USEPA requirements for these OCS areas 

are at 40 CFR part 55, Appendix A. For air emission sources located east of 87.5° W. longitude and 

more than 25 mi (40 km) from the States’ seaward boundaries, sources are subject to Federal 

requirements as specified in 40 CFR § 52.13. The USEPA regulations also establish procedures 

that allow the USEPA Administrator to exempt any OCS source from an emissions control 

requirement if it is technically infeasible or poses unreasonable threat to health or safety.

This Agency issued NTL 2009-N11 to clarify that its regulatory authority and BOEM’s

implementing regulations in 30 CFR part 250 subpart C and 30 CFR part 550 apply only to those air 

emission sources in the Gulf of Mexico westward of 87.5° W. longitude. The regulated pollutants 

include carbon monoxide, total suspended particulate matter, sulphur dioxide, nitrogen oxides, and 

volatile organic compounds. All new or supplemental EPs and DOCDs must include air emissions 
A-28 Gulf of Mexico Multisale EIS

information sufficient to determine whether an air quality review is required (30 CFR §§ 550.218 and 

550.249). BOEM’s regulations require a review of air quality emissions to determine if the projected 

emissions from a facility result in onshore ambient air concentrations above BOEM’s significance 

levels and to identify appropriate emissions controls to mitigate potential onshore air quality 

degradation.

Emissions data for new or modified onshore facilities directly associated with proposed OCS 

oil- and gas-related activities are required to be included in development plans submitted to BOEM 

so that affected States can determine potential air quality impacts on their air quality.

BOEM uses a two-level hierarchy of evaluation criteria to evaluate potential impacts of 

offshore emission sources to onshore areas. The evaluation criteria are the exemption level and the 

significance level. If the proposed activities exceed the criteria at the first (exemption) level, the 

evaluation moves to the significance level criteria. The initial evaluation compares the worst-case 

emissions with BOEM’s exemption criteria. This corresponds to the USEPA’s screening step, where 

the proposed activity emissions are checked against the screening thresholds or “exemption levels.” 

If the proposed activity’s emissions are below the exemption levels, the proposed activity is exempt 

from further air quality review.

If exemption levels are exceeded, then the second step requires refined modeling using the 

Offshore and Coastal Dispersion (OCD) Model or the California Puff Model (CALPUFF). The results 

from these models, the modeled potential onshore impacts, are compared with BOEM’s significance 

levels. If the significance levels are exceeded in an attainment area, which is an area that meets the 

National Ambient Air Quality Standards, the operator would be required to apply best available 

control technology to the emissions source. If the affected area is classified as nonattainment, 

further emission reductions or offsets may be required. Projected contributions to onshore pollutant 

concentrations are also subject to the same increments that the USEPA applies to the onshore 

areas under their Prevention of Significant Deterioration program.

A.7 FLARING/VENTING

Flaring is the controlled burning of natural gas, and venting is releasing gas directly into the 

atmosphere without burning (refer to Chapter 3.1.8.4). The BSEE regulates flaring/venting to 

minimize the loss of revenue producing natural gas resources. The BSEE regulations at 30 CFR 

part 250 allow, without prior BSEE approval, flaring or venting of natural gas on a limited basis under 

certain specified conditions. Regulations permit more extensive flaring/venting with prior approval 

from BSEE. Records must always be prepared by the operator for all flaring/venting, and 

justification must be provided for flaring/venting not expressly authorized by BSEE’s regulations.

A.8 HYDROGEN SULFIDE CONTINGENCY PLANS

The operator of a lease must request a BSEE area classification for the presence of 

hydrogen sulfide (H2S) gas. The BSEE classifies areas for proposed operations as (1) H2S absent, 

(2) H2S present, or (3) H2S unknown.
Postlease Permitting and Approval Processes A-29

All OCS operators must provide information about potential contact with sour hydrocarbons 

(contains H2S) that could result in atmospheric H2S concentrations above 20 parts per million in their 

exploration or development plan. If an area is known to contain H2S or is in an area where H2S 

potential is unknown, operators are required to file an H2S contingency plan with BSEE. This plan 

must include the 30 CFR part 250 requirements that are intended to ensure workers’ safety at the 

production facility and provide contingencies for simultaneous drilling, well-completion, wellworkovers, and production operations. The NTL 2009-G31, “Hydrogen Sulfide (H2S) Requirements,” 

provides clarification, guidance, and information regarding BSEE’s H2S regulations at 30 CFR 

part 250.

A.9 ARCHAEOLOGICAL RESOURCES REGULATION

Bottom-disturbing operations such as well placement, anchoring, and pipelaying activities 

can lead to damage to any resources that reside on or embedded within the seabed, including 

archaeological resources such as historic shipwrecks. The archaeological resources regulations at 

30 CFR § 250.194 and 30 CFR § 550.194 grant authority to BOEM’s and BSEE’s Regional Directors 

to require that an archaeological survey report be submitted with the EP, DOCD, or DPP where 

deemed necessary. The technical requirements of the high-resolution geophysical survey, 

archaeological analysis, and report are detailed in NTL 2005-G07, “Archaeological Resource 

Surveys and Reports.” If data from the operator’s high-resolution geophysical survey and 

archaeological report suggest that an archaeological resource may be present, the lessee must 

either locate the site of any operation so as not to adversely affect the area of the seafloor identified 

for archaeological avoidance, demonstrate that the identified geophysical target is not an 

archaeological resource through remotely operated vehicle or diver investigation, or demonstrate 

that potential archaeological resources will not be adversely affected by operations. If the lessee 

discovers any archaeological resource while conducting approved operations, operations must be 

immediately stopped and the discovery reported to BOEM’s Regional Supervisor, Office of 

Environment, within 48 hours of its discovery.

High-resolution surveys, where required, provide an effective tool that analysts use to identify 

and help protect archaeological resources. As part of the environmental reviews conducted for 

postlease activities, all available information will be evaluated regarding the potential presence of 

archaeological resources within a proposed action area to determine if mitigation is warranted. 

A.10 COASTAL ZONE MANAGEMENT CONSISTENCY REVIEW AND APPEALS FOR 

POSTLEASE ACTIVITIES

The Coastal Zone Management Act (CZMA) places requirements on any applicant for any 

federally licensed or permitted activities on the OCS (i.e., OCS plans, right-of-way pipelines, 

geological and geophysical surveys, and decommissioning) affecting any coastal use or resource, in 

or outside of a State’s coastal zone. The applicant must provide a consistency certification and 

necessary data and information for the State to determine that the proposed activities comply with 

the enforceable policies of the State’s CMP, approved by NOAA, and that such activities will be fully 

consistent with those enforceable policies (16 U.S.C. § 1456(c)(3)(A) and 15 CFR § 930.76).
A-30 Gulf of Mexico Multisale EIS

Except as provided in 15 CFR § 930.60(a), State agency consistency review begins when 

the State receives the OCS plan or application, consistency certification, and necessary data and 

information pursuant to 15 CFR §§ 930.76(a) and (b). Only missing information can be used to 

delay the commencement of State agency review, and a request for information and data that are 

not required by 15 CFR § 930.76 will not extend the date of commencement of review (15 CFR § 

930.58). The information requirements for CZM purposes are found at 30 CFR §§ 550.226 and 

550.260 and are discussed in NTL 2012-BSEE-N06, “Guidance to Owners and Operators of 

Offshore Facilities Seaward of the Coast Line Concerning Regional Oil Spill Response Plans” ; NTL 

2008-G04, “Information Requirements for Exploration Plans and Development Operations 

Coordination Documents”; NTL 2009-G27, “Submitting Exploration Plans and Development 

Operations Coordination Documents”; NTL 2015-BOEM-N01, “Information Requirements for 

Exploration Plans, Development and Production Plans, and Development Operations Coordination 

Documents on the OCS for Worst Case Discharge and Blowout Scenarios”; NTL 2010-N10, 

“Statement of Compliance with Applicable Regulations and Evaluation of Information Demonstrating 

Adequate Spill Response and Well Containment Resources”; and NTL 2007-G20, “Coastal Zone 

Management Program Requirements for OCS Right-of-Way Pipeline Applications.”

All of the Gulf Coast States have federally approved CMP’s. Requirements for the CZM 

consistency information for Texas, Louisiana, Mississippi, Alabama, and Florida are given in NTL’s 

2012-BSEE-N06, 2008-G04, 2009-G27, 2015-BOEM-N01, 2010-N10, and 2007-G20. In 

accordance with the requirements of 15 CFR § 930.76, BOEM’s Gulf of Mexico OCS Region sends 

copies of an OCS plan, including the consistency certification and other necessary data and 

information, to the designated State CMP agency by receipted mail or other approved 

communication. In accordance with the requirements of 15 CFR § 930.60, the applicants are 

responsible for sending the State CMP agency a copy of the applicant, consistency certification, and 

necessary data and information at the same time as when the applicant sends it to BOEM or BSEE. 

If no State-agency objection is submitted by the end of the consistency review period, BOEM shall 

presume consistency concurrence by the CZMA State (15 CFR § 930.78(b)). BOEM can require 

modification of a plan or application.

If BOEM receives a written consistency objection from the State, BOEM and/or BSEE will not 

approve any activity described in the proposed activity unless (1) the operator amends the 

application to accommodate the objection, concurrence is subsequently received or conclusively 

presumed; (2) upon appeal, the Secretary of Commerce, in accordance with 15 CFR part 930 

subpart H, finds that the proposed activity is consistent with the objectives or purposes of the CZMA 

or is necessary in the interest of national security; or (3) the original objection is declared invalid by 

the courts.

A.11 BEST AVAILABLE AND SAFEST TECHNOLOGIES

To assure that oil and gas exploration, development, and production activities on the OCS 

are conducted in a safe and environmentally sound manner, 43 U.S.C. § 1347(b) of the OCSLA, as 

amended, requires that all OCS technologies and operations use the best available and safest 
Postlease Permitting and Approval Processes A-31

technology (BAST) whenever practical. The BSEE Director may require additional BAST measures 

to protect safety, health, and the environment, if it is economically feasible and the benefits outweigh 

the costs. Conformance to the standards, codes, and practices referenced in or required under the 

authority of 30 CFR part 250 is considered the application of BAST. These standards, codes, and 

practices include requirements for state-of-the-art drilling technology, production safety systems, oil 

and gas well completions, oil-spill response plans, pollution-control equipment, and specifications for 

platform/structure designs. The BSEE conducts periodic offshore inspections and continuously and 

systematically reviews OCS technologies to ensure that the best available and safest technologies 

are applied to OCS operations. The BAST is not required when BSEE determines that the 

incremental benefits are clearly insufficient to justify increased costs; however, it is the responsibility 

of an operator of an existing operation to demonstrate why application of a new technology would 

not be feasible. The BAST requirement is applicable to equipment and procedures that, upon 

failure, would have a significant effect on safety, health, or the environment, unless benefits clearly 

do not justify the cost (30 CFR §§ 250.107(c) and (d)).

The BAST concept is addressed in BSEE’s Gulf of Mexico OCS Region by a continuous 

effort to locate and evaluate the latest technologies and to report on these advances at periodic 

Regional Operations Technology Assessment Committee meetings. A part of BSEE’s staff has an 

ongoing function to evaluate various vendors and industry representatives’ innovations and 

improvements in techniques, tools, equipment, procedures, and technologies applicable to oil and 

gas operations (i.e., drilling, producing, completion, and workover operations). This information is 

provided to BSEE’s District personnel at Regional Operations Technology Assessment Committee

meetings. The requirement for the use of BAST has been, for the most part, an evolutionary 

process whereby advances in equipment, technologies, and procedures have been integrated into 

OCS operations over a period of time. Awareness by both BSEE inspectors and the OCS operators 

of the most advanced equipment and technologies has resulted in the incorporation of these 

advances into day-to-day operations. An example of such an equipment change that evolved over a 

period of time would be the upgrading of diverter systems on drilling rigs from the smaller diameter 

systems of the past to the large-diameter, high-capacity systems found on drilling rigs operating on 

the OCS today.

Production Facilities

The BSEE regulations governing oil and gas production safety systems can be found in 

30 CFR 250 Subpart H. Production safety equipment used on the OCS must be designed, installed, 

used, maintained, and tested in a manner to assure the safety and protection of the human, marine, 

and coastal environments. All tubing installations open to hydrocarbon-bearing zones below the 

surface must be equipped with safety devices that will shut off the flow from the well in the event of 

an emergency, unless the well is incapable of flowing. Surface- and subsurface-controlled safety 

valves and locks must conform to the requirements of 30 CFR § 250.801. All surface production 

facilities, including separator and treatment tanks, compressors, headers, and flowlines must be 

designed, installed, and maintained in a manner that provides for efficiency, safety of operations, 

and protection of the environment. Production facilities also have stringent requirements concerning 
A-32 Gulf of Mexico Multisale EIS

electrical systems, flowlines, engines, and firefighting systems. The safety-system devices are 

tested by the lessee at specified intervals and must be in accordance with API RP 14 C Appendix D 

and other measures.

A.12 PERSONNEL TRAINING AND EDUCATION

An important factor in ensuring that offshore oil and gas operations are carried out in a 

manner that emphasizes operational safety and minimizes the risk of environmental damage is the 

proper training of personnel. Under 30 CFR part 250 subpart O, BSEE has outlined well control and 

production safety training program requirements for lessees operating on the OCS. The goal of the 

regulation (30 CFR § 250.1501) is safe and responsible OCS operations. Lessees must ensure that 

their employees and contract personnel engaged in well control or production safety operations 

understand and can properly perform their duties. To accomplish this, the lessee must establish and 

implement a training program so that all of its employees are trained to competently perform their 

assigned well control and production safety duties. The lessee must also verify that its employees 

understand and can perform the assigned duties.

The mandatory Drilling Well-Control Training Program was instituted by this Agency in 1979. 

In 1983, the mandatory Safety Device Training Program was established to ensure that personnel 

involved in installing, inspecting, testing, and maintaining safety devices are qualified. As a 

preventive measure, all offshore personnel must be trained to operate oil-spill cleanup equipment, or 

the lessee must retain a trained contractor(s) to operate the equipment for them. In addition, BSEE 

offers numerous technical seminars to ensure that personnel are capable of performing their duties 

and are incorporating the most up-to-date safety procedures and technology in the petroleum 

industry.

On February 5, 1997, MMS (BOEM’s predecessor) published a final rule in the Federal 

Register (1997) concerning the training of the lessee and contractor employees engaged in drilling, 

well completion, well workover, well serving, or production safety system operations in the OCS. 

The final rule streamlined the previous regulations by 80 percent, provided the flexibility to use 

alternative training methods, and simplified the training options at 30 CFR part 250 subpart O. 

Although the rule did away with many of the onerous requirements in subpart O and served as 

intermediate change to the system, it did not sufficiently address development of a performancebased training system.

On August 14, 2000, MMS (BOEM’s predecessor) published in the Federal Register (2000) 

final regulations revising 30 CFR part 250, subpart O, “Well Control and Production Safety Training.” 

The MMS distributed the published final rulemaking to lessees, operators, and training schools. 

These new performance-based regulations took effect on October 13, 2000. To allow sufficient time 

for lessees to implement their training programs, the rule provided a 2-year transition period from 

October 13, 2000, until October 15, 2002. After October 15, 2002, all lessees were required to be in 

compliance with this rule.
Postlease Permitting and Approval Processes A-33

Goal of Performance Training Rule: Safe and responsible OCS operations. Lessees must 

ensure their employees, including contractors, are trained to competently perform their assigned well 

control and production safety duties. This rule should allow companies to focus their resources on 

important areas in their program rather than on sending all of their personnel to the same school 

program on a routine basis.

Key Elements of Performance Based Training: Under this rule, schools will be free to 

operate but they will not receive agency approval and they will no longer be able to issue subpart O 

certifications. By shifting the responsibility of developing training programs to industry, lessees will 

have to decide upon the type of training for their employees. The BSEE will hold the lessees 

responsible for the success or failure of these and other training related decisions.

Lessees Training Plan: The lessees’ training plan is the core item of BSEE’s performancebased program. The plan, which does not have to be approved by BSEE, lays out the company’s 

training philosophy. It must specify the type, method(s), length, frequency, and content of their 

program. Training requirements under this rule are limited to only well control and production 

operations.

Performance Indicators: The BSEE will periodically assess lessee and contractor training 

programs to see how well their employees are trained. To assess programs, BSEE may use one or 

more of the following evaluation methods: (1) audits; (2) written tests; (3) hands-on tests; and 

(4) employee interviews.

A.13 STRUCTURE REMOVAL AND SITE CLEARANCE

During exploration, development, and production operations, temporary and permanent 

equipment and structures are often required to be embedded into or placed onto the seafloor around 

activity areas. In compliance with Section 22 of BOEM’s Oil and Gas Lease Form (BOEM-2005) and 

OCSLA regulations (30 CFR § 250.1710—Wellheads/Casings and 30 CFR § 250.1725—Platforms 

and Other Facilities), operators need to remove seafloor obstructions from their leases within 1 year 

of lease termination or after a structure has been deemed obsolete or unusable. These regulations 

also require the operator to sever bottom-founded objects and their related components at least 5 m 

(15 ft) below the mudline (30 CFR § 250.1716(a)—Wellheads/Casings and 30 CFR § 250.1728(a)—

Platforms and Other Facilities). The severance operations are generally categorized as explosive or 

nonexplosive.

There are, however, possible exemptions to the 1-year deadline, including the exemptions 

stated in Section 388 of the Environmental Policy Act. Section 388 clarifies the Secretary’s authority 

to allow an offshore oil and gas structure, previously permitted under the OCSLA, to remain in place 

after OCS oil- and gas-related activities have ceased in order to allow the use of the structure for 

other energy- and marine-related activities. This authority provides opportunities to extend the life of 

facilities for non-OCS oil- and gas-related purposes, such as research, renewable energy 

production, aquaculture, etc., before being removed.
A-34 Gulf of Mexico Multisale EIS

This Agency previously addressed removal operations and the potential impacts of severing 

methodologies (nonexplosive/explosive tools) in a Programmatic EA prepared in 1987 (USDOI, 

MMS, 1987). The scope of the decommissioning activities analyzed in the Programmatic EA was 

limited to traditional, bottom-founded structures (i.e., well protectors, caissons, and jacketed 

platforms) and did not address well abandonment operations; activities similar in nature, but 

monitored and reported according to a separate section of the OCSLA regulations. In addition, since 

the majority of removal operations took place in water depths >200 m (656 ft), only the shelf areas of 

the CPA and WPA were addressed by the proposed actions. 

In response to advancements in decommissioning methodologies and regulatory 

requirements since the 1987 Programmatic EA was prepared, as well as the continued movement 

into more deepwater prospects (>200 m; 656 ft), this Agency prepared Structure-Removal 

Operations on the Gulf of Mexico Outer Continental Shelf: Programmatic Environmental 

Assessment (USDOI, MMS, 2005). This Programmatic EA serves three primary needs:

• aids in the permitting, management, and planning of future structure-removal 

operations; 

• ensures that adequate environmental reviews are conducted on all 

decommissioning proposals that would help support human health and safety 

while simultaneously protecting the sensitive marine environment; and

• serves as a reference document to implement the "tiering" objective detailed in 

NEPA’s implementing regulations (40 CFR § 1502.20) (future, site-specific EAs 

may reference appropriate chapters of this Programmatic EA to reduce 

reiteration of issues and impacts, allowing analyses to focus on specific issues 

and impacts related to the removal activity).

In 1988, this Agency requested a “generic” consultation from NMFS pursuant to Section 7 of 

the Endangered Species Act concerning potential impacts on endangered and threatened species 

associated with explosive-severance activities conducted during structure-removal operations. 

Much like the Programmatic EA, the consultation’s “generic” Biological Opinion was limited to the 

best scientific information available and concentrated primarily on the majority of structure removals 

(water depths <200 m [656 ft]). The Incidental Take Statement was therefore limited to the five 

species of sea turtles found on the shallow shelf. Reporting guidelines and specific mitigating

measures are outlined in the Incidental Take Statement and include (1) the use of a qualified NMFS 

observer, (2) aerial surveys, (3) detonation delay radii, (4) nighttime blast restrictions, (5) charge 

staggering and grouping, and (6) possible diver survey requirements.

Emphasizing a continued need for an incentive to keep explosive weights low, this Agency 

formally requested that NMFS amend the 1988 Biological Opinion to establish a minimum charge 

size of 5 lb. The NMFS’ Southeast Regional Office subsequently addressed explosive charges ≤5 lb 

in a separate, informal Biological Opinion. The October 2003 “de-minimus” Biological Opinion 

waives several mitigating measures of the “generic” 1988 Biological Opinion (i.e., aerial 
Postlease Permitting and Approval Processes A-35

observations, 48-hour pre-detonation observer coverage, onsite NOAA personnel, etc.), reduces the 

potential impact zone from 3,000 ft to 700 ft (914 m to 213 m) and gives the operators/severing 

contractors the opportunity to conduct their own observation work.

In 1989, the American Petroleum Institute petitioned NMFS under Subpart A of the Marine 

Mammal Protection Act regulations for the incidental take of spotted and bottlenose dolphins during 

structure-removal operations (i.e., for either explosive- or nonexplosive-severance activities). The 

Incidental Take Authorization regulations were promulgated by NMFS in October 1995 (Federal 

Register, 1995) and on April 10, 1996, the regulations were moved to subpart M (50 CFR §§

216.141 et seq.). Effective for 5 years, the regulations detailed conditions, reporting requirements, 

and mitigating measures similar to those listed in the 1988 ESA Consultation requirements for sea 

turtles. After the regulations expired in November 2000, NMFS and this Agency advised operators 

to continue following the guidelines and mitigating measures of the lapsed subpart pending a new 

petition and subsequent regulations. At industry’s prompting, NMFS released interim regulations in 

August 2002, which expired on February 2, 2004. Operators have continued to follow the interim 

conditions until NMFS promulgates new regulations.

After bottom-founded objects are severed and the structures are removed, operators are 

required to verify that the site is clear of any obstructions that may conflict with other uses of the 

OCS according to 30 CFR §§ 250.1740-1743. The NTL 98-26, “Minimum Interim Requirements for 

Site Clearance (and Verification) of Abandoned Oil and Gas Structures in the Gulf of Mexico,” 

provides the requirements for site clearance. The lessee must develop, and submit to BOEM for 

approval, a procedural plan for the site clearance verification procedures. For platform and caisson 

locations in water depths of <91 m (300 ft), the sites must be trawled over 100 percent of the 

designated area in two directions (i.e., N-S and E-W). Individual well-site clearances may use highfrequency (500 kHz) sonar searches for verification. Site-clearance verification must take place 

within 60 days after structure-removal operations have been conducted.

A NEPA analysis, in the form of an EA or EIS, is completed for all structure removals that 

propose explosive severance methods and/or site clearance trawling. The Marine Protected 

Species NTLs’ discussion below describes regulations, reporting guidelines, and specific mitigating

measures developed through consultation, pursuant to section 7 of the Endangered Species Act and 

the Marine Mammal Protection Act, concerning potential impacts on endangered and threatened 

species associated with explosive severance activities conducted during the structure-removal 

operations. All of the current terms and conditions of structure and well-removal activities are 

outlined in NTL 2010-G05, “Decommissioning Guidance for Wells and Platforms,” which became 

effective on October 15, 2010.

A.14 MARINE PROTECTED SPECIES NTLS

Four NTLs advise operators of measures designed to reduce impacts to Marine Protected 

Species: NTL 2012-JOINT-G02, “Implementation of Seismic Survey Mitigation Measures and 

Protected Species Observer Program”; NTL 2012-BSEE-G01, “Marine Trash and Debris Awareness 
A-36 Gulf of Mexico Multisale EIS

and Elimination”; NTL 2016-BOEM-G01, “Vessel Strike Avoidance and Injured/Dead Protected 

Species Reporting”; and NTL 2010-G05, “Decommissioning Guidance for Wells and Platforms.” The 

provisions outlined in these NTLs apply to all existing and future oil and gas operations in the Gulf of 

Mexico OCS.

The NTL 2012-JOINT-G02, “Implementation of Seismic Survey Mitigation Measures and 

Protected Species Observer Program,” provides guidance to protect marine mammals and sea 

turtles during seismic operations. This NTL clarifies how operators should implement seismic survey 

mitigating measures (including ramp-up procedures), the use of a minimum sound source, airgun 

testing, and protected species observation and reporting.

The NTL 2012-BSEE-G01, “Marine Trash and Debris Awareness and Elimination,” provides 

information on the marine trash and debris awareness training video and slide show, and both postal 

and email addresses for submitting annual training reports.

The NTL 2016-BOEM-G01, “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.

The NTL 2010-BSEE-G05, “Decommissioning Guidance for Wells and Platforms,” provides 

clarification and interpretation of regulations regarding decommissioning, as well as guidance to 

operators proposing to use explosives to perform well/casing severance. These guidelines specify 

and reference mitigation, monitoring, and reporting requirements that allow explosive charges up to 

500 lb, internal and external placement, and both above-mudline and below-mudline detonations.

A.15 RIGS-TO-REEFS

The BSEE is responsible for permitting the placement and eventual removal of temporary oil 

and gas facilities on the Federal OCS. When an OCS lease expires and/or development and 

production operations cease, companies are obligated to decommission and remove their facilities 

(30 CFR § 250.1725(a)) and clear the seabed of all obstructions (30 CFR § 250.1740). The BSEE’s 

Rigs-to-Reefs Policy provides a means by which lessees may request a waiver to the removal 

requirement. Under 30 CFR § 250.1730, BSEE may grant a departure from the 30 CFR § 

250.1725(a) requirement to remove a platform. Although BSEE supports and encourages the reuse 

of obsolete oil and gas structures as artificial reefs and is a cooperating agency in implementing the 

National Artificial Reef Plan, specific requirements must be met for a departure to be granted. The 

BSEE may allow a departure from removal requirements (30 CFR § 250.1725(a)) and applicable 

lease obligations provided that

• the structure must become part of a State artificial reef program that complies 

with the criteria in the National Artificial Reef Plan (30 CFR § 250.1730(a));
Postlease Permitting and Approval Processes A-37

• the responsible State agency requires a permit from the COE and must accept 

title and liability for the reefed structure once removal/reefing operations are 

concluded (30 CFR § 250.1730(a)); and

• the lessee/operator must satisfy any USCG navigational requirements for the 

reefed structure (30 CFR § 250.1730(b)).

All five Gulf Coast States have active artificial reef programs that develop and manage 

artificial reefs on the Federal OCS; however, Louisiana and Texas are the primary participants since 

the majority of platforms are installed offshore these two states. Since the inception of Rigs-to Reef, 

over 470 decommissioned platforms have been donated and deployed as artificial reefs in the Gulf 

of Mexico.

A.16 REFERENCES

Federal Register. 1995. Incidental take of marine mammals; bottlenose dolphins and spotted 

dolphins. 60 FR 233, pp. 62243-62244. December 5, 1995.

Federal Register. 1997. Training of lessee and contractor employees engaged in oil and gas and 

sulphur operations in the outer continental shelf (OCS). Final rule. 62 FR 24, pp. 5320-5329. 

February 5, 1997.

Federal Register. 2000. Oil and gas and sulphur operations in the outer continental shelf—

Subpart O—Well control and production safety training. Final rule. 65 FR 157, 

pp. 49485-49491. August 14, 2000.

Federal Register. 2005. Oil and gas and sulphur operations in the outer continental shelf-Plans and 

information. Final Rule. 70 FR 167, pp. 51478-51519. August 30, 2005.

Federal Register. 2006. Oil and gas and sulphur operations in the outer continental shelf—Incident 

reporting requirements. Final rule. 71 FR 73, pp. 19640-19646. April 17, 2006.

Federal Register. 2010. Oil and gas and sulphur operations in the outer continental shelf—

Increased safety measures for energy development on the outer continental shelf. Interim final 

rule. 75 FR 198, pp. 63346-63377. October 14, 2010.

Regg, J.B., S. Atkins, B. Hauser, J. Hennessey, B. Kruse, J. Lowenhaupt, B. Smith, and A. White. 

2000. Deepwater development: A reference document for the deepwater environmental 

assessment, Gulf of Mexico OCS (1998 through 2007). U.S. Dept. of the Interior, Minerals 

Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Report MMS 

2000-015. 94 pp.

U.S. Dept. of the Interior. 2010. Increased safety measures for energy development on the outer 

continental shelf, May 27, 2010. U.S. Dept. of the Interior, Washington, DC. 44 pp. Internet 

website: http://loe.org/images/content/100528/Increased-Safety-Measures-Report-2.pdf. 

U.S. Dept. of the Interior. Bureau of Safety and Environmental Enforcement. 2014. Annual report 

2014. Internet website: http://www.bsee.gov/uploadedFiles/BSEE/BSEE_Newsroom/
A-38 Gulf of Mexico Multisale EIS

Publications_Library/Annual_Report/BSEE%202014%20Annual%20Report.pdf. Accessed 

December 2, 2015.

U.S. Dept. of the Interior. Bureau of Safety and Environmental Enforcement. 2015. Official 

communication. Memorandum regarding BSEE’s initiated oil spill response equipment 

deployments – coverage under the National Environmental Policy Act (NEPA) and the 

Endangered Species Act (ESA). November 18, 2015.

U.S. Dept. of the Interior. Minerals Management Service. 1987. Programmatic environmental 

assessment: Structure removal activities, Central and Western Gulf of Mexico Planning Areas. 

U.S. Dept. of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New 

Orleans, LA. OCS EIS/EA MMS 87-0002. 84 pp.

U.S. Dept. of the Interior. Minerals Management Service. 2000. Gulf of Mexico deepwater 

operations and activities: Environmental assessment. U.S. Dept. of the Interior, Minerals 

Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS EIS/EA MMS 

2000-001. 264 pp. Internet website: http://www.boem.gov/BOEM-Newsroom/Library/

Publications/2000/2000-001.aspx. 

U.S. Dept. of the Interior. Minerals Management Service. 2004. Geological and geophysical 

exploration for mineral resources on the Gulf of Mexico outer continental shelf—final 

programmatic environmental assessment. U.S. Dept. of the Interior, Minerals Management 

Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS EIS/EA MMS 2004-054. 466 pp.

U.S. Dept. of the Interior. Minerals Management Service. 2005. Structure-removal operations on 

the outer continental shelf of the Gulf of Mexico—programmatic environmental assessment. 

U.S. Dept. of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New 

Orleans, LA. OCS EIS/EA MMS 2005-013. 333 pp.
APPENDIX B 

 

COMMONLY APPLIED MITIGATING MEASURES

Commonly Applied Mitigating Measures B-3 

B COMMONLY APPLIED MITIGATING MEASURES 

Postlease mitigating measures have been implemented for over 40 years in the Gulf of 

Mexico region, as they relate to OCS plans and pipeline applications. These mitigating measures 

have been amended over time to address changes in regulations, new technology, and new 

methods of operating. Many of these mitigating measures have been adopted and incorporated into 

regulations and/or guidelines governing OCS oil and gas exploration, development, and production 

activities. All plans for OCS oil- and gas-related activities (e.g., exploration and development plans, 

pipeline applications, geological and geophysical activities, and structure-removal applications) go 

through rigorous BOEM review and approval to ensure compliance with established laws and 

regulations. Existing mitigating measures must be incorporated and documented in plans submitted 

to BOEM. Operational compliance of the mitigating measures is enforced through the Bureau of 

Safety and Environmental Enforcement’s (BSEE’s) onsite inspection program.

Mitigating measures are an integral part of BOEM’s program to ensure that postlease 

operations are always conducted in an environmentally sound manner (with an emphasis on 

minimizing any adverse impact of routine operations on the environment). For example, post-activity 

surveys are carried out to ensure that a site has been cleared of potential snags to commercial 

fishing gear, and pre-activity surveys seek to avoid archaeological sites and biologically sensitive 

areas such as pinnacles, topographic features, and chemosynthetic communities.

Some BOEM-identified mitigating measures are incorporated into OCS operations through 

cooperative agreements or efforts with industry and State and Federal agencies. These mitigating 

measures include the National Marine Fisheries Service’s (NMFS’) Observer Program to protect 

marine mammals and sea turtles during explosive removals, labeling operational supplies to track 

possible sources of debris or equipment loss, development of methods of pipeline landfall to 

eliminate impacts to beaches or wetlands, and beach cleanup events.

Site-specific mitigating measures are also applied by BOEM during plan and permit reviews. 

BOEM realized that many of these site-specific mitigations were recurring and developed a list of 

“standard” or commonly applied mitigations. There are currently over 120 standard mitigations. The 

wording of a standard mitigation is developed by BOEM in advance and may be applied whenever 

conditions warrant. Standard mitigation text is revised as often as is necessary (e.g., to reflect 

changes in regulatory citations, agency/personnel contact numbers, and internal policy). 

Site-specific mitigation “categories” include the following: 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 (EWTAs); hydrogen 

sulfide (H2S); drilling hazards; remotely operated vehicle surveys; geophysical survey reviews; and 

general safety concerns. Site-specific mitigation “types” include the following: advisories; conditions 

of approval; hazard survey reviews; inspection requirements; notifications; post-approval submittals; 

and safety precautions. In addition to standard mitigations, BOEM may also apply nonrecurring 

mitigating measures that are developed on a case-by-case basis.
B-4 Gulf of Mexico Multisale EIS

Following a lease sale, an applicant seeks approvals to develop their lease by preparing and 

submitting OCS plans. The OCS plans are reviewed by BOEM and, depending on what is proposed 

to take place in a specific place, BOEM may assign conditions of approval (COA). The COAs 

become part of the approved postlease authorization and include environmental protections, 

requirements that maintain conformance with law, the requirements of other agencies having 

jurisdiction, or safety precautions.

Some of BOEM’s conditions of approval include the following:

• other approvals prerequisite to BOEM’s approval (e.g., the Coastal Zone 

Management Act);

• safety precautions (e.g., H2S present);

• post-approval submittals (e.g., surveys and interpretive reports);

• inspection requirements (e.g., pipeline pressure testing);

• pre-deployment notifications (e.g., U.S. Department of Defense use restrictions 

and Military Warning Areas); and

• reduce or avoid environmental impacts on resources identified in NEPA or other 

laws (e.g., the National Historic Preservation Act).

BOEM is continually revising applicable mitigations to allow the Gulf of Mexico OCS Region 

to more easily and routinely track mitigation compliance and effectiveness. A primary focus of this 

effort is requiring post-approval submittal of information within a specified timeframe or after a 

triggering event (e.g., end of operations reports for plans, construction reports for pipelines, and 

removal reports for structure removals).

Table B-1 provides a list and description of standard postlease mitigating measures that may 

be required by BOEM or BSEE as a result of plan and permit review processes for the Gulf of 

Mexico OCS Region. 
Commonly Applied Mitigating Measures

B-5

Table B-1. Commonly Applied or “Standard” Mitigating Measures. 

Mitigation 

Number Mitigating Measure Title Description of Mitigation

0.0 Non-Recurring Mitigation A non-recurring mitigation is a mitigating measure that is used for a unique, special, onetime-only mitigation that is added to certain plans.

Boat Traffic Mitigations

1.04 Seismic Vessels (protected 

species requirements)

The applicant will comply with Notice to Lessees and Operators (NTL) 2012-JOINT-G02, 

“Implementation of Seismic Survey Mitigation Measures and Protected Species Observer 

Program.” Additionally, the applicant will comply with the guidance under this NTL when 

operating in all water depths (not just in water depths >200 m [656 ft] or in the Eastern 

Planning Area), and the NTL’s “Shut-Down Conditions” will be applied towards manatees.

1.05 Seismic Vessels (vessel-strike 

avoidance/reporting) 

The applicant will follow the guidance provided under NTL 2016-BOEM-G01, “Vessel 

Strike Avoidance and Injured/Dead Protected Species Reporting.” This provides guidance 

on how a seismic applicant should implement monitoring programs to minimize the risk of 

vessel strikes to protected species and report observations of injured or dead protected 

species. In lieu of a formal observer program, NTL 2016-BOEM-G01 provides specific 

guidelines that should be followed to identify and avoid injury to marine mammals and sea 

turtles.

1.06 Progressive-Transport/“Hopping”

(structure removals)

In accordance with the Outer Continental Shelf Lands Act (OCSLA) requirements (30 CFR 

§ 250.1727(g)), if at any point in the decommissioning schedule progressivetransport/“hopping” activities are required to section the jacket assembly or support 

material barge loading, a prior written request must be submitted and approval must be 

obtained from the Bureau of Safety and Environmental Enforcement’s (BSEE’s) Regional 

Supervisor, Field Operations. The applicant’s request to use progressive-transport must 

include a detailed procedural narrative and separate location plat for each “set-down” site, 

showing pipelines, anchor patterns for the derrick barge, and any known archaeological 

and/or potentially sensitive biological features. The diagram/map of the route to be taken 

from the initial structure location along the transport path to each site must also be 

submitted with the request. If the block(s) that the applicant intends to use as “set-down” 

sites have not been surveyed as per NTL 2009-G39, “Biologically-Sensitive Underwater 

Features and Areas,” and NTL 2005-G07, “Archaeological Resource Surveys and 

Reports,” the applicant may be required to conduct the necessary surveys/reporting prior 

to mobilizing on site and conducting any seafloor-disturbing activities.
B-6 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

1.07 Seismic Vessels (notification 

requirements)

In accordance with 30 CFR § 550.208(b)(2), the applicant is hereby required to notify other 

users of the Outer Continental Shelf (OCS) before conducting the proposed ancillary 

activities. Prior to commencing the survey(s), the applicant must inform the operators of 

all leases affected by the proposed activities of when and where the applicant intends to 

conduct the vessel operations to ensure that proper navigation and safety protocol are 

observed.

Air Quality Mitigations

2.05 Fuel Usage or Run Time 

Documentation

The projected nitrogen oxides (NOx) emissions amounts in the plan were calculated using 

historic (insert fuel consumption rates, run times). Maintain monthly records of the total 

annual (insert fuel consumption, run times) for the (specify the affected vessels or 

equipment) with a limit of (insert limit in gallons/year, limit in hours/year) and provide the 

information to the Bureau of Ocean Energy Management’s (BOEM’s) Regional Supervisor, 

Office of Leasing and Plans, Plans Section annually by February 1st of each year, 

beginning in the year (insert year). If no activities were conducted during a calendar year, 

provide a statement to that effect in lieu of the required records. If at any time during the 

applicant’s activities these records indicate that the NOx annual emissions may exceed the 

annual limit approved in your plan or the total annual (insert fuel consumption, run time) 

limit, the applicant must immediately prepare a revised plan pursuant to 30 CFR § 550.283 

to include the recalculated emissions amounts. The applicant will not proceed with the 

actions that could cause the potential annual increase in emissions until the revised plan 

has been submitted to and approved by BOEM.

2.08 Potential to Exceed SO2

Significance Levels (flaring)

Should hydrogen sulfide (H2S) concentrations greater than (insert number) ppm be 

encountered, the 3- and 24-hour sulphur oxides (SO2) onshore ambient air concentration 

significance levels as prescribed by 30 CFR § 550.303(e) could be exceeded during the 

proposed well test flaring. Therefore, the applicant is advised that, should H2S 

concentrations greater than (insert number) ppm be encountered, they shall use the graph 

included in their plan to determine the maximum allowable flow rate for the flaring 

operation. The applicant is responsible for ensuring that their maximum emission 

concentrations remain below the aforementioned significance levels. In accordance with 

30 CFR § 250.1164(c), the applicant is hereby required to submit monthly reports that 

contain the following: (1) the daily volume and duration (number of hours) of each flaring 

episode; (2) the H2S concentration (ppm) in the flared gas; and (3) the calculated amount 

of SO2 emitted.
Commonly Applied Mitigating Measures

B-7

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

2.11 Using Ultra-Low Sulfur Content 

Fuel

As proposed, use ultra-low sulfur content diesel fuel (sulfur concentration 0.0015% or less 

by weight) while conducting these operations. Sulfur content records must be maintained 

on the platform and made available to authorized BSEE personnel upon request.

2.12 Verification of Emissions Factors 

(clean burn engines) 

The rating, manufacturer, and type of engine(s) proposed in the applicant’s plan will be 

operated and maintained in accordance with the manufacturer’s specifications. Using a 

U.S. Environmental Protection Agency (USEPA)-approved or equivalent method, perform 

an emissions stack test on the subject engine(s) within 60 days following installation and 

at least every 3 years thereafter. These tests will be performed at loads representing 25, 

50, 75, and 100 percent of the rated capacity or at minimum, average, and highest 

operational loads to verify that the emission factors are not exceeding those used in 

calculating the proposed emissions in the plan.

Prepare a report of the results of each stack test and submit it to BOEM’s Regional 

Supervisor, Office of Leasing and Plans, Plans Section within 45 days of the test. During 

engine operation, the applicant will maintain the baseline parameters (such as air-fuel 

rations) established during the most recent successful stack test. The applicant must 

monitor and record these parameters daily to ensure consistency with those observed 

during the most recent successful stack test. Records of these parameters must be 

maintained on the platform and made available to authorized BSEE personnel upon 

request. In addition, the applicant must submit this information to BOEM’s Regional 

Supervisor, Office of Leasing and Plans, Plans Section annually by February 1st of each 

year, beginning in the year (insert year). If no activities were conducted during a calendar 

year, provide a statement to that effect in lieu of the required records.

2.13 Monitoring of NOx Emissions 

(catalytic converters)

The rating, manufacturer, and type, and catalytic converter(s) proposed in the plan must 

be operated and maintained in accordance with the manufacturer’s specifications. Using a 

USEPA-approved or equivalent method, perform an emissions stack test on the subject 

engine(s) and catalytic converter(s) within 60 days following installation and at least every 

3 years thereafter. These tests will be performed at loads representing 25, 50, 75, and 

100 percent of the rated capacity or at minimum, average, and highest operational loads to 

verify that the emissions factors are not exceeding those used in calculating the proposed 

emissions in the plan. The applicant must contact BSEE at least 30 days prior to 

conducting the test to determine proper protocol for the stack test and also to have 

BSEE’s representative witness the test. Prepare a report of the results of each stack test 

and submit it to BOEM’s Regional Supervisor, Office of Leasing and Plans, Plans Section 

within 45 days of the test.
B-8 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

During operation, the applicant will maintain the baseline parameters, such as air-fuel 

ratios for the engine(s) and the pressure drop and temperature increase across the 

catalytic converter(s) established during the most recent successful stack test. The 

applicant must monitor and record these parameters daily to ensure they remain 

consistent with those observed during the most recent successful stack test. The records 

of these parameters will be maintained on the platform and made available to authorized 

BSEE personnel upon request. In addition, the applicant must submit this information to 

BOEM’s Regional Supervisor, Office of Leasing and Plans, Plans Section annually by 

February 1st of each year, beginning in the year (insert year). If no activities were 

conducted during a calendar year, the applicant must provide a statement to that effect in 

lieu of the required records.

2.15 Sulfur Recovery Unit, Flaring 

Episodes, Production 

Curtailment

If a shutdown of the sulfur recovery unit necessitates diverting the acid gas stream and if 

the resulting increased emissions would cause the SO2 onshore ambient air concentration 

significance levels as prescribed by 30 CFR § 550.303(e) to be exceeded, begin curtailing 

production within 6 hours of the onset of the increased emissions. If curtailment is 

necessary, the appropriate reduced production rate will be reached no later than 8 hours 

from the onset of the increased emissions and will continue until such time that normal 

operation of the sulfur recovery unit can resume.

2.16 Monitoring of SO2 Emissions 

(sulfur recovery units)

The amine unit and the (specify name of sulfur recovery unit) proposed in the plan must be 

operated and maintained in accordance with the manufacturer’s specifications. Using a 

USEPA-approved or equivalent method, perform an emissions stack test on the subject 

sulfur recovery unit within 60 days following installation. This test will be performed at 

loads representing 25, 50, 75, and 100 percent of the rated capacity of the amine unit or at 

minimum, average, and highest operational loads of the amine unit to verify that the 

emission factors are not exceeding those used in calculating the proposed emissions in 

the plan. Contact BSEE’s Environmental Enforcement Division at least 30 days prior to 

conducting the test to determine proper protocol for the stack test and also to have 

BSEE’s representative witness the test. Prepare a report of the results of each stack test 

and submit it to BOEM’s Regional Supervisor, Office of Leasing and Plans, Plans Section 

within 45 days of the test.

The applicant must monitor and record these parameters daily to ensure they remain 

consistent with the approved baseline parameters from the most recent successful stack 

test. Records of these parameters must be maintained on the platform and made 

available to authorized BSEE personnel upon request. In addition, the applicant must 
Commonly Applied Mitigating Measures

B-9

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

submit this information to BOEM’s Regional Supervisor, Office of Leasing and Plans, 

Plans Section annually by February 1st of each year, beginning in the year (insert year). If 

no activities were conducted during a calendar year, provide a statement to that effect in 

lieu of the required records.

2.17 Verification of Emissions Factors 

(general)

The rating, manufacturer, and type of engine(s) proposed in the plan will be operated and 

maintained in accordance with the manufacturer’s specifications. Using a USEPAapproved or equivalent method, perform an emissions stack test on the subject engine(s) 

within 60 days following installation and at least every 3 years thereafter. These tests will 

be performed at loads representing 25, 50, 75, and 100 percent of the rated capacity or at 

minimum, average, and highest operational loads to verify that the emission factors are 

not exceeding those used in calculating the proposed emissions in the plan. Contact 

BSEE’s Environmental Enforcement Division at least 30 days prior to conducting the test 

to determine proper protocol for the stack test and also to have BSEE’s representative 

witness the test.

Prepare a report of the results of each stack test and submit it to BOEM’s Regional 

Supervisor, Office of Leasing and Plans, Plans Section within 45 days of the test. During 

engine operation, the applicant will maintain the baseline parameters (such as air-fuel 

rations) established during the most recent successful stack test. The applicant must 

monitor and record these parameters daily to ensure consistency with those observed 

during the most recent successful stack test. Records of these parameters must be 

maintained on the platform and made available to authorized BSEE personnel upon 

request. In addition, the applicant must submit this information to BOEM’s Regional 

Supervisor, Office of Leasing and Plans, Plans Section annually by February 1st of each 

year, beginning in the year (insert year). If no activities were conducted during a calendar 

year, provide a statement to that effect in lieu of the required records.

2.18 Alternative Monitoring of NOx

Emissions (catalytic converters)

Using your established baseline parameters listed below, monitor the performance of the 

engine(s) and catalytic converter(s) and record daily to ensure that performance remains 

consistent. Air to fuel ratio for engine: (insert baseline parameters); pressure drop across 

catalytic converter: (insert baseline parameters); and temperature increase across 

catalytic converter: (insert baseline parameters).

Records of these parameters must be maintained on the platform and made available to 

authorized BSEE personnel upon request. In addition, the applicant must submit a 

summary of these data to BOEM’s Regional Supervisor, Office of Leasing and Plans, 
B-10 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

Plans Section annually by February 1st of each year, beginning in the year (insert year). 

The summary will report minimum, average, and maximum values for the above-listed 

parameters, on a monthly basis, for the year. If no activities were conducted during a 

calendar year, provide a statement to that effect in lieu of the required records. Notify 

BOEM’s Regional Supervisor, Office of Leasing and Plans, Plans Section as soon as 

practical but no later than 24 hours after the event, whenever the engine(s) or catalytic 

converter(s) exceed these parameters for periods greater than a day. File a detailed 

report with this office within 5 days of the termination of any such event. At a minimum, 

this report will include a chronology of the event, NOx emissions rates in pounds per hour, 

total NOx emissions for the duration of the event, and any measures taken to regain 

operation within these parameters or to prevent a recurrence of similar events. If 

exceeding the above parameters results in increased emissions that would cause onshore 

NOx concentration to exceed BOEM significance levels (30 CFR § 550.303(e)), curtail the 

use of the (identify equipment associated with catalytic converter) within 2 days of the 

onset of the increased emissions and continue curtailment until such time that normal 

operation of the catalytic converter can resume.

Archaeology Mitigations

3.00 Archaeology Non-Recurring 

Mitigation

A non-recurring mitigation is a mitigating measure that is used for a unique, special, onetime-only mitigation that is added to certain plans.

3.02 Buried Channels (pipeline 

applications)

BOEM’s review indicates that the proposed activities are in the vicinity of buried channel 

margin features that may contain significant archaeological resources. In accordance with 

30 CFR § 250.1007(a)(5), the applicant must either (1) conduct an underwater 

archaeological investigation (diver and/or remotely operated vehicle (ROV) investigations) 

prior to commencing activities to determine whether these features represent 

archaeological resources or (2) ensure that the depth of the pipeline trench in the vicinity 

of these features does not exceed 3 ft and that all other seafloor-disturbing actions 

resulting from the proposed activities avoid the subject channel margins (see the enclosed 

map depicting the avoidance area in the application). If the applicant conducts an 

underwater archaeological investigation prior to commencing operations, the applicant 

should contact BOEMs’ Office of Environment and BSEE’s Environmental Enforcement 

Branch at least 2 weeks prior to performing operations to obtain the investigation 

methodology. If the applicant chooses to avoid the features, then the applicant should 

submit anchor position plats, at a scale of 1 in = 1,000 ft with differential global positioning 

system (DGPS) accuracy, with your pipeline construction report required by 30 CFR § 

250.1008(b). These plats must depict the “as-placed” location of all anchors, anchor 
Commonly Applied Mitigating Measures

B-11

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

chains, wire ropes, and cables on the seafloor (including sweep) and demonstrate that the 

features were not physically impacted by the construction activities. If the applicant 

chooses to avoid the features and no anchoring activities were conducted during pipeline 

construction, provide a statement to that effect in lieu of the required anchor position plats. 

This mitigation may be applied by BSEE at the post-approval stage.

3.03 Buried Channels (plans) BOEM’s review indicates that the proposed activities are in the vicinity of buried channel 

margin features that may contain significant archaeological resources. In accordance with 

30 CFR § 550.194, the applicant must either (1) conduct an underwater archaeological 

investigation (diver and/or ROV investigations) prior to commencing activities to determine 

whether these features represent archaeological resources or (2) ensure that all seafloordisturbing actions resulting from the proposed activities avoid the subject features (see the 

enclosed map depicting the avoidance area in the application). If the applicant conducts 

an underwater archaeological investigation prior to commencing operations, contact 

BOEM’s Office of Environment least 2 weeks prior to performing operations to obtain the 

investigation methodology.

If the applicant chooses to avoid the features, then submit an as-built map at a scale of 

1 in = 1,000 ft with DGPS accuracy, showing the location of all seafloor disturbances (e.g., 

the rig or platform, anchors, anchor chains, wire ropes, cables, etc.) relative to these 

features, to BOEM’s Regional Supervisor, Office of Leasing and Plans, Plans Section at 

the same time that the applicant submits its (specify submittal type).

3.04 and 

3.05

Magnetic Anomalies and/or 

Side-Scan Sonar Targets 

(pipeline applications - multiple 

features)

Magnetic Anomalies and/or 

Side-Scan Sonar Targets 

(pipeline application – singular 

feature)

BOEM’s review indicates that the proposed activities are in the vicinity of the unidentified 

(insert magnetic anomalies, side-scan sonar targets, magnetic anomalies and side-scan 

sonar targets) listed in the enclosure, features that may represent significant 

archaeological resources. In accordance with 30 CFR § 250.1007(a)(5), the applicant 

must either (1) conduct an underwater archaeological investigation (diver and/or ROV 

investigations) prior to commencing activities to determine whether these features 

represent archaeological resources or (2) ensure that all seafloor-disturbing actions 

resulting from the proposed activities avoid the unidentified features by a distance greater 

than that listed in the enclosure. If the applicant conducts an underwater archaeological 

investigation prior to commencing operations, then the applicant must contact BOEM’s 

Office of Environment at least 2 weeks prior to performing operations to obtain the 

investigation methodology. If the applicant chooses to avoid the features, then submit 

anchor position plats, at a scale of 1 in = 1,000 ft with DGPS accuracy, with the pipeline 

construction report required by 30 CFR § 250.1008(b). These plats must depict the 
B-12 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

“as-placed” location of all anchors, anchor chains, wire ropes, and cables on the seafloor 

(including sweep) and demonstrate that the features were not physically impacted by the 

construction activities. If the applicant chooses to avoid the features and no anchoring 

activities were conducted during pipeline construction, then provide a statement to that 

effect in lieu of the required anchor position plats. This mitigation may be applied by 

BSEE at the post-approval stage.

3.06 and 

3.07

Magnetic Anomalies and/or 

Side-Scan Sonar Targets (plans 

– multiple features)

Magnetic Anomalies and/or 

Side-Scan Sonar Targets (plans 

– singular feature)

BOEM’s review indicates that the proposed activities are in the vicinity of the unidentified 

(insert magnetic anomalies, side-scan sonar targets, magnetic anomalies and side-scan 

sonar targets) listed in the enclosure of the application, features that may represent 

significant archaeological resources. In accordance with 30 CFR § 550.194, the applicant 

must either (1) conduct an underwater archaeological investigation (diver and/or ROV

investigations) prior to commencing the activities to determine whether these features 

represent archaeological resources or (2) ensure that all seafloor-disturbing actions 

resulting from the proposed activities avoid the subject features by a distance greater than 

that listed in the enclosure of the application. If the applicant conducts an underwater 

archaeological investigation, then the applicant must contact BOEM’s Office of 

Environment at least 2 weeks prior to performing operations to obtain the investigation 

methodology. If the applicant chooses to avoid the features, submit an as-built map at a 

scale of 1 in = 1,000 ft with DGPS accuracy, showing the location of all seafloor 

disturbances (e.g., the rig or platform, anchors, anchor chains, wire ropes, cables, etc.) 

relative to these features to BOEM’s Regional Supervisor, Office of Leasing and Plans, 

Plans Section at the same time the applicant submits the plan.

3.08 Buried Channels (lease block 

survey review

BOEM’s review of the archaeological assessment indicates that there are buried channel 

margin features that may contain significant archaeological resources in the lease 

block(s). The enclosed map in the application identifies the areas to be avoided during 

any future development within the block(s). In accordance with 30 CFR § 550.194, the 

applicant must either (1) conduct an underwater archeological investigation (diver and/or 

ROV investigations) to determine whether these features represent archaeological 

resources or (2) ensure that all seafloor-disturbing actions required by future exploration or 

development will avoid the subject features. If the applicant chooses to conduct an 

underwater archaeological investigation, then the applicant must contact BOEM’s Office of 

Environment at least 2 weeks prior to performing operations to obtain the investigation 

methodology.
Commonly Applied Mitigating Measures

B-13

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

3.09 and 

3.10

Magnetic Anomaly and/or SideScan Sonar Target (survey 

review – single feature)

Magnetic Anomaly and/or SideScan Sonar Target (survey 

review – multiple features)

BOEM’s review of the archaeological assessment indicates the presence of the 

unidentified magnetic anomaly(ies), side-scan sonar target(s), or magnetic anomaly(ies) 

and side-scan sonar target(s) listed in the enclosure of the application, features that may 

represent significant archaeological resources. In accordance with 30 CFR § 550.194, the 

applicant must either (1) conduct an underwater archaeological investigation (diver and/or 

ROV investigations) to determine whether these features represent archaeological 

resources or (2) ensure that all seafloor-disturbing actions required by future exploration 

and development avoid the unidentified features by a distance greater than that listed in 

the enclosure of the application. If the applicant conducts an underwater archaeological 

investigation, then the applicant must contact BOEM’s Office of Environment at least 

2 weeks prior to performing operations to obtain the investigation methodology.

3.11 Unsurveyed Area (plans) Avoid impacts to the seafloor in the unsurveyed area approximately (insert number) feet to 

the (insert direction) of the proposed (specify Well X, Wells X and Y, Platform X, etc.). 

This area has been identified as requiring a (insert 50-meter or 300-meter) line spacing 

archaeological resource survey to determine the potential for archaeological resources. 

BOEM has no archaeological resource assessment on file for this area and, therefore, 

cannot determine the potential effects to archaeological resources outside of the 

applicant’s survey coverage. Submit an as-built map at a scale of 1 in = 1,000 ft with 

DGPS accuracy, showing the location of all seafloor disturbances (e.g., the rig or platform, 

anchors, anchor chains, wire ropes, cables, etc.) relative to the unsurveyed area to 

BOEM’s Regional Supervisor, Office of Leasing and Plans, Plans Section at the same time 

the applicant submits the plan.

3.12 and 

3.13

Magnetic Anomalies and/or 

Side-Scan Sonar Targets 

(structure removals – multiple 

features)

Magnetic Anomalies and/or 

Side-Scan Sonar Targets 

(structure removals – single 

feature)

BOEM’s review indicates that the proposed activities are in the vicinity of the unidentified 

magnetic anomaly(ies), side-scan sonar target(s), or magnetic anomaly(ies) and side-scan 

sonar target(s) listed in the table in the application, a feature that may represent a 

significant archaeological resource. In accordance with 30 CFR § 250.194(c), the 

applicant must either (1) conduct an underwater archaeological investigation (diver and/or 

ROV investigations) prior to commencing activities to determine whether this feature 

represents an archaeological resource or (2) ensure that all anchoring operations (e.g., 

anchors, anchor chains, wire ropes, cables, etc.) avoid the unidentified feature by a 

distance greater than that listed in the table in the application. If the applicant plans to 

conduct an underwater archaeological investigation prior to commencing operations, then 

the applicant must contact BOEM’s Office of Environment to obtain the investigation 

methodology at least 2 weeks prior to performing operations and contact BOEM’s Office of 

Environment and BSEE’s Environmental Enforcement Branch. If the applicant chooses to 
B-14 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

avoid the feature, then include in the post-removal report as-built plats, at a scale of 1 in = 

1,000 ft with DGPS accuracy, the position of anchors, anchor chains, wire ropes, and 

cables deployed during the structure removal relative to the feature. In addition, supply a 

copy of ALL vessel logs related to the removal operations (e.g., anchor handling vessels, 

lift boats, dive vessels, and tug boats). This mitigation may be applied by BSEE at the 

post-approval stage.

3.16 ROV Surveys (plans) The proposed operations are in an area designated by BOEM’s Regional Director as 

having a high potential for the location of historic shipwrecks. In accordance with 30 CFR 

§ 550.194(a)(2), prior to commencing the operations, conduct an ROV investigation (using 

video, sector-scanning sonar, or multibeam bathymetry) of the seafloor areas that could be 

disturbed by the operations (e.g., the rig or platform, anchors, anchor chains, wire ropes, 

cables, etc.) to ensure that the applicant will avoid harming potentially significant 

archaeological sites. The applicant must contact BOEM’s Office of Environment at least 

2 weeks prior to performing operations to obtain the investigation methodology. The 

applicant must submit a report of this investigation prepared by a qualified marine 

archaeologist, along with an “as-placed” anchor plat and copies of the ROV video and 

acoustic recordings of the investigation to BOEM’s Regional Supervisor, Office of Leasing 

and Plans, Plans Section at the same time the applicant submits the plan. If the applicant 

discovers any potential archaeological resource (i.e., cannot be definitively identified as 

modern debris or refuse) while conducting this investigation or future operations, the 

applicant must immediately halt any seafloor-disturbing activities and report the discovery 

to BOEM’s Regional Supervisor, Office of Environment.

3.17 Conditional Approval for ROV 

Surveys (plans)

Drilling permits will not be issued for proposed well(s) and well name(s) until the applicant 

submits an archaeological report to BOEM’s Regional Supervisor, Office of Leasing and 

Plans, Plans Section and receives approval. This report must be based on an ROV 

investigation (using video, sector-scanning sonar, or multibeam bathymetry) of the 

seafloor areas that could be disturbed by the operations. The report must be prepared by 

a qualified marine archaeologist and must include copies of the ROV video and acoustic 

recordings of the investigation, along with an “as-placed” anchor plat. If the applicant 

discovers any potential archaeological resource (i.e., cannot be definitively identified as 

modern debris or refuse) while conducting this investigation, the applicant must 

immediately halt any seafloor-disturbing activities and report the discovery to BOEM’s 

Regional Supervisor, Office of Environment. The applicant must contact BOEM’s Office of 

Environment at least 2 weeks prior to performing this survey to obtain the investigation 

methodology.
Commonly Applied Mitigating Measures

B-15

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

3.18 Buried Channels (structure 

removal)

BOEM’s review indicates that the proposed activities are in the vicinity of buried channel 

margin features that may contain significant archaeological resources. In accordance with 

30 CFR § 250.194(c), the applicant must either (1) conduct an underwater archaeological 

investigation (diver and/or ROV investigations) prior to commencing activities to determine 

whether these features represent archaeological resources or (2) ensure that all seafloordisturbing actions resulting from the proposed activities (e.g., site-clearance trawling, 

anchors, anchor chains, wire ropes, cables, etc.) avoid the subject features (see the 

enclosed map depicting the avoidance area in the application). If the applicant plans to 

conduct an underwater archaeological investigation prior to commencing operations, then 

the applicant must contact BOEM’s Office of Environment at least 2 weeks prior to 

performing operations to obtain the investigation methodology and contact BOEM’s, Office 

of Environment and BSEE’s Environmental Enforcement Branch. If the applicant chooses 

to avoid the features, then include in the post-removal report as-built plats, at a scale of 

1 in = 1,000 ft with DGPS accuracy, the position of anchors, anchor chains, wire ropes, 

and cables deployed during the structure removal relative to these features. In addition, 

supply a copy of ALL vessel logs related to the removal operations (e.g., anchor handling 

vessels, lift boats, dive vessels, and tug boats). This mitigation may be applied by BSEE 

at the post-approval stage.

3.20 Avoidance of Potential 

Archaeological Resources

BOEM’s review indicates that the proposed operations have the potential to impact 

submerged archaeological resources that could be in the area of potential effect, which 

encompasses all portions of the seafloor where bottom-disturbing activities are to occur. 

Before conducting any authorized, bottom-disturbing activities, the company will follow the 

guidance provided at http://www.boem.gov/Environmental-Stewardship/Archaeology/Gulfof-Mexico-Archaeological-Information.aspx, which includes minimum survey 

recommendations, requisite certification submittals, and post-activity reporting standards 

needed to ensure compliance with the regulations under 30 CFR § 550.194. This 

mitigation may be applied by BSEE at the post-approval stage.

3.21 and 

3.22

Side-Scan Sonar Targets (site 

clearance – single features)

Side-Scan Sonar Targets (site 

clearance – multiple features)

BOEM’s review indicates that the proposed activities are in the vicinity of the unidentified 

side-scan sonar target(s) listed in the table in the application, features that may represent 

significant archaeological resources. In accordance with 30 CFR § 250.194(c), the 

applicant must conduct an underwater archaeological investigation (diver and/or ROV 

investigation) under the supervision of a professional archaeologist to determine whether 

these features represent archaeological resources potentially eligible to the National 

Register of Historic Places prior to conducting site-clearance trawling activities. This 

mitigation may be applied by BSEE at the post-approval stage.
B-16 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

3.23 Protection of Potential 

Archaeological Resources (all 

structure removals)

Per 30 CFR § 250.194(c) and clarified in 2005-G07, if, during site-clearance operations 

the applicant discovers any object of potential archaeological significance, the applicant is 

required to immediately halt operations. In addition, the applicant must immediately report 

this discovery to BSEE’s Environmental Enforcement Branch. Additional guidance will be 

provided to the applicant as to what steps will be needed to protect any potentially 

submerged archaeological resources. In order for BSEE to ensure compliance with 

30 CFR § 250.194(c) and as specified under 30 CFR § 250.1743, the applicant is required 

to provide the trawling logs for both heavy-duty nets and verification nets, with descriptions 

of each item recovered. Should the applicant only pull site-clearance verification nets, the 

applicant must clearly state this within the body of the Site-Clearance Report. The 

applicant is also requested to provide the following as an appendix in the Site-Clearance 

Report: a CD or DVD of all digital photographs of the items recovered during the use of 

both the heavy-duty trawl nets and the site-clearance verification trawl nets. This 

mitigation may be applied by BSEE at the post-approval stage.

Artificial Reef Material Mitigations

4.01 Louisiana (artificial reef area) The proposed anchoring operations are located within 500 ft (152 m) of an artificial reef 

permit area established by the State of Louisiana. At least 2 weeks prior to conducting 

anchoring operations (including the use of anchors, anchor chains, and wire ropes) that 

could disturb the seafloor within 500 ft (152 m) of an artificial reef permit area, the 

applicant must contact the Louisiana Artificial Reef Coordinator to ensure that the 

proposed anchoring operations do not damage reefal material. Prior to conducting 

anchoring operations, the applicant must send an email to BSEE’s Environmental 

Enforcement Branch confirming that the Louisiana Artificial Reef Coordinator has been 

contacted.

If the anchoring operations intersect or cross-over the artificial reef permit area, then 

submit anchor position plats, at a scale of 1 in = 1,000 ft with DGPS accuracy, depicting 

the “as-placed” location of all anchors, anchor chains, wire ropes, and cables (including 

sweep if applicable) on the seafloor relative to the reefal material. For plans, submit the 

plats to BOEM’s Regional Supervisor, Office of Leasing and Plans, Plans Section at the 

same time the applicant submits the End of Operations Report (Form BSEE-0125) to the 

appropriate BSEE, Gulf of Mexico OCS Region, District Office and/or notification of 

platform installation date and final as-built location data as directed in 30 CFR § 

250.900(e). For pipelines, submit the plats with the pipeline construction report required 

by 30 CFR § 250.1008(b). For structure removals, submit the plats with the post-removal 
Commonly Applied Mitigating Measures

B-17

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

report. This mitigation may be applied by BSEE at the post-approval stage.

4.02 Texas (artificial reef general 

permit area)

The proposed operations are located within an artificial reef General Permit Area 

established by the State of Texas. At least 2 weeks prior to conducting operations 

(including the use of anchors, anchor chains, and wire ropes) that could disturb the 

seafloor within the artificial reef General Permit Area, contact the Texas Artificial Reef 

Coordinator to ensure that the proposed operations do not damage reefal material. Prior 

to conducting operations, the applicant must send an email to BSEE’s Environmental 

Enforcement Branch confirming that the Texas Artificial Reef Coordinator has been 

contacted. This mitigation may be applied by BSEE at the post-approval stage.

4.021 Texas (artificial reef permit area 

– anchoring)

The proposed anchoring operations are located within 1,000 ft (305 m) of an artificial reef 

permit area established by the State of Texas. At least 2 weeks prior to conducting 

anchoring operations (including the use of anchors, anchor chains, and wire ropes) that 

could disturb the seafloor within 1,000 ft (305 m) of the artificial reef permit area, contact 

the Texas Artificial Reef Coordinator to ensure that the proposed anchoring operations do 

not damage reefal material. Prior to conducting anchoring operations, the applicant must 

send an email to BSEE’s Environmental Enforcement Branch confirming that the Texas 

Artificial Reef Coordinator has been contacted.

If the anchoring operations intersect or cross-over the artificial reef permit area, submit 

anchor position plats, at a scale of 1 in = 1,000 ft with DGPS accuracy, depicting the 

“as-placed” location of all anchors, anchor chains, wire ropes, and cables (including sweep 

if applicable) on the seafloor relative to the reefal material. For plans, submit the plats to 

BOEM’s Regional Supervisor, Office of Leasing and Plans, Plans Section at the same time 

the applicant submits the End of Operations Report (Form BSEE-0125) to the appropriate 

BSEE, Gulf of Mexico OCS Region, District Office and/or notification of platform 

installation date and final as-built location data as directed in 30 CFR § 250.900(e). For 

pipelines, submit the plats with the pipeline construction report required by 30 CFR § 

250.1008(b). For structure removals, submit the plats with the post-removal report. This 

mitigation may be applied by BSEE at the post-approval stage.

4.03 Mississippi (artificial reef area) The proposed anchoring operations are located within 500 ft (152 m) of an artificial reef 

permit area established by the State of Mississippi. At least 2 weeks prior to conducting 

anchoring operations (including the use of anchors, anchor chains, and wire ropes) that 

could disturb the seafloor within 500 ft (152 m) of an artificial reef structure or an artificial 

reef permit area, contact the Mississippi Artificial Reef Coordinator to ensure that the 

proposed anchoring operations do not damage reefal material. Prior to conducting 
B-18 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

anchoring operations, the applicant must send an email to BSEE’s Environmental 

Enforcement Branch confirming that the Mississippi Artificial Reef Coordinator has been 

contacted. This mitigation may be applied by BSEE at the post-approval stage.

4.04 Alabama (artificial reef general 

permit area)

The proposed operations are in a General Permit Area established by the State of 

Alabama for the placement of artificial reef material. At least 2 weeks prior to conducting 

operations, contact the Alabama Artificial Reef Coordinator to ensure that the proposed 

operations do not damage reefal material. Prior to conducting operations, the applicant 

must send an email to BSEE’s Environmental Enforcement Branch confirming that the 

Alabama Artificial Reef Coordinator has been contacted. This mitigation may be applied 

by BSEE at the post-approval stage.

4.05 Florida (artificial reef general 

permit area)

The proposed operations are in a General Permit Area established by the State of Florida 

for the placement of artificial reef material. At least 2 weeks prior to conducting 

operations, contact the Florida Artificial Reef Coordinator to ensure that the proposed 

operations do not damage reefal material. Prior to conducting operations, the applicant 

must send an email to BSEE’s Environmental Enforcement Branch confirming that the 

Florida Artificial Reef Coordinator has been contacted. This mitigation may be applied by 

BSEE at the post-approval stage.

4.06 Post-Reefing Survey 

Requirements

BOEM’s review indicates that the structure proposed for decommissioning will be 

abandoned-in-place as an artificial reef under the Rigs-to-Reefs Program. In order to 

verify compliance with OCSLA reefing (30 CFR § 250.1727(g)) and obstruction clearance 

requirements (30 CFR § 250.1740(a)(2)), the applicant is required to conduct a highresolution sonar survey (500 kHz or greater) of the permitted reefal material. The 

applicant must design the line spacing (for side-scan) or sonar drops (for sector-scanning) 

and the display range to ensure that 100 percent of the material permitted under this 

action is covered and that it is demonstrated that the associated seabed is clear of all 

obstructions apart from the reefal material. The applicant is required to submit the sonar 

data/survey report to BSEE’s Environmental Enforcement Branch at the same time as the 

post-removal report. This mitigation may be applied by BSEE at the post-approval stage.

Chemosynthetic Communities Mitigations

5.00 Chemosynthetic Communities 

Non-Recurring Mitigation

A non-recurring mitigation is a mitigating measure that is used for a unique, special, onetime-only mitigation that is added to certain plans.

5.01 Anchor Positioning (GPS) 

(plans)

The proposed activities are in the vicinity of areas that could support high-density 

deepwater benthic communities. Use a state-of-the-art positioning system (e.g., DGPS) 

on the anchor handling vessel to ensure that any seafloor disturbance resulting from the 
Commonly Applied Mitigating Measures

B-19

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

use of anchors (including that caused by the anchors, anchor chains, and wire ropes) does 

not occur within 250 ft (76 m) of such areas (see the enclosed map/Map xxx [specify map 

by name], submitted with the survey report, which depicts the areas). Submit plats for 

Well(s) (insert number[s] or name[s]), which depict the “as-placed” location of all anchors 

and any associated anchor chains and wire ropes on the seafloor, at a scale of 1 in = 

1,000 ft with DGPS accuracy, to BOEM’s Regional Supervisor, Office of Leasing and 

Plans, Plans Section at the same time the applicant submits the End of Operations Report 

(Form BSEE-0125) to the appropriate BSEE, Gulf of Mexico OCS Region, District Office to 

demonstrate that the features were not physically impacted by these anchoring activities. 

This mitigation may be applied by BSEE at the post-approval stage.

5.02 Conventional Pipeline Laying 

Vessels (GPS) (pipeline 

applications)

The proposed pipeline construction activities are in the vicinity of areas that could support 

high-density deepwater benthic communities. Use a state-of-the-art positioning system 

(e.g., DGPS) on the pipeline laying vessel and the anchor handling vessels to ensure that 

any seafloor disturbance (including that caused by anchors, anchor chains, and wire 

ropes) during pipeline construction activities does not occur within 250 ft (76 m) of such 

areas (see the enclosed map/Map xxx [specify map by name], submitted with the pipeline 

application, which depicts the areas). Additionally, include lay barge anchor position plats, 

at a scale of 1 in = 1,000 ft with DGPS accuracy, with the pipeline construction report 

required by 30 CFR § 250.1008(b), which depict the “as-placed” location of all anchors, 

anchor chains, and wire ropes on the seafloor and which demonstrate that the features 

were not physically impacted by the construction activities. This mitigation may be applied 

by BSEE at the post-approval stage.

5.03 Anchor Positioning (ROV) 

(plans)

The proposed activities are in the vicinity of areas that could support high-density 

deepwater benthic communities. Use an ROV to ensure that any seafloor disturbance 

resulting from the use of anchors (including that caused by the anchors, anchor chains, 

and wire ropes) does not occur within 250 ft (76 m) of such areas (see the enclosed 

map/Map xxx [specify map by name], submitted with your survey report which depicts the 

areas). Submit plats for Well(s) (insert number[s] or name[s]), which depict the 

“as-placed” location of all anchors and any associated anchor chains and wire ropes on 

the seafloor, at a scale of 1 in = 1,000 ft with DGPS accuracy, along with the highresolution ROV video on disc or removable drive, to BOEM’s Regional Supervisor, Office 

of Leasing and Plans, Plans Section at the same time the applicant submits the End of 

Operations Report (Form BSEE-0125) to the appropriate BSEE, Gulf of Mexico OCS 

Region, District Office to demonstrate that the features were not physically impacted by 

these anchoring activities. The ROV video screen should show time, date, depth, 
B-20 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

heading, and location coordinates. Observational notes and a corresponding map 

showing the ROV heading shall also be provided. If still images are collected, include the 

same information in the images’ integrated data. This mitigation may be applied by BSEE 

at the post-approval stage.

5.04 Conventional Pipeline Laying 

Vessels (ROV) (pipeline 

applications)

The proposed pipeline construction activities are in the vicinity of areas that could support 

high-density deepwater benthic communities. Use an ROV to ensure that any seafloor 

disturbance (including that caused by the anchors, anchor chains, and wire ropes) during 

pipeline construction activities does not occur within 250 ft of such areas (see the 

enclosed map/Map “xxx” [specify map by name], submitted with the pipeline application, 

which depicts the areas). Submit lay barge anchor position plats, at a scale of 1 in = 

1,000 ft with DGPS accuracy, with the pipeline construction report required by 30 CFR § 

250.1008(b), which depict the “as-placed” location of all anchors, anchor chains, and wire 

ropes on the seafloor and which demonstrate that the features were not physically 

impacted by the construction activities. Additionally, submit the high-resolution ROV video 

on disc or removable drive. The ROV video screen should show time, date, depth, 

heading, and location coordinates. Observational notes and a corresponding map 

showing the ROV heading shall also be provided. If still images are collected, include the 

same information in the images’ integrated data. This mitigation may be applied by BSEE 

at the post-approval stage.

5.05 Dynamically Positioned Pipeline 

Laying Vessels (GPS) (pipeline 

applications)

The proposed pipeline construction activities are in the vicinity of areas that could support 

high-density deepwater benthic communities. Use a state-of-the-art positioning system 

(e.g., DGPS) on the dynamically positioned pipeline laying vessel to ensure that any 

seafloor disturbance resulting from the pipeline construction activities does not occur 

within 250 ft (76 m) of such areas (see the enclosed map/Map “xxx” [specify map by 

name], submitted with the pipeline application, which depicts the areas). Additionally, 

include “as-built” location plats, at a scale of 1 in = 1,000 ft with DGPS accuracy, with the 

pipeline construction report required by 30 CFR § 250.1008(b), which depict the location of 

the pipeline(s) relative to these features to demonstrate that the features were not 

physically impacted by the construction activities. This mitigation may be applied by BSEE 

at the post-approval stage.

5.07 Anchor Positioning (GPS and 

ROV)

The proposed activities are in the vicinity of areas that could support high-density 

deepwater benthic communities. Use a state-of-the-art positioning system (e.g., DGPS) 

on the anchor handling vessel and use an ROV to ensure that any seafloor disturbance

resulting from the use of anchors (including that caused by the anchors, anchor chains, 

and wire ropes) does not occur within 250 ft (76 m) of such areas. Submit plats for Well(s) 
Commonly Applied Mitigating Measures

B-21

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

(insert number[s] or name[s]), which depict the “as-placed” location of all anchors and any 

associated anchor chains and wire ropes on the seafloor, at a scale of 1 in = 1,000 ft with 

DGPS accuracy, along with the high-resolution ROV video on disc or removable drive, to 

BOEM’s Regional Supervisor, Office of Leasing and Plans, Plans Section at the same time 

the applicant submits the End of Operations Report (Form BSEE-0125) to the appropriate 

BSEE, Gulf of Mexico OCS Region, District Office to demonstrate that the features were 

not physically impacted by these anchoring activities. The ROV video screen should show 

time, date, depth, heading, and location coordinates. Observational notes and a 

corresponding map showing the ROV heading shall also be provided. If still images are 

collected, include the same information in the images’ integrated data. This mitigation 

may be applied by BSEE at the post-approval stage.

5.08 Well Placement Variance (plans) There is an area capable of supporting high-density deepwater benthic communities within 

2,000 ft (610 m) of the proposed well(s), also known as the chemosynthetic well 

parameter. The proposed well(s) is/are (insert chemosynthetic distance parameter) from 

the area capable of supporting high-density deepwater benthic communities, which in this 

case provides adequate protection from muds and cuttings during operations. The actual 

well(s) shall not be placed closer than (CHEMO DISTANCE PARAMETER 1) from the 

potential habitat (see the chemosynthetic map parameter, which depicts the area). 

Provide a map showing the final as-placed well(s), potential habitat, and distance of the 

well(s) from the potential habitat to BOEM’s Regional Supervisor, Office of Leasing and 

Plans, Plans Section at the same time the applicant submits the End of Operations Report 

(Form BSEE-0125) to the appropriate BSEE, Gulf of Mexico OCS Region, District Office to 

demonstrate that the feature(s) were not physically impacted by the drilling activity. This 

mitigation may be applied by BSEE at the post-approval stage.

5.09 Well Placement Variance – “Zero 

Discharge” (plans)

There is an area capable of supporting high-density deepwater benthic communities within 

2,000 ft (610 m) of the proposed well(s) (insert chemosynthetic wells parameter). Since 

this area is (insert chemosynthetic distance parameter) from your well site(s), 

chemosynthetic reason parameter, BSEE permits the activity with the following mitigations 

added.

• Do not move the well(s) any closer to the area capable of supporting highdensity deepwater benthic communities (see chemosynthetic map parameter, 

which depicts the area).

• Follow “zero discharge” practices (i.e., no muds or cuttings shall be 

discharged near the sea surface in the vicinity of the permitted activity).

• In this instance, it is understood that the discharge of muds and cuttings will 
B-22 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

occur on or near the seafloor for the riserless portion of the drilling operations 

ONLY as part of the “zero discharge” practice.

• No muds or cuttings shall be discharged near the seafloor or at the sea 

surface once the blowout preventer and marine riser have been installed. No 

additional or excess muds or cuttings beyond those necessary to properly 

accomplish the riserless portion of the drilling activity shall be discharged on 

or near the seafloor.

• Perform an assessment survey after the drilling of the well(s) is complete. 

(a) Conduct an ROV survey to assess sedimentation and its effects on the 

area capable of supporting high-density deepwater benthic communities (see 

chemosynthetic map parameter 1, which depicts the area. Transects must be 

run no more than 50 ft apart). (b) Ensure that the imagery in the ROV survey 

is high enough quality to adequately assess drilling effects. (This can be 

accomplished by employing the use of high-resolution still photography, highresolution video, and/or lower resolution imaging through the use of close-up 

photography.) (c) The surveyed areas shall be recorded and documented on 

disc or removable drive for review, and the screen should show time, date, 

depth, heading, and location coordinates.

This mitigation may be applied by BSEE at the post-approval stage.

Coastal Zone Management Mitigations

6.01 Texas (Coastal Zone 

Management)

Drilling permits cannot be issued for the proposed wells until concurrence with the coastal 

zone management consistency certification has been received by BOEM’s Office of 

Environment from the Texas General Land Office or until concurrence with the certification 

has been conclusively presumed.

6.02 Louisiana (Coastal Zone 

Management)

Drilling permits cannot be issued for the proposed wells until concurrence with the coastal 

zone management consistency certification has been received by BOEM’s Office of 

Environment from the Louisiana Department of Natural Resources or until concurrence 

with the certification has been conclusively presumed.

6.03 Alabama (Coastal Zone 

Management)

Drilling permits cannot be issued for the proposed wells until concurrence with the coastal 

zone management consistency certification has been received by BOEM’s Office of 

Environment from the Alabama Department of Environmental Management or until 

concurrence with the certification has been conclusively presumed.

6.04 Mississippi (Coastal Zone 

Management)

Drilling permits cannot be issued for the proposed wells until concurrence with the coastal 

zone management consistency certification has been received by BOEM’s Office of 
Commonly Applied Mitigating Measures

B-23

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

Environment from the Mississippi Department of Marine Resources or until concurrence 

with the certification has been conclusively presumed.

6.05 Florida (Coastal Zone 

Management)

Drilling permits cannot be issued for the proposed wells until concurrence with the coastal 

zone management consistency certification has been received by BOEM’s Office of 

Environment from the Florida Department of Environmental Protection or until concurrence 

with the certification has been conclusively presumed.

Flower Garden Banks Mitigations

7.07 Environmental Monitoring Plan Develop a plan for the early initiation of environmental monitoring of the effects of a 

hydrocarbon spill that may occur as a result of the proposed activities on the resources of 

the Flower Garden Banks National Marine Sanctuary, including water quality, pelagic fish, 

and benthic communities.

7.09 Pressure Sensor Testing High- and low-pressure sensors protecting the proposed pipeline will be tested at least 

once bi-weekly with no more than 3 weeks elapsing between each test. The applicant will 

maintain these records on the platform and will make them available to BSEE personnel 

upon request.

7.10 Pressure Sensor Setting The low-pressure sensor protecting the proposed pipeline will be set no lower than 

10 percent below the lower limit of the normal operating pressure range.

Hydrogen Sulfide Mitigations

8.01, 8.02, 

and 8.03

H2S Present (plans)

H2S Unknown (plans)

H2S Absent (plans)

In response to the request accompanying your plan for a hydrogen sulfide (H2S) 

classification, the area in which the proposed drilling operations are to be conducted is 

hereby classified, in accordance with 30 CFR § 250.490(c), as “H2S present,” “H2S 

unknown,” or “H2S absent.”

Accordingly, comply with the appropriate requirements of 30 CFR § 250.490 if H2S is 

present or unknown.

8.04 H2S Concentration Deviation The plan indicates that the applicant anticipates H2S at a concentration of approximately 

(specify the ppm). Should the applicant actually encounter H2S at a concentration greater 

than 500 ppm, revise the plan in accordance with 30 CFR § 550.285 to include toxic 

modeling and an analysis of any potential environmental impacts. Contact BOEM’s Office 

of Environment to obtain the methodology for modeling an H2S plume. The applicant must 

receive approval of the revised plan before additional permits filed under the plan will be 

approved.
B-24 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

8.05 Corrosion Inspections (H2S

pipelines)

Inspect the pipeline(s) bi-annually, annually, or biennially for an indication of corrosion or 

other flaws. Report the results of these inspections to BSEE’s Office of Field Operations 

within 30 days of completion. This mitigation may be applied by BSEE at the postapproval stage.

8.07 National Ocean Service 

Notification (H2S pipelines)

When the applicant provides the National Ocean Service, Nautical Data Section with a 

copy of the pipeline construction report plat, the applicant must also request that the 

National Ocean Service, Nautical Data Section include the pipeline(s) on their navigation 

charts and identify it/them as (an) H2S or toxic sour gas pipeline(s).

8.08 USCG Notification (H2S 

pipelines)

Immediately after the applicant begins operation of the pipeline(s), the applicant must 

notify the U.S. Coast Guard Commander, Eighth Coast Guard District that the pipeline(s) 

is/are in operation and request that USCG publish information about the pipeline(s), 

including the fact that it is or they are transporting natural gas with a high concentration of 

H2S, in the Eighth District Local Notice to Mariners, Gulf of Mexico.

8.09 H2S Concentration Deviation 

(pipeline applications)

The application indicated that the applicant anticipates the H2S concentration of the 

product to be transported in the proposed pipeline is approximately (specify the ppm). 

Should the applicant determine at some future date that the H2S concentration is greater 

than 500 ppm, immediately submit an application to modify the pipeline in accordance with 

30 CFR § 250.1007(b) to include toxic modeling and an analysis of any potential 

environmental impacts. Contact BOEM’s Office of Environment to obtain the methodology 

for modeling an H2S plume.

8.10 Notification to Federal Aviation 

Administration

Prior to initiating operations approved in your plan or pipeline application, the applicant 

shall update their emergency notification list in their H2S contingency plan to include the 

Federal Aviation Administration (FAA): Houston Air Traffic Control/Traffic Management 

Control Desk). In the event of an above-water or below-water sour gas release greater 

than 100 standard cubic feet, notify the FAA that air traffic (except evacuation and medical 

aircraft) should be routed safely away from the site until further notice. For purposes of 

avoidance recommendations to the FAA, a distance of 10 nmi (11.5 mi; 18.5 km) and an 

altitude of 4,000 ft (1,1219 m), as minimal, shall be used. In the case of a release of H2S 

(that constitutes an emergency), notify all facilities that might be exposed to atmospheric 

concentrations of 20 ppm or more of H2S (i.e., all facilities located within [insert number] 

miles of the H2S release). The applicant must also assist in the removal of all personnel 

as well as any other persons observed within the affected area.

8.11 H2S Absent and H2S Present or 

Unknown below Certain Depths 

In response to the request accompanying the plan for a H2S classification, the area in 

which the proposed drilling operations are to be conducted above (specify depth) is hereby 
Commonly Applied Mitigating Measures

B-25

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

(plans) classified, in accordance with 30 CFR § 250.490(c), as H2S absent. However, the area in 

which the proposed drilling operations are to be conducted below (specify depth) is hereby 

classified, in accordance with 30 CFR § 250.490(c), as H2S present or unknown. 

Accordingly, comply with the appropriate requirements of 30 CFR § 250.490.

Live Bottom Areas

9.00 Hard Bottoms/Pinnacles/

Potentially Sensitive Biological 

Features Non-Recurring 

Mitigation

A non-recurring mitigation is a mitigating measure that is used for a unique, special, onetime-only mitigation that is added to certain plans.

9.01 Hard Bottoms/Pinnacles/

Potentially Sensitive Biological 

Features (conventional lay 

barge) (pipeline applications)

BOEM’s analysis indicates that there are hard bottoms/pinnacles/potentially sensitive 

biological features (PSBFs) that likely provide habitat for biological assemblages located 

within the scope of the anchor array of the pipeline lay barge. The pipeline construction 

activities (including the use of anchors, chains, and wire ropes) must avoid these hard 

bottoms/pinnacles/PSBFs as depicted on the enclosed map(s) in the application by a 

distance of at least 100 ft (30 m). Include lay barge anchor position plats, at a scale of 1 in 

= 1,000 ft (305 m) with DGPS accuracy, with the pipeline construction report required by 

30 CFR § 250.1008(b), which depict the “as-placed” location of all anchors, anchor chains, 

and wire ropes on the seafloor and which demonstrate that the features were not 

physically impacted by the construction activities. This mitigation may be applied by BSEE 

at the post-approval stage.

9.03 Hard Bottoms/Pinnacles/

Potentially Sensitive Biological 

Features (plans)

BOEM’s analysis indicates that there are hard bottoms/pinnacles/PSBFs located in the 

vicinity of the activities proposed in the plan that likely provide habitat for biological 

assemblages. Any bottom-disturbing activities associated with the activities proposed in 

the plan must avoid these hard bottoms/pinnacles/PSBFs as depicted on the enclosed 

map(s) in the application by a distance of at least 100 ft (30 m). Submit to BSEE’s Office 

of Field Operations at the same time you submit your End of Operations report (Form 

BSEE-0125) to the appropriate BSEE, Gulf of Mexico OCS Region, District Office an asbuilt map at a scale of 1 in = 1,000 ft with DGPS accuracy, showing the location of any 

seafloor disturbance (e.g., jack-up rig, barge anchors, etc.) relative to these features. This 

mitigation may be applied by BSEE at the post-approval stage.

9.04 Hard Bottoms/Pinnacles/

Potentially Sensitive Biological 

Features (DP lay barge) 

(pipeline applications)

BOEM’s analysis indicates that there are hard bottoms/pinnacles/PSBFs that likely provide 

habitat for biological assemblages located on or near the proposed pipeline route. The 

pipeline construction activities must avoid these hard bottoms/pinnacles/PSBFs as 

depicted on the enclosed map(s) in the application by a distance of at least 100 ft (30 m). 
B-26 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

This mitigation may be applied by BSEE at the post-approval stage.

9.05 Hard Bottoms/Pinnacles/

Potentially Sensitive Biological 

Features (structure removal)

BOEM’s review of the application indicates that there are hard bottoms/pinnacles/PSBFs 

located in the vicinity of the activities proposed in the application that likely provide habitat 

for biological assemblages. Any bottom-disturbing activities associated with the activities 

proposed in the application must avoid these hard bottoms/pinnacles/PSBFs as depicted 

on the enclosed map(s) in the application by a distance of at least 100 ft (30 m). Include in 

the post-removal report the as-built plats, at a scale of 1 in = 1,000 ft with DGPS accuracy, 

which depict the “as-placed” location of all anchors, anchor chains, and wire ropes on the 

seafloor deployed during the structure removal relative to these features. This mitigation 

may be applied by BSEE at the post-approval stage.

9.10 ROV Survey Required NonRecurring MitigationA non-recurring mitigation is a mitigating measure that is used for a unique, special, onetime-only mitigation that is added to certain plans.

Military Mitigations

10.09 Naval Coastal Systems Center Please be reminded that the lease stipulation requires the applicant to enter into an 

agreement with the Coastal Test and Evaluation Division, Coastal System Station/Code 

E21, Panama City, Florida 32407, concerning the control of your electromagnetic 

emissions and use of boats and aircraft in the Naval Coastal Systems Center Area.

11.11 Military Warning Area (all) BOEM’s review indicates that the proposed pipeline route and/or the routes to be taken by 

boats and aircraft in support of the proposed activities are located in or could traverse 

Military Warning Area W-(insert number) or Eglin Water Test Area EWTA-(insert number) 

(see BOEM’s website at http://www.boem.gov/MWA-Boundaries/ for a map of the areas). 

Contact the appropriate individual military command headquarters (see BOEM’s website 

at http://www.boem.gov/Military-Contacts-for-Warning-and-Water-Test-Areas/ for a list of 

the contacts) concerning the control of electromagnetic emissions and the use of boats 

and aircraft in this area(s) before commencing such traffic.

12.01 Unexploded Ordnance The proposed operations are located in an area that was used until 1970 by the U.S. 

Department of Defense as an explosives dumping area. Please be advised that 

precautions should therefore be taken while conducting operations that involve any 

disturbance of the seafloor in order to avoid possible unexploded ordnance.

12.02 Naval Mine Warfare Area

(MU 732, 733, and 734)

The proposed operations are located within a stipulated area designated by the Naval 

Mine Warfare Command for mine operations. Therefore, surface structures for exploration 

activities are subject to approval by BOEM’s Gulf of Mexico OCS Region’s Regional 

Director after consultation with the Commander, Mine Warfare Command. No permanent 

structures or debris of any kind will be allowed in the area during exploration operations. 
Commonly Applied Mitigating Measures

B-27

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

Plans for any above seafloor development operations within the designated area must be 

coordinated with the Commander, Mine Warfare Command, 325 Fifth Street, SE, Corpus 

Christi, Texas 78491-5032.

Shallow Drilling Hazards Mitigations (Plans)

14.01 Shallow Gas and/or Water Flow Exercise caution while drilling due to indications of shallow gas (and/or faulting) (and/or 

possible water flow).

14.02 Seafloor Instability Exercise caution during drilling rig placement due to indications of seafloor instability.

14.03 Insufficient Information Exercise caution during drilling rig placement due to insufficient information regarding 

seafloor foundation integrity.

Shallow Hazards Mitigations

15.01 and 

15.02

Multiple Hazards (plans)

Single Hazard (plans)

BOEM’s review indicates that there are pipeline(s), unidentified magnetic anomaly(ies), 

unidentified side-scan sonar contact(s), or other specified hazard(s) in the vicinity of (insert 

name of platform(s) or well(s)) that may pose a hazard to the proposed operations. 

Therefore, take precautions in accordance with NTL 2008-G05, Section VI.B, prior to 

performing operations.

15.05 and 

15.06

Multiple Hazards 

(plans/pipelines) (anchoring 

activities)

Single Hazard (plans) 

(anchoring)

BOEM’s review indicates that there is a pipeline(s), unidentified magnetic anomaly(ies), 

unidentified side-scan sonar contact(s), or other specified hazard(s) in the vicinity of (insert 

name of platform(s) or well(s)) that may pose a hazard due to anchoring activities 

associated with the proposed operations. If any of these activities will take place within 

150 m (490 ft) of the potential hazard, take precautions in accordance with NTL 2008-G05, 

Section VI.B, prior to performing operations.

15.07 Pipeline Spanning BOEM’s review indicates areas of seafloor relief in the vicinity of the proposed pipeline 

route, which may cause spanning problems for the pipeline. Use an ROV in conjunction 

with the pipeline construction activities to ensure that these areas are avoided to the 

extent possible. Additionally, include a report with the pipeline construction report, which 

is required by 30 CFR § 250.1008(b) and which analyzes the as-laid pipeline with respect 

to spanning and describes the protective measures taken to ensure pipeline integrity for 

those portions of the pipeline where the areas of seafloor relief could not be avoided. This 

mitigation may be applied by BSEE at the post-approval stage.

15.08 Conflict with Anchors Please be advised that exploration activities have been approved or are pending approval 

for (insert lease, block, area), which could potentially interfere with the proposed activities. 

Therefore, the applicant should contact (insert contact name, company, address, phone 

number) prior to commencement of the activities in order to avoid any potential conflicts.
B-28 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

Topographic Features Mitigations

16.00 Topographic Features 

Non-Recurring Mitigation

A non-recurring mitigation is a mitigating measure that is used for a unique, special, onetime-only mitigation that is added to certain plans.

16.01 Shunting All Wells (plans) The proposed activities are within the “4-mile, 3-mile, 1-mile, or 1,000-meter zone” of 

(insert name of topographic feature). Shunt all drill cuttings and drilling fluids to the 

seafloor through a downpipe that terminates an appropriate distance, but no more than 

10 m (33 ft), from the bottom.

16.02 Shunting Some Wells (plans) Some of the proposed activities are within the “4-mile, 3-mile, 1-mile, or 1,000-meter zone” 

of (insert name of topographic feature). For (insert name of wells to be shunted”, shunt all 

drill cuttings and drilling fluids to the seafloor through a downpipe that terminates an 

appropriate distance, but no more than 10 m (33 ft), from the bottom.

16.03 No Activity Zone (right-of-way 

pipeline applications)

BOEM’s analysis indicates that the “no activity zone(s)” of the biologically sensitive 

feature(s) shown on the enclosed map(s) in the application may be located within the 

scope of the anchor array of the pipeline lay barge. Anchors, anchor chains, and wire 

ropes associated with the proposed pipeline construction activities must avoid this/these 

“no activity zone(s)” by a distance of at least 500 ft (152 m). Include lay barge anchor 

positions plats, at a scale of 1 in = 1,000 ft with DGPS accuracy, with the pipeline 

construction report required by 30 CFR § 250.1008(b), which depict the “as-placed” 

location of all anchors, anchor chains, and wire ropes on the seafloor, and which 

demonstrate that the “no activity zone(s)” was/were not physically impacted by the 

construction activities. This mitigation may be applied by BSEE at the post-approval 

stage.

16.04 No Activity Zone (plans) Bottom-disturbing activities associated with the activities proposed in the plan must avoid 

the “no activity zone” of the biologically sensitive feature shown on the enclosed map in 

the application by a distance of at least 500 ft (152 m). Submit to BSEE’s Office of Field 

Operations, at the same time the End of Operations report (Form BSEE-0125) is 

submitted to the appropriate BSEE, Gulf of Mexico OCS Region, District Office, an as-built 

map at a scale of 1 in = 1,000 ft with DGPS accuracy, showing the location of any seafloor 

disturbance (e.g., jack-up rig placement, rig anchors, construction barge anchors, etc.) to 

demonstrate that the “no activity zone(s)” was not physically impacted. This mitigation 

may be applied by BSEE at the post-approval stage.

16.05 No Activity Zone (structure 

removal)

Bottom-disturbing activities associated with the activities proposed in the application must 

avoid the “no activity zone” of the biologically sensitive feature shown on the enclosed 

map in the application by a distance of at least 500 ft (152 m). Include in the post-removal 
Commonly Applied Mitigating Measures

B-29

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

report an as-built plat, at a scale of 1 in = 1,000 ft with DGPS accuracy, depicting the “asplaced” location of all anchors, anchor chains, and wire ropes on the seafloor deployed 

during the structure-removal activities to show that the “no activity zone” was not 

physically impacted. This mitigation may be applied by BSEE at the post-approval stage.

Non-Plan and Pipeline Mitigations

17.02 Fish (structure removals using 

explosives)

Under the Magnuson-Stevens Fisheries Conservation and Management Act, 50 CFR § 

600.725 prohibits the use of explosives to take reef fish in the Exclusive Economic Zone. 

Consequently, those involved in explosive structure removals must not take such stunned 

or killed fish on board their vessels. Should this happen, they could be charged by the 

National Marine Fisheries Service (NMFS) with violation of the Act.

17.04 Site-Clearance Trawling 

Reporting

If trawling is used to comply with the site-clearance verification requirements under 

30 CFR §§ 250.1740-1743, which mandates that turtle excluder devices (TED) be 

removed from the trawl nets to facilitate the collection of seabed debris, the applicant must 

abide by maximum trawl times of 30 minutes, allowing for the removal of any captured sea 

turtles. If, during trawling activities, the applicant captures a sea turtle in the nets, the 

applicant must (1) contact BSEE’s Environmental Enforcement Branch and NMFS’ 

Southeast Regional Office immediately, (2) resuscitate and release any captured sea 

turtles as per NMFS’ guidelines found online at http://www.sefsc.noaa.gov/turtles/

TM_NMFS_SEFSC_580_2010.pdf (refer to page 3-6, Plate 3-1), and (3) photograph the 

turtle and complete a sea turtle stranding form for each sea turtle caught in the nets. The 

form can be found at http://www.sefsc.noaa.gov/species/turtles/strandings.htm and 

submitted to NMFS and BSEE.

Conservation Information Document Mitigations

18 Self-Burial Approval BOEM hereby concurs with the determination that the subject pipeline will be installed in 

an area that is prone to self-burial. However, in the future, should it be determined that the 

pipeline(s) constitute(s) a hazard to navigation or commercial fishing operations or unduly 

interferes(s) with other uses of the OCS, the applicant will be required to bury it (them).

18.01 Conservation Information 

Document – Condition of 

Approval

Within 15 days after the proposed well is or wells are completed and logged, submit a 

revision to the plan consisting of the information required for a Conservation Information 

Document in accordance with NTL 2000-N05.

18.02 Conservation Information 

Document – Operations 

Approval

At the applicant’s request, we are approving your development operation coordination 

document (DOCD) prior to the completion of our review of the accompanying 

Conservation Information Document (CID). However, please be advised that, if the CID 

review indicates that any of the proposed activities do not conform to sound conservation, 
B-30 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

engineering, and economic practices as cited in 30 CFR §§ 550.202(a) and 550.1101(a), 

we will, in accordance with 30 CFR § 550.281(4)(b), require such revisions to the DOCD 

as are necessary to make the activities conform to such practices.

ROV Survey Mitigations

19.01 ROV Survey Required –

Exploration Plans (EP)

In accordance with NTL 2008-G06, the applicant must conduct the two ROV surveys 

proposed in the plan. The first survey will be for the first well location approved under this 

plan and which is actually drilled. The post-drilling survey can be conducted at the time 

the applicant is preparing to leave this location. The applicant must submit both survey 

reports within 60 days after the rig leaves the well location. This mitigation may be applied 

by BSEE at the post-approval stage.

19.02 ROV Survey Required – DOCD In accordance with NTL 2008-G06, the applicant must conduct the ROV surveys proposed 

in the plan for the facility location approved under this plan. The applicant must submit the 

pre- and post-installation survey reports within 60 days after the facility installation is 

completed. This mitigation may be applied by BSEE at the post-approval stage.

19.03 ROV Survey Not Required In accordance with NTL 2008-G06, BOEM has determined that the applicant will not need 

to conduct the two ROV surveys proposed in the plan. This mitigation may be applied by 

BSEE at the post-approval stage.

Surveys Mitigations

21.01 Archaeology Assessment Not 

Acceptable

BOEM’s review has determined that the archaeological analysis included in the survey 

report does not meet current BOEM requirements.

21.02 Archaeology Assessment 

Acceptable

BOEM’s review has determined that the archaeological analysis included in the survey 

report meets current BOEM requirements.

21.03 Geophysical Review Acceptable BOEM’s review has determined that the subject survey report complies with the provisions 

of NTL 2008-G05 and, based on available data regarding any manmade hazards that may 

have been present at the time the survey was conducted, contains sufficient information to 

prepare an acceptable shallow hazards analysis for specific drilling or platform sites that 

the applicant may propose in future EPs or DOCDs. However, prior to submitting any 

such EPs or DOCDs, the applicant should update the accompanying anomaly map, if 

appropriate, to indicate the location of any manmade hazards (e.g., pipelines, abandoned 

wells, etc.) that did not exist at the time the survey was performed. Additionally, please be 

reminded that under the guidelines of NTL 2008-G04, the applicant should submit highresolution survey data from the line closest to any proposed well or platform location, with 

one copy of each such EP or DOCD.
Commonly Applied Mitigating Measures

B-31

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

21.04 Geophysical Survey Report Not 

Acceptable

BOEM’s review has also determined the subject survey report does not comply with the 

provisions of NTL 2008-G05.

21.05 3D Survey Waiver Use of three-dimensional (3D) seismic data in lieu of high-resolution survey data as per 

NTL 2008-G05 is acceptable for the requested locations.

Pipeline Section Mitigations and Conditions

22 Concrete Mats The applicant’s request to install protective concrete mats over the pipeline crossings in 

water less than 200 ft (61 m) deep is hereby approved pursuant to 30 CFR § 250.141.

25 Pipeline High-Pressure (PSH) 

Higher Than 15%

The applicant’s request to set the PSH higher than 15 percent above the normal operating 

pressure range is hereby approved pursuant to 30 CFR § 250.142. The pipeline PSH 

shall be set no more than 5 percent above the latest shut-in tubing pressure of the well 

and will not be set above the maximum allowable operating pressure of the pipeline.

26 Denied Self-Burial BOEM cannot concur with the applicant’s determination that the subject pipeline will be 

installed in an area that is prone to self-burial. BOEM will only allow self-burial in areas 

with a soil strength that does not exceed 200 pounds per square foot. Therefore, the 

portions of the pipeline in water depths less than or equal to 200 ft (61 m) shall be buried.

28 Hydrostatic Head to Raise 

Maximum Allowable Operating 

Pressure

The applicant’s request to determine the internal design pressure of the submerged 

portion of the pipeline by considering the effects of the external hydrostatic pressure, in 

lieu of using the standard formula outlined in 30 CFR § 250.1002(a), is hereby approved 

pursuant to 30 CFR § 250.141(a).

National Marine Fisheries Service Mitigations

28.001 Species Protective Measures The applicant must comply with the following species protective measures in all activities 

conducted pursuant to the plan: NTL 2016-BOEM-G01, “Vessel Strike Avoidance and 

Injured/Dead Protected Species Reporting”; NTL 2012-JOINT-G02, “Implementation of 

Seismic Survey Mitigation Measures and Protected Species Observer Program”; and NTL 

2012-BSEE-G01, “Marine Trash and Debris Awareness and Elimination.” These 

measures are designed to promote environmental protection, consistent environmental 

policy, compliance with environmental laws, and safety.

29 Oil Spill Financial Responsibility 

(OSFR) Coverage

BOEM’s review of the application indicates that, per 30 CFR §§ 553.3(1)-(3), the proposed 

right-of-way pipeline is classified as a covered offshore facility (COF) and requires oil-spill 

financial responsibility (OSFR) coverage. At this time, BSEE’s records do not indicate that 

the required OSFR coverage is in place. The applicant is advised that they may begin 

construction of the proposed pipeline immediately. However, in accordance with 30 CFR 

§ 553.15(b), the applicant may not begin operation of the pipeline until they have 
B-32 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

submitted an application showing evidence of OSFR coverage and that demonstration has 

been approved by BSEE.

99 Department of Transportation 

Right-of-Way Pipeline

The applicant shall construct, operate, and maintain the pipeline in accordance with the 

appropriate U.S. Department of Transportation regulations.

110 Spanning Potential There are several fault scarps along with the proposed pipeline route. Include with the 

construction report a listing of the location and length of any pipeline “spanning,” resulting 

from laying the pipeline over these fault scarps. Also include a description of any remedial 

action necessary to minimize “spanning” and prevent pipeline damage. This mitigation 

may be applied by BSEE at the post-approval stage.

Office of Structural Technical Support Mitigations

120.1 Reminder of NTL 2008-G05 If there are pipelines within the immediate proximity of the proposed platform site, 

precautions outlined in NTL 2008-G05, “Shallow Hazards Program,” shall be taken while 

conducting operations.

120.15 Notify National Imagery and 

Mapping

In order to assure publication of onsite activity as it affects marine navigation safety, the 

applicant must notify the National Imagery and Mapping Agency in advance of 

commencement of platform installation.

120.2 Send Report to Office of 

Structural and Technical Support 

(OSTS)

Written notification shall be submitted to the Office of Structural and Technical Support 

(OSTS) and the Pipeline Section within 15 calendar days of completion of the platform 

installation operations, at which time the applicant will be provided with the “Complex 

Identification Number” (CPXID) that has been assigned to this structure. The CPXID 

should be included with other pertinent information (i.e., the right-of-way number, area 

code, block number, platform name, etc.) in all future correspondence related to this 

structure. Should significant problems occur during structure installation operations, 

please inform OSTS immediately. If for any reason the applicant decides not to install this 

structure, they shall submit a written cancellation letter.

120.7 Downhole Well Plugging In accordance with 30 CFR § 250.1710, the applicant must downhole plug and abandon 

all wells on (insert area/block platform name) (except [insert well names]), no later than 

(insert date). However, the applicant will not be required to sever the casings, remove the 

wellhead, or clear the site until the right-of-use expires.

Geological and Geophysical Mitigations (deep-penetration applications)

(no assigned mitigation numbers)

Vessel-Strike Avoidance/Reporting The applicant will follow the guidance provided under NTL 2016-BOEM-G01, “Vessel 

Strike Avoidance and Injured/Dead Protected Species Reporting.” The NTL 2016-
Commonly Applied Mitigating Measures

B-33

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

BOEM-G01 provides guidance on how a seismic operator should implement monitoring 

programs to minimize the risk of vessel strikes to protected species and should report 

observations of injured or dead protected species. In lieu of a formal observer program, 

this NTL provides specific guidelines that should be followed to identify and avoid injury to 

marine mammals and sea turtles.

Seismic Survey Operation, Monitoring, and 

Reporting Guidelines

The applicant will follow the guidance provided under NTL 2012-JOINT-G02, 

“Implementation of Seismic Survey Mitigation Measures and Protected Species Observer 

Program.” Additionally, the applicant will comply with the guidance under this NTL when 

operating in all water depths (not just in water depths >200 m [656 ft] or in the Eastern 

Planning Area), and the NTL’s “shut-down conditions” will be applied towards manatees.

Pre-Activity Sound-Source and Array 

Calibration Verification

Prior to conducting survey activities, the applicant will verify in writing that the proposed 

airgun arrays to be used are of the lowest sound intensity level that still achieves the 

survey goals. The written verification must include confirmation that the airgun array has 

been calibrated/tuned to maximize subsurface illumination and minimize, to the extent 

practicable, horizontal propagation of noise.

Mandatory Separation Buffer between Survey 

Operations

The applicant will be required to maintain, to the extent it can practicably and safely do so, 

a minimum separation distance of 30 km (19 mi) from any other vessels concurrently 

conducting deep-penetration seismic surveys and 40 km (29 mi) when operating within an 

Area of Concern. To assist in implementation of this measure, BOEM will provide the 

applicant with contact information for all deep-penetration seismic applicants concurrently 

permitted/authorized to operate within or near the proposed survey area.

Supplemental Reporting Requirements In addition to the reporting requirements under NTL 2012-JOINT-G02, the applicant is 

required to submit bi-weekly reports containing the information listed below. The reporting 

periods end on the 1st and 15th of each month. These bi-weekly reports are required for 

the total duration of the permit. When applicable, the reports must be submitted with 

survey navigation data for the 2-week reporting period. BOEM has a suggested format for 

the written report. If BOEM’s suggested written format is not used, the following 

information must be submitted along with the navigation data: (1) the dates, locations, and 

duration of any deep-penetration seismic operations conducted during the reporting period 

(the navigation data provides this information); (2) any circumstances that caused the total 

energy output of the airgun source array to exceed that set forth in the permit application; 

(3) confirmation that the permittee maintained, to the extent they could practicably and 

safely do so, the minimum separation distance (If applicable, submit a written explanation 

of why the minimum separation distance was not maintained.); and (4) confirmation that 

the permittee complied with the other terms of Section V of the Settlement Agreement.
B-34 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

Military Warning Area Coordination BOEM’s review indicates that the routes to be taken by boats in support of the applicant’s 

activities traversed Military Warning Areas W-92, W-147AB, and W-602. The applicant 

shall contact the appropriate individual military command headquarters concerning the 

control of electromagnetic emissions and use of boats in each of the areas before 

commencing the operations.

Marine Trash and Debris Awareness and 

Elimination

The applicant will follow the guidance provided under NTL 2012-BSEE-G01, “Marine 

Trash and Debris Awareness and Elimination.” The NTL 2012-BSEE-G01 provides 

information on reducing, if not eliminating, trash intentionally jettisoned into the Gulf of 

Mexico. The programs described in the NTL to assist in the reduction of marine trash and 

debris are the marine trash and debris placards, marine trash and debris awareness 

training, and the marine trash and debris awareness training and certification process.

Geological and Geophysical Mitigation

Natural Resource Defense Council Area of Concern (equal to or greater than 20-m [66-ft] water depth)

(no assigned mitigation numbers)

Seismic Survey Restriction Period BOEM’s review indicates that the proposed survey area falls within a portion of an unusual 

mortality event area declared/established by the National Marine Fisheries Service for 

cetaceans (whales and dolphins). The applicant shall adhere to a restriction period 

between March 1 and April 30 (primary bottlenose dolphin calving season) for deep 

penetration seismic surveys on the Federal OCS in coastal waters out to the 20-m (66-ft) 

isobath in the northern Gulf of Mexico to avoid potential impacts to dolphins in regards to 

behavioral disruptions to mother/calf bonding or masking of important acoustic cues. No 

airgun use, including the use of mitigation guns, is permitted during the restriction period.

Geological and Geophysical Mitigation

Natural Resource Defense Council Area of Concern (equal to or greater than 100-m [328-ft] water depth)

(no assigned mitigation numbers)

Required Passive Acoustic Monitoring (PAM) BOEM requires that the applicant use passive acoustic monitoring (PAM) in water depths 

of 100 m (328 ft) or greater at times of reduced visibility (darkness, rain, fog, etc.) as part 

of their protected species observer program. The PAM will be monitored at all times of 

reduced visibility. Applicants will be required to provide BSEE with a description of the 

passive acoustic system, the software used, and the monitoring plan prior to its use. 

Additionally, after survey completion, the applicant will provide an assessment of the 

usefulness, effectiveness, and problems encountered with the use of PAM for marine 

mammal detection to BSEE for review.
Commonly Applied Mitigating Measures

B-35

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

Mitigation for High-Resolution Surveys

Vessel-Strike Avoidance/Reporting The applicant will follow the guidance provided under NTL 2016-BOEM-G01, “Vessel 

Strike Avoidance and Injured/Dead Protected Species Reporting.” The NTL 2016-

BOEM-G01 provides guidance on how a seismic operator should implement monitoring 

programs to minimize the risk of vessel strikes to protected species and should report 

observations of injured or dead protected species. In lieu of a formal observer program, 

this NTL provides specific guidelines that should be followed to identify and avoid injury to 

marine mammals and sea turtles.

Marine Trash and Debris Awareness and 

Elimination

The applicant will follow the guidance provided under NTL 2012-BSEE-G01, “Marine 

Trash and Debris Awareness and Elimination.” The NTL 2012-BSEE-G01 provides 

information on reducing, if not eliminating, trash intentionally jettisoned into the Gulf of 

Mexico. The programs described in the NTL to assist in the reduction of marine trash and 

debris are the marine trash and debris placards, marine trash and debris awareness 

training, and the marine trash and debris awareness training and certification process.

Geological and Geophysical Non-Recurring Mitigations

Benthic Communities Review of BOEM’s 3D seismic database of water bottom anomalies identified both 

confirmed deepwater benthic communities and features that could potentially support 

communities within the area of the proposed activities. Based on BOEM’s review of 

exploration activities proposed in the applicant’s application, the following non-recurring 

mitigations are applied to the area encompassed by the plan:

• BOEM’s 3D seismic database of water bottom anomalies and confirmed 

communities shall be used to identify features for the purpose of applying this 

mitigation.

• The following nine water bottom anomaly categories will be considered as 

supporting or potentially supporting deepwater benthic communities, unless 

proved otherwise through high- resolution surveys: anom_conf_coral; 

anom_conf_mvol; anom_conf_orgs; anom_poss_oil_pos; wb_anom_lith; 

wb_anom_mvol; wb_anom_neg; wb_anom_pock; and wb_anom_pos.

• These shape files may be downloaded from http://www.boem.gov/Oil-andGas-Energy-Program/Mapping-and-Data/Map-Gallery/Seismic-Water-BottomAnomalies-Map-Gallery.aspx. 

• Features shall be either avoided or surveyed to confirm the presence or 

absence of deepwater benthic communities.

• Per NTL 2009-G40, “Deepwater Benthic Communities,” a minimum separation 
B-36 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

of 250 ft (76 m) must be maintained between documented communities or 

features that could potentially support high-density deepwater benthic 

communities and bottom-disturbing activities (e.g., sensors deployed on the 

seafloor).

− Therefore, a minimum distance of separation for planned sensor 

deployment sites from any feature or community documented in BOEM’s 

water-bottom anomaly database must be at least 250 ft (76 m). 

− If at any time it is determined that a node has landed within 250 ft (76 m) 

of any feature or community documented in BOEM’s water-bottom 

anomaly database, an ROV must be used to document the seafloor 

surrounding the landing location. The seafloor beneath the node and 

arms must be surveyed visually with an ROV for damages. All images 

collected during this survey, showing the area within the footprint of the 

node, must be returned to BOEM’s Gulf of Mexico OCS Region, Biological 

Sciences Unit for evaluation.

• As required by NTL 2009-G40, for bottom-disturbing activities occurring within 

500 ft (152 m) of a high-density deepwater benthic community, the operator 

must provide BOEM with an as-placed plat showing the actual location of the 

disturbance on the seafloor, in relation to documented anomalies and 

communities. This requirement will apply to sensors placed within 500 ft 

(152 m) of a documented anomaly or community, as shown in BOEM’s 3D 

seismic database.

For sensor deployments requiring as-placed plats, prepare at a scale of 1 in = 1,000 ft and 

submit to BOEM’s Regional Supervisor, Office of Resource Evaluation, Data Acquisition 

and Special Projects Unit.

Tethered Ocean Bottom Node Surveys Acoustic buoy releases, tethered acoustic pingers, and nodal tethering lines pose an 

entanglement risk to sea turtles and other marine life. Implementing the following 

measures act to reduce the risk of entanglement and ensure proper reporting of 

entanglement situations. Reasonable measures are available to applicants using this 

deployment technique to reduce the risk of entanglement. These measures include the 

following: (1) shortening the acoustic buoy line and tethered acoustic pinger line to the 

shortest length practical; and (2) replacing tether rope lines equal to or greater than 1⁄4-in 

diameter with a thicker, more rigid tether line, modifying the line by tying knots in the line to 

increase the diameter and rigidness in order to minimize the risk of entanglement. 

Additional measures include ensuring that a Protected Species Observer (PSO) is 
Commonly Applied Mitigating Measures

B-37

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

onboard each vessel during tethered node retrieval operations. The PSOs will document 

any entanglement of marine species in the nodal gear, specifically noting the location 

where entanglement occurred (e.g., pinger tether, acoustic buoy line, etc.). If a marine 

protected species becomes entangled, specifically a sea turtle, the PSO will immediately 

begin resuscitation procedures as described in the National Oceanic and Atmospheric 

Administration’s guidelines that can be found at http://www.st.nmfs.noaa.gov/Assets/

Observer-Program/pdf/Shrimp_Reef_fish_Manual_9_22_10.pdf. The PSO must also 

contact the sea turtle stranding network’s State coordinator to report the incident, condition 

of the turtle, and request additional instructions to reduce risk of injury or mortality, 

including rehabilitation and salvage techniques.

Topographic Features The applicant must adhere to the provisions of the topographic features lease stipulation 

and the policy described in NTL 2009-G39, “Biologically-Sensitive Underwater Features 

and Areas,” which restricts any bottom-disturbing activities within 152 m (500 ft) of the 

designated “No Activity Zone” of a topographic feature, as well as all applicable 

requirements described in the NTL.

Potential Archaeological Resource Protection BOEM’s review of the application indicates that numerous targets identified by existing 

remote-sensing data are located in the project area where the ocean bottom cables 

(OBCs) are proposed to be deployed. Therefore, in order to demonstrate compliance with 

30 CFR § 551.6(a)(5), the applicant will either (1) ensure that all seafloor-disturbing 

actions required for the OBC deployment avoid the features by a distance greater than 

that listed in the tables or (2) conduct an underwater archaeological investigation prior to 

cable deployment to determine whether the feature represents an archaeological 

resource. If the applicant chooses to avoid the feature, they will be required to submit a 

plat, at a scale of 1 in = 1000 ft with DGPS accuracy, with their final report as required by 

30 CFR § 551.8(c)(2), which demonstrates the feature was not physically impacted by the 

OBC deployment and retrieval or by any other associated bottom disturbances. If the 

applicant chooses to conduct an underwater archaeological investigation, they will be 

required to comply with the investigation methodology and reporting guidelines found on 

BOEM’s website at http://www.boem.gov/gom-archaeology/. 

This is only a partial list of potential archaeological sites within the project area, based on 

existing remote-sensing data. There are significant portions of the project area within the 

OCS that have received either limited or no previous archaeological survey, and these 

areas are likely to contain additional archaeological materials that may be impacted by the 

proposed operations. If the applicant discovers additional manmade debris that appears 
B-38 Gulf of Mexico Multisale EIS

Table B-1. Commonly Applied or “Standard” Mitigating Measures (continued).

Mitigation 

Number Mitigating Measure Title Description of Mitigation

to indicate the presence of a shipwreck (e.g., a sonar image or visual confirmation of an 

iron, steel, or wooden hull; wooden timbers; anchors; concentrations of manmade objects 

such as bottles or ceramics; and piles of ballast rock) within or adjacent to the proposed 

action area during the proposed survey operations, the applicant will be required to 

immediately halt operations, take steps to ensure that the site is not disturbed in any way, 

and contact BOEM’s Regional Supervisor, Office of Environment within 48 hours of its 

discovery. The applicant must cease all operations within 1,000 ft (305 m) of the site until 

BOEM’s Regional Director instructs the applicant on what steps must be taken to assess 

the site’s potential historic significance and what steps the applicant must take to protect it. 

If an OBC becomes snagged on any submerged object, divers are required to un-snag 

and retrieve the OBC, and the applicant must submit a report detailing each instance of 

this activity. This report should include the coordinates of the snag (to DGPS accuracy), 

the diver’s description of the submerged object creating the snag, any damage that may 

have resulted from the OBC placement or retrieval operations, and any photographic or 

video imagery that is collected. The applicant must submit a report of any data collected 

as a result of these investigations.
APPENDIX C 

 

COOPERATING AGENCY MEMORANDUM OF AGREEMENT

Cooperating Agency Memorandum of Agreement C-3

C COOPERATING AGENCY MEMORANDUM OF AGREEMENT
C-4 Gulf of Mexico Multisale EIS
Cooperating Agency Memorandum of Agreement C-5
C-6 Gulf of Mexico Multisale EIS
APPENDIX D 

 

PROPOSED LEASE MITIGATING MEASURES (STIPULATIONS) 

Proposed Lease Mitigating Measures (Stipulations) D-3 

D PROPOSED LEASE MITIGATING MEASURES (STIPULATIONS)

The potential lease stipulations and mitigating measures included for analysis in this 

Multisale EIS were developed as a result of numerous scoping efforts for the continuing OCS 

Program in the Gulf of Mexico. The Topographic Features and Live Bottom (Pinnacle Trend) 

Stipulations have been applied as programmatic mitigation in the 2017-2022 Five-Year Program EIS 

(USDOI, BOEM, 2016B) and therefore, would apply to all leases issued under the 2017-2022 Oil 

and Gas Program in designated lease blocks. The other 8 lease stipulations described below would 

be considered for each proposed lease sale, as applicable. These measures will be considered for 

adoption by the Assistant Secretary for Land and Minerals Management (ASLM), under authority 

delegated by the Secretary of the Interior. The analysis of any stipulations for any particular 

alternative does not ensure that the ASLM will make a decision to apply the stipulations to leases 

that may result from any proposed lease sale nor does it preclude minor modifications in wording 

during subsequent steps in the prelease process if comments indicate changes are necessary or if 

conditions change.

Any stipulations or mitigation requirements to be included in a lease sale will be described in 

the Record of Decision for that lease sale. Mitigating measures in the form of lease stipulations are 

added to the lease terms and are therefore enforceable as part of the lease. In addition, each 

exploration and development plan, as well as any pipeline applications that result from a lease sale, 

will undergo a NEPA review, and additional project-specific mitigations applied as conditions of plan 

approval at the postlease stage. The BSEE has the authority to monitor and enforce these 

conditions, and under 30 CFR part 250 Subpart N, may seek remedies and penalties from any 

operator that fails to comply with those conditions, stipulations, and mitigating measures.

D.1 TOPOGRAPHIC FEATURES STIPULATION

The topographic features located in the WPA and CPA provide habitat for coral-reefcommunity organisms (Chapter 4.6.1). There are currently no identified topographic features 

protected under this stipulation in the EPA. Oil- and gas-related activities resulting from a proposed 

action could have a severe, even lethal, impact on or near these communities if the Topographic 

Features Stipulation was not adopted and such activities were not otherwise mitigated. The DOI has 

recognized this problem for some years, and since 1973 stipulations have been made a part of 

leases on or near these biotic communities; impacts from nearby oil- and gas-related activities were 

mitigated to the greatest extent possible. This stipulation does not prevent the recovery of oil and 

gas resources but would serve to protect valuable and sensitive biological resources.

The Topographic Features Stipulation was formulated based on consultation with various 

Federal agencies and comments solicited from the States, industry, environmental organizations,

and academic representatives. The stipulation is based on years of scientific information collected 

since the inception of the stipulation. This information includes various Bureau of Land 

Management/MMS (BOEM)-funded studies of topographic highs in the GOM; numerous stipulationimposed, industry-funded monitoring reports; and the National Research Council’s (NRC) report 
D-4 Gulf of Mexico Multisale EIS

entitled Drilling Discharges in the Marine Environment (1983). The blocks affected by the 

Topographic Features Stipulation are shown in Figure 2-4. 

The requirements in the stipulation are based on the following facts:

(1) Shunting of the drilling effluent to the nepheloid layer confines the effluent to a 

level deeper than that of the living components of a high-relief topographic 

feature. Shunting is therefore an effective measure for protecting the biota of 

high-relief topographic features (Bright and Rezak, 1978; Rezak and Bright, 

1981; NRC, 1983).

(2) The biological impact on the benthos from the deposition of nonshunted 

discharge is mostly limited to within 1,000 m (3,281 ft) of the discharge (NRC, 

1983).

(3) The biota of topographic features can be categorized into depth-related zones 

defined by degree of reef-building activity (Rezak and Bright, 1981; Rezak et al., 

1983 and 1985).

The stipulation establishes No Activity Zones at the topographic features. A zone is defined 

by the 85-m (279-ft) bathymetric contour (isobath) because, generally, the biota shallower than 85 m 

(279 ft) are more typical of the Caribbean reef biota, while the biota deeper than 85 m (279 ft) are 

similar to soft bottom organisms found throughout the GOM. Where a bank is in water depths less 

than 85 m (279 ft), the deepest “closing” isobath defines the No Activity Zone for that topographic 

feature. Within the No Activity Zones, no operations, anchoring, or structures are allowed. Outside 

the No Activity Zones, additional restrictive zones are established where oil and gas operations 

could occur, but where drilling discharges would be shunted.

The stipulation requires that all effluents within the area shown as the “1,000-Meter Zone” on 

the Topographic Features Stipulation Map (found on BOEM’s website at http://www.gomr.mms.gov/

homepg/lsesale/topo_features_package.pdf) be shunted to within 10 m (33 ft) of the seafloor. Banks 

containing the more sensitive and productive algal-sponge zone require a shunt zone extending 

1 nmi (1.2 mi; 1.9 km) and an additional 3-nmi (3.5-mi; 5.6-km) shunt zone for development only.

Exceptions to the general stipulation are made for the Flower Garden Banks and the lowrelief banks. Because the East and West features of the Flower Garden Banks have received 

National Marine Sanctuary status, they are protected to a greater degree than the other banks. The 

added provisions at the Flower Garden Banks National Marine Sanctuary (i.e., the boundary as of 

the publication of this Multisale EIS) require that (a) the No Activity Zone be based on the 100-m 

(328-ft) isobath instead of the 85-m (279-ft) isobath and be defined by the “1/4 1/4 1/4” system (a 

method of defining a specific portion of a block) rather than the actual isobath and (b) there be a 

4-Mile Zone instead of a 1-Mile Zone in which shunting is required. Although Stetson Bank (a highrelief feature) was made part of the Flower Garden Banks National Marine Sanctuary in 1996, it has 

not as yet received added protection that would differ from current stipulation requirements.
Proposed Lease Mitigating Measures (Stipulations) D-5 

Low-relief banks have only a No Activity Zone. A shunting requirement would be 

counterproductive because it would put the potentially toxic drilling muds in the same water depth 

range as the features associated biota that are being protected. Also, the turbidity potentially 

caused by the release of drilling effluents in the upper part of the water column would not affect the 

biota on low-relief features as they appear to be adapted to high turbidity. Claypile Bank, which is a 

low-relief bank that exhibits the Millepora-sponge community, has been given the higher priority 

protection of a 1,000-Meter Zone where monitoring is required.

The stipulation reads as follows:

Topographic Features Stipulation

(a) No activity including placement of structures, drilling rigs, pipelines, or anchoring 

will be allowed within the listed isobath (“No Activity Zone”) of the leases on 

banks as listed below.

(b) Operations within the “1,000-Meter Zone” shall be restricted by shunting all drill 

cuttings and drilling fluids to the bottom through a structurally sound downpipe 

that terminates at an appropriate distance, but no more than 10 m, from the 

bottom.

(c) Operations within a “1-Mile Zone” must be restricted by shunting all drill cuttings 

and drilling fluids to the bottom through a structurally sound downpipe that 

terminates at an appropriate distance, but no more than 10 m, from the bottom. 

(Where there is a “1-Mile Zone” designated, the “1,000-Meter Zone” in paragraph 

(b) is not designated.) This restriction on operations also applies to areas 

surrounding the Flower Garden Banks National Marine Sanctuary (i.e., the 

boundary as of the publication of this Multisale EIS), namely the “4-Mile Zone” 

surrounding the East Flower Garden Bank and the West Flower Garden Bank.

(d) Operations within a “3-Mile Zone” must be restricted by shunting all drill cuttings 

and drilling fluids from development operations to the bottom through a 

structurally sound downpipe that terminates at an appropriate distance, but no 

more than 10 m, from the bottom. If more than two exploration wells that are for 

purposes other than development operations are to be drilled from the same 

surface location, all drill cuttings and drilling fluids must be restricted by shunting 

to the bottom through a structurally sound downpipe that terminates at an 

appropriate distance, but no more than 10 meters, from the bottom.

The Topographic Features Stipulation, together with the appropriate Topographic Features 

Stipulation Map, may be included in leases issued as a result of a lease sale on blocks within the 

areas so indicated in the Western and Central Gulf of Mexico Topographic Features Stipulation Map 

Package, which is available from the BOEM’s Gulf of Mexico OCS Region’s Public Information 

Office at 1-800-200-GULF and on BOEM’s website at http://www.boem.gov/Topo-Stip-Map-
D-6 Gulf of Mexico Multisale EIS

Package/. As referenced in paragraphs (a)-(d) of this stipulation, a Topographic Features Stipulation 

Map will be attached to each lease instrument subject to this stipulation.

The banks and corresponding blocks to which this stipulation may be applied in the WPA are 

as follows:

Shelf Edge Banks Low-Relief Banks2 South Texas Banks4

Bank Name Isobath (m) Bank Name Isobath (m) Bank Name Isobath (m)

West Flower 

Garden Bank

(defined by 

1⁄4 1⁄4 1⁄4 system)

100

Mysterious Bank 74, 76, 78, 80, 84 Dream Bank 78, 82

Coffee Lump Various Southern Bank 80

East Flower 

Garden Bank

(defined by 

1⁄4 1⁄4 1⁄4 system)

100

Blackfish Ridge 70 Hospital Bank 70

Big Dunn Bar 65 North Hospital 

Bank 68

MacNeil Bank 82 Small Dunn Bar 65 Aransas Bank 70

29 Fathom Bank 64 32 Fathom Bank 52 South Baker 

Bank 70

Rankin Bank 85 Claypile Bank3 50 Baker Bank 70

Bright Bank1 85

Stetson Bank 52

Appelbaum 

Bank 85

1 CPA bank with a portion of its “3-Mile Zone” in the WPA.

2 Low-Relief Banks—only paragraph (a) of the stipulation applies. 3 Claypile Bank—only paragraphs (a) and (b) of the stipulation apply. In paragraph (b), monitoring of the 

effluent to determine the impact on the biota of Claypile Bank shall be required rather than shunting. 4 South Texas Banks—only paragraphs (a) and (b) of the stipulation apply.
Proposed Lease Mitigating Measures (Stipulations) D-7 

The banks and corresponding blocks to which this stipulation may be applied in the CPA are 

as follows:

Bank Name Isobath (m) Bank Name Isobath (m)

McGrail Bank 85 Jakkula Bank 85

Bouma Bank 85 Sweet Bank1 85

Rezak Bank 85 Bright Bank3 85

Sidner Bank 85 Geyer Bank 85

Sackett Bank2 85 Elvers Bank 85

Ewing Bank 85 Alderdice Bank 80

Diaphus Bank2 85 Fishnet Bank2 76

Parker Bank 85 Sonnier Bank 55

1 Only paragraph (a) of the stipulation applies.

2 Only paragraphs (a) and (b) of the stipulation apply.

3 CPA bank with a portion of its “3-Mile Zone” in the WPA.

Effectiveness of the Lease Stipulation

The purpose of the stipulation is to protect the biota of the topographic features from adverse 

impacts due to routine oil and gas activities. Such impacts include physical damage from anchoring 

and rig emplacement and potential toxic and smothering impacts from muds and cuttings 

discharges. The Topographic Features Stipulation has been used on leases since 1973, and this 

experience shows that the stipulation effectively prevents damage to the biota of these banks from 

routine oil and gas activities. Anchoring related to oil- and gas-related activities on the sensitive 

portions of the topographic features has been prevented. Monitoring studies have demonstrated 

that the shunting requirements of the stipulations are effective in preventing the muds and cuttings 

from impacting the biota of the banks. The stipulation, if adopted for a proposed action, will continue 

to protect the biota of the banks, specifically as discussed below.

Mechanical damage resulting from oil- and gas-related operations is probably the single 

most serious impact to benthic habitat. Complying with the No Activity Zone designation of the 

Topographic Features Stipulation should completely eliminate this threat to the sensitive biota of 

WPA and CPA topographic features from activities resulting from a proposed action. The sensitive 

biota within the zones provided for in the Topographic Features Stipulation will thus be protected.

Several other impact-producing factors may threaten communities associated with 

topographic features. Vessel anchoring and structure emplacement result in physical disturbance of 

benthic habitat and are the most likely activities to cause permanent or long-lasting impacts to 

sensitive offshore habitats. Recovery from damage caused by such activities may take 10 or more 

years (depending on the maturity of the impacted community). Operational discharges (drilling muds 
D-8 Gulf of Mexico Multisale EIS

and cuttings, produced waters) may impact the biota of the banks due to turbidity and sedimentation, 

resulting in death to benthic organisms in large areas. Recovery from such damage may take 10 or 

more years (depending on the maturity of the impacted community). A loss of well control without 

the release of substantial amounts of oil could cause similar damage to benthic biota by 

resuspending sediments, causing turbidity and sedimentation, which could ultimately have a lethal 

impact on benthic organisms. Recovery from such damage may take up to 10 years (depending on 

the maturity of the impacted community). Oil spills will cause damage to benthic organisms if the oil 

contacts the organisms; such contact is unlikely except from spills related to blowouts. There have 

been few blowouts in the GOM. Structure removal using explosives can result in water turbidity, 

redeposition of sediments, and explosive shock-wave impacts. Recovery from such damage could 

take more than 10 years (depending on the maturity of the impacted community). The above 

activities, especially bottom-disturbing activities, have the greatest potential to severely impact the 

biota of topographic features. A proposed action, without the Topographic Features Stipulation or 

comparable mitigation, is expected to have a severe impact on the sensitive offshore habitats of the 

topographic features.

The stipulation provides different levels of protection for banks in different categories as 

defined by Rezak and Bright (1981). The categories and their definitions are as follows:

Category A: zone of major reef-building activity; maximum environmental 

protection recommended;

Category B: zone of minor reef-building activity; environmental protection strongly 

recommended;

Category C: zone of negligible reef-building activity, but crustose algae present; 

environmental protection recommended; and

Category D: zone of no reef-building and insignificant populations of crustose 

algae; additional protection not necessary.

The stipulation requires that all effluents within 1,000 m (3,281 ft) of Sackett, Fishnet, and 

Diaphus Banks, categorized by Rezak and Bright (1981) as Category C banks, be shunted into the 

nepheloid layer; the potentially harmful materials in drilling muds will be trapped in the bottom 

boundary layer and will not move up the banks where the biota of concern are located. Surface 

drilling discharge at distances greater than 1,000 m (3,281 ft) from the bank is not expected to 

impact the biota.

The stipulation protects the remaining banks (Category A and B banks) with even greater 

restrictions. Surface discharge will not be allowed within 1 nmi (1.2 mi; 1.9 km) of these more 

sensitive banks. Surface discharges outside of 1 nmi (1.2 mi; 1.9 km) are not expected to impact the 

biota of the banks, as adverse impacts from surface discharge are limited to 1,000 m (3,281 ft). 

However, it is possible that, when multiple wells are drilled from a single platform (surface location), 

typical during development operations, extremely small amounts of muds discharged more than 
Proposed Lease Mitigating Measures (Stipulations) D-9 

1 nmi (1.2 mi; 1.9 km) from the bank may reach the bank. In order to eliminate the possible 

cumulative impact of muds discharged during development drilling, the stipulation imposes a 3-Mile 

Zone within which shunting of development well effluent is required.

The stipulation would prevent damage to the biota of the banks from routine oil- and 

gas-related activities resulting from a proposed action, while allowing the development of nearby oil 

and gas resources. The stipulation will not protect the banks from the adverse impacts of an 

accident such as a large blowout on a nearby oil or gas operation.

D.2 LIVE BOTTOM (PINNACLE TREND) STIPULATION

The Live Bottom (Pinnacle Trend) Stipulation is intended to protect live bottoms and the 

associated hard bottom communities from damage and, at the same time, provide for recovery of 

potential oil and gas resources. This stipulation has been routinely applied to appropriate CPA oil 

and gas lease sales since 1974, to protect known pinnacle trend features.

The Live Bottom (Pinnacle Trend) Stipulation covers the pinnacle trend area of the CPA 

(Figure 2-4). A small portion of the northeastern proposed CPA lease sale area is characterized by 

a pinnacle trend, which is classified as a live bottom under the stipulation. The pinnacles are a 

series of topographic irregularities with variable biotal coverage, which provide structural habitat for a 

variety of pelagic fish. The pinnacles trend features in the region could be impacted from physical 

damage of unrestricted OCS oil- and gas-related activities, as noted in Chapter 4.6.2. More detail 

on the Live Bottom (Pinnacle Trend) Stipulation and the affected blocks can be found at 

http://www.boem.gov/Biologically-Sensitive-Areas-List/. 

The stipulation reads as follows:

Live Bottom (Pinnacle Trend) Stipulation

For the purpose of this stipulation, “live bottom areas” are defined as seagrass 

communities; or those areas which contain biological assemblages consisting of 

such sessile invertebrates as sea fans, sea whips, hydroids, anemones, ascidians, 

sponges, bryozoans, or corals living upon and attached to naturally occurring hard or 

rocky formations with rough, broken, or smooth topography; or areas whose lithotope 

favors the accumulation of turtles, fishes, and other fauna.

Prior to any drilling activities or the construction or placement of any structure for 

exploration or development on this lease, including, but not limited to, anchoring, well 

drilling, and pipeline and platform placement, the lessee will submit to the BOEM 

Regional Director (RD) a live bottom survey report containing a bathymetry map 

prepared utilizing remote-sensing data and an interpretation of live bottom areas 

prepared from the data collected. The resultant bathymetry map shall be prepared 

for the purpose of determining the presence or absence of live bottoms which could 
D-10 Gulf of Mexico Multisale EIS

be impacted by the proposed activity. This map shall encompass such an area of 

the seafloor where surface disturbing activities, including anchoring, may occur.

If the BOEM Regional Director determines that live bottoms might be adversely 

impacted by the proposed activity, the RD will require the lessee to undertake any 

measure deemed economically, environmentally, and technically feasible to protect 

the live bottom area. These measures may include, but are not limited to, relocation 

of operations, shunting of fluids and cuttings, and monitoring to assess the impact of 

the activity on the live bottoms.

NOTE: In the past, a similar stipulation known as the Live Bottom (Low-Relief) Stipulation

was applied to appropriate oil and gas lease sales since 1982 to protect known low-relief features. 

All EPA blocks in water depths of 100 m (328 ft) or less and the following CPA blocks have known 

live bottom (low-relief) features and would be subject to the stipulation: Pensacola Blocks 751-754, 

793-798, 837-842, 881-886, 925-930, and 969-975; and Destin Dome Blocks 1-7, 45-51, 89-96, 

133-140, 177-184, 221-228, 265-273, 309-317, 353-361, 397-405, 441-448, 485-491, 529-534, and 

573-576. However, these blocks are located in areas currently under moratorium and are not a part 

of a proposed action for this Multisale EIS. While none of the blocks with known concentrations of 

live bottom low-relief habitat are expected to be offered for lease, several live bottom low-relief areas 

are adjacent to blocks that would be offered for lease under a proposed action and could potentially 

be affected by impacts of routine activities and accidental events. If, however, any low-relief 

features are identified during NEPA reviews of site-specific development plans, then the protective 

measures outlined in NTL 2009-G39 would be applied to prevent impacts. More detail on the Live 

Bottom (Low-Relief) Stipulation and the affected blocks can be found in NTL 2009-G39 and online at 

http://www.boem.gov/Biologically-Sensitive-Areas-List/. 

Effectiveness of the Lease Stipulation

Through detection and avoidance, this stipulation minimizes the likelihood of mechanical 

damage from OCS oil- and gas-related activities associated with rig and anchor emplacement to the 

sessile and pelagic communities associated with the crest and flanks of such features. Since this 

area is subject to heavy natural sedimentation, this stipulation does not include any specific 

measures to protect the live bottoms from the discharge of effluents.

The sessile and pelagic communities associated with the crest and flanks of the live bottom 

features could be adversely impacted by oil- and gas-related activities resulting from a proposed 

action if such activities took place on or near these communities without the Live Bottom Stipulation. 

For many years, this stipulation has been made a part of leases on blocks in the CPA to ensure that 

pinnacle trend areas are mitigated to the greatest extent possible from nearby OCS oil- and gasrelated activities. This stipulation does not prevent the recovery of oil and gas resources; however, it 

does serve to protect valuable and sensitive biological resources.
Proposed Lease Mitigating Measures (Stipulations) D-11

Activities resulting from a proposed action, particularly anchor damage to localized live 

bottom areas, would be expected to cause substantial damage to portions of these areas because 

these activities are potentially destructive to the biological communities and could damage one or 

several individual live bottom areas. The most potentially damaging of these are the impacts 

associated with mechanical damages that may result from anchors. However, the action is judged 

to be infrequent because of the limited operations in the vicinity of live bottoms and the small size of 

many of the features. Minor impact is expected from large oil spills, losses of well control, pipeline 

emplacement, muds and cuttings discharges, and structure removals. A proposed action, without 

the benefit of the Live Bottom Stipulation, could have an adverse impact on these areas, but such 

impact is expected to be localized in nature. Impact from mechanical damage, including anchors, 

could potentially be long term if the physical integrity of the live bottoms themselves became altered.

The pinnacle trend occurs as patchy regions within the general area of the eastern portion of 

the CPA (Ludwick and Walton, 1957; Barry A. Vittor and Associates, Inc., 1985; Brooks and 

Giammona, 1990). The pinnacle trend also extends into the EPA but not in the portion of the EPA 

proposed or available for leasing. The stipulation would require the operators to locate the individual 

pinnacles and associated communities that may be present in the block. Outside of the pinnacle 

trend, live bottom low-relief features can and do occur in isolated locations in shallow waters 

(<984 ft; 300 m) throughout the GOM wherever there is suitable hard substrate and other physical 

conditions (e.g., depth, turbidity, etc.) that allow for epibenthic community development (Rezak et al., 

1990). However, they are primarily known to be present in some locations on the MississippiAlabama Shelf and in many more locations on the West Florida Shelf (Figure 4-17), which is far east 

of the proposed EPA lease sale area. The stipulation requires that a survey be done to encompass 

the potential area of proposed surface disturbance and that a bathymetry map depicting any live 

bottoms in the vicinity be prepared from the survey. BOEM’s Regional Director, through consultation 

with FWS, could then decide if live bottom features would be potentially impacted and, if so, require 

appropriate mitigating measures.

By identifying the live bottom features present at the activity site, the lessee would be 

directed to avoid placement of the drilling rig and anchors on the sensitive areas. Thus, mechanical 

damage to the live bottom features is eliminated when measures required by the stipulation are 

imposed. The rapid dilution of drill cuttings and muds will minimize the potential of significant 

concentration of effluents on live bottom features; therefore, the stipulation does not address effluent 

discharges.

D.3 MILITARY AREAS STIPULATION

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

1977 and reduces potential space-use conflicts, particularly in regards to safety; but, it 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 an accident involving military operations) and requires lessees to 

coordinate their activities with appropriate local military contacts. Figure 2-7 shows the military 
D-12 Gulf of Mexico Multisale EIS

warning areas in the Gulf of Mexico. As referenced in paragraph (a) of the stipulation, a list of the 

appropriate command headquarters will be included with each lease package subject to this 

stipulation.

Military Areas Stipulation

(a) Hold and Save Harmless

Whether compensation for such damage or injury might be due under a theory of 

strict or absolute liability or otherwise, the lessee assumes all risks of damage or 

injury to persons or property, which occur in, on, or above the OCS, to any persons 

or to any property of any person or persons who are agents, employees, or invitees 

of the lessee, its agents, independent contractors, or subcontractors doing business 

with the lessee in connection with any activities being performed by the lessee in, on, 

or above the OCS, if such injury or damage to such person or property occurs by 

reason of the activities of any agency of the United States (U.S.) Government, its 

contractors or subcontractors, or any of its officers, agents or employees, being 

conducted as a part of, or in connection with, the programs and activities of the 

command headquarters listed at the end of this stipulation.

Notwithstanding any limitation of the lessee's liability in Section 14 of the lease, the 

lessee assumes this risk whether such injury or damage is caused in whole or in part 

by any act or omission, regardless of negligence or fault, of the U.S. Government, its 

contractors or subcontractors, or any of its officers, agents, or employees. The 

lessee further agrees to indemnify and save harmless the U.S. Government against 

all claims for loss, damage, or injury sustained by the lessee, or to indemnify and 

save harmless the U.S. Government against all claims for loss, damage, or injury 

sustained by the agents, employees, or invitees of the lessee, its agents, or any 

independent contractors or subcontractors doing business with the lessee in 

connection with the programs and activities of the aforementioned military 

installation, whether the same be caused in whole or in part by the negligence or 

fault of the U.S. Government, its contractors, or subcontractors, or any of its officers, 

agents, or employees and whether such claims might be sustained under a theory of 

strict or absolute liability or otherwise.

(b) Electromagnetic Emissions

The lessee agrees to control its own electromagnetic emissions and those of its 

agents, employees, invitees, independent contractors or subcontractors emanating 

from individual designated defense warning areas in accordance with requirements 

specified by the commander, or his/her designee, of the command headquarters to 

the degree necessary to prevent damage to, or unacceptable interference with, 

Department of Defense flight, testing, or operational activities, conducted within 
Proposed Lease Mitigating Measures (Stipulations) D-13

individual designated warning areas. Necessary monitoring control, and coordination 

with the lessee, its agents, employees, invitees, independent contractors or 

subcontractors, will be affected by the commander of the appropriate onshore 

military installation conducting operations in the particular warning area; provided, 

however, that control of such electromagnetic emissions shall in no instance prohibit 

all manner of electromagnetic communication during any period of time between a 

lessee, its agents, employees, invitees, independent contractors or subcontractors 

and onshore facilities.

(c) Operational

The lessee, when operating or causing to be operated on its behalf, boat, ship, or 

aircraft traffic in the individual designated warning areas, shall enter into an 

agreement with the commander, or his/her designee, of the individual command 

headquarters, upon utilizing an individual designated warning area prior to 

commencing such traffic. Such an agreement will provide for positive control of 

boats, ships, and aircraft operating in the warning areas at all times.

Effectiveness of the Lease Stipulation

The hold harmless section of the military stipulation serves to protect the U.S. Government 

from liability in the event of an accident involving the lessee and military activities. The operations of 

the military and the lessee and its agents will not be affected by this section.

The electromagnetic emissions section of the stipulation requires the lessee and its agents to 

reduce and curtail the use of radio, CB, or other equipment emitting electromagnetic energy within 

some areas. This serves to reduce the impact of oil- and gas-related activity on the communications 

of military missions and reduces the possible impacts of electromagnetic energy transmissions on 

missile testing, tracking, and detonation.

The operational section requires notification to the military of oil- and gas-related activity to 

take place within a military use area. This allows the base commander to plan military missions and 

maneuvers that will avoid the areas where oil- and gas-related activities are taking place or to 

schedule around these activities. Prior notification helps reduce the potential impacts associated 

with vessels and helicopters traveling unannounced through areas where military activities are 

underway.

This stipulation reduces potential impacts, particularly in regards to safety, but it does not 

reduce or eliminate the actual physical presence of oil- and gas-related operations in areas where 

military operations are conducted. The reduction in potential impacts resulting from this stipulation 

makes multiple-use conflicts unlikely. Without the stipulation, some potential conflict is likely. The 

best indicator of the overall effectiveness of the stipulation may be that there has never been an

accident involving a conflict between military operations and oil- and gas-related activities.
D-14 Gulf of Mexico Multisale EIS

D.4 EVACUATION STIPULATION

This stipulation would be a part of any lease in the easternmost portion of the CPA and all 

blocks in the EPA portion of the proposed lease sale area resulting from a proposed action. An 

evacuation stipulation has been applied to all blocks leased in these areas since 2001. The 

Evacuation Stipulation is designed to protect the lives and welfare of offshore oil and gas personnel. 

Oil- and gas-related activities have the potential to occasionally interfere with specific requirements 

and operating parameters for the lessee’s activities in accordance with the military stipulation 

clauses contained herein. If it is determined that the operations will result in interference with 

scheduled military missions in such a manner as to possibly jeopardize the national defense or to 

pose unacceptable risks to life and property, then a temporary suspension of operations and the 

evacuation of personnel may be necessary. The stipulation reads as follows:

Evacuation Stipulation

(a) The lessee, recognizing that oil and gas resource exploration, exploitation, 

development, production, abandonment, and site cleanup operations on the 

leased area of submerged lands may occasionally interfere with tactical military 

operations, hereby recognizes and agrees that the United States reserves and 

has the right to temporarily suspend operations and/or require evacuation on this 

lease in the interest of national security. Such suspensions are considered 

unlikely in this area. Every effort will be made by the appropriate military agency 

to provide as much advance notice as possible of the need to suspend 

operations and/or evacuate. Advance notice of fourteen (14) days shall normally 

be given before requiring a suspension or evacuation, but in no event will the 

notice be less than four (4) days. Temporary suspension of operations may 

include the evacuation of personnel, and appropriate sheltering of personnel not 

evacuated. Appropriate shelter means the protection of all lessee personnel for 

the entire duration of any Department of Defense activity from flying or falling 

objects or substances; it will be implemented by a written order from the BSEE 

Gulf of Mexico Region, Regional Supervisor for District Field Operations 

(RSDFO), after consultation with the appropriate command headquarters or other 

appropriate military agency, or higher authority. The appropriate command 

headquarters, military agency or higher authority will provide information to allow 

the lessee to assess the degree of risk to, and provide sufficient protection for, 

lessee’s personnel and property. Such suspensions or evacuations for national 

security reasons will not normally exceed seventy-two (72) hours; however, any 

such suspension may be extended by order of the RSDFO. During such periods, 

equipment may remain in place, but all production, if any, must cease for the 

duration of the temporary suspension if so directed by the RSDFO. Upon 

cessation of any temporary suspension, the RSDFO will immediately notify the 

lessee such suspension has terminated and operations on the leased area can 

resume.
Proposed Lease Mitigating Measures (Stipulations) D-15

(b) The lessee shall inform the BSEE of the persons/offices to be notified to 

implement the terms of this stipulation.

(c) The lessee is encouraged to establish and maintain early contact and 

coordination with the appropriate command headquarters, in order to avoid or 

minimize the effects of conflicts with potentially hazardous military operations.

(d) The lessee is not entitled to reimbursement for any costs or expenses associated 

with the suspension of operations or activities or the evacuation of property or 

personnel in fulfillment of the military mission in accordance with subsections 

(a) through (c) above.

(e) Notwithstanding subsection (d), the lessee reserves the right to seek 

reimbursement from appropriate parties for the suspension of operations or 

activities or the evacuation of property or personnel associated with conflicting 

commercial operations.

Effectiveness of the Lease Stipulation

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

during any events conducted by the military that could pose a danger to ongoing oil- and gas-related 

operations. It is expected that the invocation of these evacuation requirements will be extremely 

rare.

It is expected that these measures will serve to eliminate dangerous conflicts between 

oil- and gas-related operations and military operations. Continued close coordination between 

BSEE and the military may result in improvements in the wording and implementation of these 

stipulations.

D.5 COORDINATION STIPULATION

This stipulation would be a part of any lease in the easternmost portion of the CPA and all 

blocks leased in the EPA portion of the proposed leased sale area. A coordination stipulation has 

been applied to all blocks leased in these areas since 2001. The Coordination Stipulation is 

designed to increase communication and cooperation between military authorities and offshore oil 

and gas operators. Specific requirements and operating parameters are established for the lessee’s 

activities in accordance with the Military Stipulation clauses. For instance, if it is determined that the 

operations will result in interference with scheduled military missions in such a manner as to possibly 

jeopardize the national defense or to pose unacceptable risks to life and property, then certain 

measures become activated and the oil- and gas-related operations may be curtailed in the interest 

of national defense. The stipulation reads as follows and, as referenced in paragraph (a) of the 

stipulation, a list of military stipulation clauses will be included with each lease package subject to 

this stipulation.
D-16 Gulf of Mexico Multisale EIS

Coordination Stipulation

(a) The placement, location, and planned periods of operation of surface structures 

on this lease during the exploration stage are subject to approval by the BOEM 

Regional Director (RD) after the review of an operator’s EP. Prior to approval of 

the EP, the lessee shall consult with the appropriate command headquarters 

regarding the location, density, and the planned periods of operation of such 

structures, and to maximize exploration while minimizing conflicts with 

Department of Defense activities. When determined necessary by the 

appropriate command headquarters, the lessee will enter into a formal Operating 

Agreement with such command headquarters, that delineates the specific 

requirements and operating parameters for the lessee’s activities in accordance 

with the military stipulation clauses contained herein. If it is determined that the 

final operations will result in interference with scheduled military missions in such 

a manner as to possibly jeopardize the national defense or to pose unacceptable 

risks to life and property, then the BOEM RD may approve the EP with 

conditions, disapprove it, or require modification in accordance with 30 CFR 

part 550. The RD will notify the lessee in writing of the conditions associated 

with plan approval, or the reason(s) for disapproval or required modifications. 

Moreover, if there is a serious threat of harm or damage to life or property, or if it 

is in the interest of national security or defense, pending or approved operations 

may be suspended in accordance with 30 CFR part 250 or 30 CFR part 550. 

Such a suspension will extend the term of a lease by an amount equal to the 

length of the suspension. The BSEE RD will attempt to minimize such 

suspensions within the confine of related military requirements. It is recognized

that the issuance of a lease conveys the right to the lessee as provided in section 

8(b)(4) of the Outer Continental Shelf Lands Act, 43 U.S.C. § 1337(b)(4), to 

engage in exploration, development, and production activities conditioned upon 

other statutory and regulatory requirements.

(b) The lessee is encouraged to establish and maintain early contact and 

coordination with the appropriate command headquarters, in order to avoid or 

minimize the effects of conflicts with potentially hazardous military operations.

(c) If national security interests are likely to be in continuing conflict with an existing 

Operating Agreement, EP, DPP, or DOCD, the BSEE RD, in consultation with 

BOEM, will direct the lessee to modify any existing operating agreement or to 

enter into a new operating agreement to implement measures to avoid or 

minimize the identified potential conflicts, subject to the terms and conditions and 

obligations of the legal requirements of the lease.
Proposed Lease Mitigating Measures (Stipulations) D-17

Effectiveness of the Lease Stipulation

This stipulation would provide for 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.

D.6 BLOCKS SOUTH OF BALDWIN COUNTY, ALABAMA, STIPULATION

This stipulation will be included only on leases on blocks south of and within 15 mi (24 km) of 

Baldwin County, Alabama. The stipulation reads as follows:

Blocks South of Baldwin County, Alabama, Stipulation

(a) In order to minimize visual impacts from development operations on this block, 

you will contact lessees and operators of leases in the vicinity prior to submitting 

a DOCD to determine if existing or planned surface production structures can be 

shared. If feasible, your DOCD should reflect the results of any resulting sharing 

agreement, propose the use of subsea technologies, or propose another 

development scenario that does not involve new surface structures.

(b) If you cannot formulate a feasible development scenario that does not call for 

new surface structure(s), your DOCD should ensure that they are the minimum 

necessary for the proper development of the block and that they will be 

constructed and placed, using orientation, camouflage, or other design 

measures, to limit their visibility from shore.

(c) The BOEM will review and make decisions on your DOCD in accordance with 

applicable Federal regulations and BOEM policies, and in consultation with the 

State of Alabama (Geological Survey/Oil and Gas Board).

Effectiveness of the Lease Stipulation

For several years, the then-Governor of Alabama had indicated opposition to new leasing 

south and within 15 mi (24 km) of Baldwin County but requested that, if the area is offered for lease, 

a lease stipulation to reduce the potential for visual impacts should be applied to all new leases in 

this area. Prior to the decision in 1999 on the Final Notice of Sale for Lease Sale 172, BOEM’s Gulf 

of Mexico OCS Region’s 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 (24-km) area to mitigate potential visual impacts. The stipulation specifies 

requirements for consultation that lessees must follow when developing plans for fixed structures. A 

lessee’s development operations coordination document (DOCD) should reflect the results of any 

resulting sharing agreement, should propose the use of subsea technologies, or should propose 

another development scenario that does not involve new surface structures. If the lessee cannot 

formulate a feasible development scenario that does not call for new surface structure(s), the 

lessee’s DOCD should ensure that the structures are the minimum necessary for the proper 
D-18 Gulf of Mexico Multisale EIS

development of the block and that they will be constructed and placed, using orientation, 

camouflage, or other design measures, in such a manner as to limit their visibility from shore. The 

stipulation has been continually adopted in annual CPA lease sales since and has effectively 

mitigated visual impacts.

D.7 PROTECTED SPECIES STIPULATION

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, National Oceanic and Atmospheric Administration, NMFS and the U.S. Department of 

the Interior, FWS in accordance with Section 7 of the Endangered Species Act, and it is designed to 

minimize or avoid potential adverse impacts to federally protected species.

Protected Species Stipulation

A. The Federal Endangered Species Act (ESA; 16 U.S.C. §§ 1531-1544) and the 

Marine Mammal Protection Act (MMPA; 16 U.S.C. 1361-1423h) are designed to 

protect threatened and endangered species and marine mammals and apply to 

activities on the Outer Continental Shelf (OCS). The Outer Continental Shelf 

Lands Act (OCSLA; at 43 U.S.C. §§ 1331-1356a) provides that the OCS should 

be made available for expeditious and orderly development subject to 

environmental safeguards, in a manner which is consistent with the maintenance 

of competition and other national needs (see 43 U.S.C. § 1332). BOEM and 

BSEE comply with these laws on the OCS.

B. The lessee and its operators must:

(1) collect and remove flotsam resulting from activities related to exploration, 

development, and production of this lease;

(2) post signs in prominent places on all vessels and platforms used as a result 

of activities related to exploration, development, and production of this lease 

detailing the reasons (legal and ecological) why release of debris must be 

eliminated;

(3) observe for marine mammals and sea turtles while on vessels, reduce vessel 

speed to 10 knots or less when assemblages of cetaceans are observed, and 

maintain a distance of 91 meters or greater from whales, and a distance of 

45 meters or greater from small cetaceans and sea turtles;

(4) employ mitigation measures prescribed by BOEM/BSEE or the National 

Marine Fisheries Service (NMFS) for all seismic surveys, including the use of 

an “exclusion zone” based upon the appropriate water depth, ramp-up and 

shutdown procedures, visual monitoring, and reporting;
Proposed Lease Mitigating Measures (Stipulations) D-19

(5) identify important habitats, including designated critical habitat, used by listed 

species (e.g., sea turtle nesting beaches, piping plover critical habitat), in oil 

spill contingency planning and require the strategic placement of spill cleanup 

equipment to be used only by personnel trained in less-intrusive cleanup 

techniques on beaches and bay shores; and

(6) immediately report all sightings and locations of injured or dead protected 

species (e.g., marine mammals and sea turtles) to the appropriate stranding 

network. If oil and gas industry activity is responsible for the injured or dead 

animal (e.g., because of a vessel strike), the responsible parties should 

remain available to assist the stranding network. If the injury or death was 

caused by a collision with the lessee’s vessel, the lessee must notify BSEE 

within 24 hours of the strike in accordance with NTL No. 2016-BOEM-G01 

(Vessel Strike Avoidance and Injured/Dead Protected Species Reporting).

C. BOEM and BSEE issue Notices to Lessees (NTLs) which more fully describe 

measures implemented in support of the above-mentioned implementing statutes 

and regulations, as well as measures identified by the U.S. Fish and Wildlife 

Service and NMFS arising from, among others, conservation recommendations, 

rulemakings pursuant to the MMPA, or consultation. The lessee and its 

operators, personnel, and subcontractors, while undertaking activities authorized 

under this lease, must implement and comply with the specific mitigation 

measures outlined in: NTL No. 2016-BOEM-G01 (Vessel Strike Avoidance and 

lnjured/Dead Protected Species Reporting), NTL No. 2016-BOEM-G02 

(Implementation of Seismic Survey Mitigation Measures and Protected Species 

Observer Program), and NTL No. 2015-BSEE-G03 (Marine Trash and Debris 

Awareness and Elimination). At the lessee’s option, the lessee, its operators, 

personnel and contractors may comply with the most current measures to protect 

species in place at the time an activity is undertaken under this lease, including 

but not limited to new or updated versions of the NTLs identified in this 

paragraph. The lessee and its operators, personnel and subcontractors will be 

required to comply with the mitigation measures, identified in the above 

referenced NTLs, and additional measures in the conditions of approvals for their 

plans or permits.

Effectiveness of the Lease Stipulation

This stipulation was developed in consultation with NMFS and FWS, and is designed to 

minimize or avoid potential adverse impacts to federally protected species. The stipulation 

immediately implements existing mitigations on postlease activities and notifies lessees that 

subsequent approvals for oil and gas activities may include additional mitigations (as conditions of 

approval) when those actions have the potential to impact marine mammals, sea turtles, and other 

federally protected species. Among others, these requirements and conditions provide protection by 

ensuring the animals remain a minimum distance from the operations or the activity.
D-20 Gulf of Mexico Multisale EIS

D.8 UNITED NATIONS CONVENTION ON THE LAW OF THE SEA ROYALTY PAYMENT 

STIPULATION

If the United States becomes a party to the 1982 United Nations Convention on the Law of 

the Sea (UNCLOS) prior to or during the life of a lease issued by the United States on a block or 

portion of a block located beyond its Exclusive Economic Zone as defined in UNCLOS, and subject 

to such conditions that the Senate may impose through its constitutional role of advice and consent, 

then the royalty payment lease provisions will apply to the lease so issued, consistent with Article 82 

of UNCLOS.

Law of the Sea Convention Royalty Payment Stipulation

(A) UNCLOS requires payments annually by coastal states party to the Convention 

with respect to all production at a site after the first five years of production at that 

site. Any such payments will be made by the U.S. Government and not the 

lessee.

(B) For the purpose of this stipulation regarding payments by the lessee to the U.S., 

each lease constitutes a separate site, whether or not a lease is committed to a 

unit.

(C) For the purpose of this stipulation, the first production year begins on the first day 

of commercial production (excluding test production). Once a production year 

begins, it will run for a period of 365 days whether or not the lease produces 

continuously in commercial quantities. Subsequent production years shall begin 

on the anniversary date of first production.

(D) If total lease production during the first five years following first production 

exceeds the total royalty suspension volume(s) provided in the lease terms, or 

through application and approval of relief from royalties, the following provisions 

of this stipulation will not apply. If, after the first five years of production, but prior 

to termination of this lease, production exceeds the total royalty suspension 

volume(s) provided in the lease terms or through application and approval of 

relief from royalties, the provisions of this stipulation will no longer apply effective 

the day after the suspension volumes have been produced.

(E) If, in any production year after the first five years of lease production, due to 

lease royalty suspension provisions or through application and approval of relief 

from royalties, no lease production royalty is due or payable by the lessee to the 

U.S., then the lessee will be required to pay, as stipulated in paragraph I below, 

Convention-related royalty in the following amount so that the required 

Convention payments may be made by the U.S. Government, as provided under 

the Convention:

(1) In the sixth year of production, 1 percent of the value of the sixth year's lease 

production saved, removed, or sold from the leased area;
Proposed Lease Mitigating Measures (Stipulations) D-21

(2) After the sixth year of production, the Convention-related royalty payment 

rate shall increase by 1 percent for each subsequent year until the twelfth 

year and shall remain at 7 percent thereafter until lease termination.

(F) If the U.S. becomes a party to UNCLOS after the fifth year of production from the 

lease, and a lessee is required, as provided herein, to pay Convention-related 

royalty, the amount of the royalty due will be based on the above payment 

schedule as determined from first production. For example, the U.S. 

Government becomes a party to the UNCLOS in the tenth year of lease 

production resulting in a UNCLOS-related royalty payment of 5 percent of the 

value of the tenth year's lease production, saved, removed, or sold from the 

lease. The following year, a payment of 6 percent would be due, and so forth, as 

stated above, up to a maximum of 7 percent per year.

(G) If, in any production year after the first five years of lease production, due to 

lease royalty suspension provisions or through application and approval of relief 

from royalties, lease production royalty is paid but is less than the payment 

provided for by the Convention, then the lessee will be required to pay to the U.S. 

Government the UNCLOS-related royalty in the amount of the shortfall.

(H) In determining the value of production from the lease if a payment of UNCLOSrelated royalty is to be made, the provisions of the lease and applicable 

regulations will apply.

(I) The UNCLOS-related royalty payment(s) required under paragraphs E through G 

of this stipulation, if any, shall not be paid monthly but will be due and payable to 

the Office of Natural Resources Revenue on or before 30 days after the 

expiration of the relevant production lease year.

(J) The lessee will receive royalty credit in the amount of the UNCLOS-related 

royalty payment required under paragraphs E through G of this stipulation, which 

will apply to royalties due under the lease for which the Convention-related 

royalty accrued in subsequent periods, as non-UNCLOS-related royalty 

payments become due.

(K) Any lease production for which the lessee pays no royalty other than a 

UNCLOS-related requirement, due to lease royalty suspension provisions or 

through application and approval of relief from royalties, will count against the 

lease's applicable royalty suspension or relief volume.

(L) The lessee will not be allowed to apply or recoup any unused UNCLOS-related 

credit(s) associated with a lease that has been relinquished or terminated.

D.9 BELOW SEABED OPERATIONS STIPULATION

This stipulation is designed to minimize or avoid potential space-use conflicts with moored 

and/or floating production facilities that have already been granted rights-of-use and easements in 
D-22 Gulf of Mexico Multisale EIS

particular OCS blocks. The stipulation language below is intended to be lease sale-specific 

language and would incorporate maps of the blocks that may be affected by the Below Seabed 

Operations Stipulation.

Below Seabed Operations Stipulation

Rights-of-use and easements have been granted to allow permanent mooring of 

floating production facilities. As a result, any lessee holding an interest in oil and gas 

leases for these blocks is not allowed to conduct activities, including, but not limited 

to, the construction and use of structures, operation of drilling rigs, laying of 

pipelines, and/or anchoring, will occur or be located on the seafloor or in the water 

column within the areas depicted by the attached maps. Subseabed activities that 

are part of exploration, development, and production activities from outside the areas 

depicted by the attached maps may be allowed, including the use of directional 

drilling or other techniques.

This stipulation will be included in any lease awarded from this lease sale on the following list 

of blocks. (The list of blocks is updated in the Final Notice of Sale before each lease sale, 

but it currently includes the blocks below.)

Mississippi Canyon 650, 651, 692, 694, 723, 735, 767, 919, 920, 921, and 964; 

Walker Ridge 293 and 294, 717, 762, and 763; 

Green Canyon 613, 786, 787, 788, and 860; and

Keathley Canyon 831. 

Effectiveness of the Lease Stipulation

This stipulation is designed to minimize or avoid potential space-use conflicts with moored 

and/or floating production facilities that have already been granted rights-of-use and easements in 

particular OCS blocks. BOEM has effectively used this stipulation for over a decade to make 

bidders aware of other activities with rights-of-use and easements on the above OCS blocks and 

may require buffers or additional requirements prior to acquiring leases on those specific blocks.

D.10 TRANSBOUNDARY STIPULATION

This stipulation incorporates by reference the Agreement and notifies lessees that, among 

other things, activities in this boundary area will be subject to the Agreement and that approval of 

plans, permits, and unitization agreements will be conditioned upon compliance with the terms of the 

Agreement.
Proposed Lease Mitigating Measures (Stipulations) D-23

Agreement between the United States of America 

and the United Mexican States Concerning 

Transboundary Hydrocarbon Reservoirs in the Gulf of Mexico Stipulation

The “Agreement between the United States of America and the United Mexican 

States Concerning Transboundary Hydrocarbon Reservoirs in the Gulf of Mexico” 

(Agreement) signed on February 20, 2012, entered into force on July 18, 2014. All 

activities carried out under this lease must comply with the Agreement and any law, 

regulation, or condition of approval of a unitization agreement, plan, or permit 

adopted by the United States to implement the Agreement before or after issuance of 

this lease. The lessee is subject to, and must comply with, all terms of the 

Agreement, including, but not limited to, the following requirements:

This Agreement makes it possible for U.S. lessees to enter into voluntary 

agreements with a licensee of the United Mexican States (e.g., Petróleos Mexicanos 

(PEMEX)) to develop transboundary reservoirs. Lessees in the Boundary Area may 

be subject to certain provisions of the Agreement.

A. When the United States is obligated under the Agreement to provide information 

that may be considered confidential, commercial, or proprietary to a third-party or 

the Government of the United Mexican States, if the lessee holds such 

information, the lessee is required to provide it to the lessor as provided for in the 

Agreement;

B. When the United States is obligated under the Agreement to prohibit 

commencement of production on a lease, the Bureau of Safety and 

Environmental Enforcement (BSEE) will direct a Suspension of Production with 

which the lessee must comply;

C. When the United States is obligated under the Agreement to seek development 

of a transboundary reservoir under a unitization agreement, the lessee is 

required to cooperate and explore the feasibility of such development with a 

licensee of the United Mexican States;

D. When there is a proven transboundary reservoir, as defined by the Agreement, 

and the relevant parties, including the lessee, fail to conclude a unitization 

agreement, the lessee’s rights to produce the hydrocarbon resources will be 

limited by the terms of the Agreement;

E. If the lessee seeks to jointly explore or develop a transboundary reservoir with a 

licensee of the United Mexican States, the lessee is required to submit to BSEE 

information and documents that comply with and contain terms consistent with 

the Agreement, including, but not limited to, a proposed unitization agreement 

that designates the unit operator for the transboundary unit and provides for the 
D-24 Gulf of Mexico Multisale EIS

allocation of production and any redetermination of the allocation of production; 

and

F. The lessee is required to comply with and abide by determinations issued as a 

result of the Agreement’s dispute resolution process on, among other things, the 

existence of a transboundary reservoir, and the allocation and/or reallocation of 

production.

The lessee and its operators, personnel, and subcontractors are required to comply 

with these and any other additional measures necessary to implement the provisions 

of the Agreement, including, but not limited to, conditions of approvals for their plans 

and permits for activities related to any transboundary reservoir or geologic structure 

subject to the Agreement.

The term “Boundary Area,” means an area comprised of any and all blocks in the 

Western and Central Planning Areas, that are located wholly or partially within three 

statute miles of the Maritime and Continental Shelf boundary with Mexico, as the 

Maritime Boundary is delimited in the Treaty to Resolve Pending Boundary 

Differences and Maintain the Rio Grande and Colorado River as the International 

Boundary, signed November 24, 1970; the Treaty on Maritime Boundaries between 

the United Mexican States and the United States of America, signed on May 4, 1978; 

and, as the continental shelf in the Western Gulf of Mexico beyond 200 nautical miles 

is delimited in the Treaty between the Government of the United Mexican States and 

the Government of the United States of America, signed on June 9, 2000.

A copy of the Agreement can be found at the Department of the Interior website at: 

http://www.boem.gov/BOEM-Newsroom/Library/Boundaries-Mexico.aspx. 

Effectiveness of the Lease Stipulation

The Transboundary Agreement removes uncertainties regarding development of 

transboundary resources in the resource-rich Gulf of Mexico. As a result of the agreement, nearly 

1.5 million ac of the OCS will now be made more accessible for exploration and production activities. 

BOEM’s estimates indicate that this area contains as much as 172 million barrels of oil and 

304 billion cubic feet of natural gas. The Agreement also opens up resources in the Western Gap 

that were off limits to both countries under a previous treaty that imposed a moratorium along the 

boundary. The Transboundary Agreement sets clear guidelines for the development of oil and 

natural gas reservoirs that cross the maritime boundary. Under the Agreement, U.S. companies and 

PEMEX will be able to voluntarily enter into agreements to jointly develop those reservoirs. In the 

event that consensus cannot be reached, the Transboundary Agreement establishes the process 

through which U.S. companies and PEMEX can individually develop the resources on each side of 

the border while protecting each nation's interests and resources.
Proposed Lease Mitigating Measures (Stipulations) D-25

D.11 REFERENCES

Barry A. Vittor and Associates, Inc. 1985. Tuscaloosa Trend regional data search and synthesis 

study. Volume I: Synthesis report. U.S. Dept. of the Interior, Minerals Management Service, 

Gulf of Mexico OCS Region, Metairie, LA. OCS Study MMS 85-0056. 398 pp.

Bright, T.J. and R. Rezak. 1978. Northwestern Gulf of Mexico topographic features study: Final 

report. U.S. Dept. of the Interior, Bureau of Land Management, New Orleans OCS Office, New 

Orleans, LA. Study No. 1978-4. 692 pp. Internet website: http://www.gomr.boemre.gov/PI/

PDFImages/ESPIS/3/4069.pdf. 

Brooks, J.M. and C.P. Giammona. 1990. Mississippi-Alabama marine ecosystem study: Annual 

report; year 2. Volume I: Technical narrative. U.S. Dept. of the Interior, Minerals Management 

Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 89-0095. 348 pp.

Ludwick, J.C. and W.R. Walton. 1957. Shelf-edge, calcareous prominences in the northeastern 

Gulf of Mexico. Bulletin of the American Association of Petroleum Geologists 41(9):2054-2101.

National Research Council (NRC). 1983. Drilling discharges in the marine environment. Panel on 

Assessment of Fates and Effects of Drilling Fluids and Cuttings in the Marine Environment. 

National Research Council, Commission on Engineering and Technical Systems, Marine Board. 

Washington, DC: National Academy Press. Pp. 18-21.

Rezak, R. and T.J. Bright. 1981. Northern Gulf of Mexico topographic features study: Final report. 

U.S. Dept. of the Interior, Bureau of Land Management, Gulf of Mexico OCS Region, New 

Orleans, LA. Contract No. AA551-CT8-35. 5 vols.

Rezak, R., T.J. Bright, and D.W. McGrail. 1983. Reefs and banks of the northwestern Gulf of 

Mexico: Their geological, biological, and physical dynamics. Final Technical Report No. 83-1-T.

Rezak, R., T.J. Bright, and D.W. McGrail. 1985. Reefs and banks of the northwestern Gulf of 

Mexico: Their geological, biological, and physical dynamics. New York, NY: Wiley and Sons. 

259 pp.

Rezak, R., S.R. Gittings, and T.J. Bright. 1990. Biotic assemblages and ecological controls on reefs 

and banks of the northwest Gulf of Mexico. American Zoologist 30:23-35.

APPENDIX E 

 

OIL SPILL RISK ANALYSIS FIGURES

Oil Spill Risk Analysis Figures E-3 

E OIL SPILL RISK ANALYSIS FIGURES

The following figures comprise the results of the Oil Spill Risk Analysis (OSRA) conducted 

for Alternatives A, B, and C. All of the assumptions and scenario estimates for Alternative D 

(including the commonly applied mitigating measures in Appendix B) are the same as for a 

proposed action under Alternative A, B, or C; consequently, refer to the corresponding Alternative A, 

B, or C for information relevant to Alternative D. Chapter 3.2.1 of this Multisale EIS provides for a 

discussion of oil spills and the OSRA model. In summary, oil-spill risk was calculated by multiplying 

the probability of contact generated by the OSRA model by the probability of occurrence of one or 

more spills ≥1,000 bbl as a result of a proposed action. This provides a risk factor that represents 

the probability of a spill occurring as a result of a proposed action and contacting a specified 

geographic area or feature. These are referred to as “combined probabilities” because they combine 

the risk of occurrence of a spill from OCS sources and the risk of such a spill contacting areas of 

sensitive environmental, social, and economic resources. Figure E-1 shows the geographic 

boundaries, known as the domain, used for the analysis. Figures E-2 through E-7 show the 

probabilities of oil spills (≥1,000 bbl) occurring and contacting within 10 or 30 days the shoreline 

(counties and parishes) as a result of an Alternative A, B, or C proposed action. Figures E-8 

through E-19 show the probabilities of oil spills (≥1,000 bbl) occurring and contacting within 10 or 

30 days nearshore (0-20 m), shelf (20-300 m), and deepwater (300 m to outer jurisdiction) areas as 

a result of the low- or high-case scenario of resource estimates for Alternatives A, B, or C. Lastly, 

Figure E-20 shows the probabilities of oil spills (≥1,000 bbl) occurring and contacting within 10 days 

and 30 days State offshore waters as a result of Alternative A, B, or C.
E-4 Gulf of Mexico Multisale EIS

Figure E-1. The Oil Spill Risk Analysis Domain.

Figure E-2. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days the Shoreline 

(counties and parishes) as a Result of Alternative A.
Oil Spill Risk Analysis Figures E-5 

Figure E-3. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days the Shoreline 

(counties and parishes) as a Result of Alternative A.

Figure E-4. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days the Shoreline 

(counties and parishes) as a Result of Alternative B.
E-6 Gulf of Mexico Multisale EIS

Figure E-5. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days the Shoreline 

(counties and parishes) as a Result of Alternative B.

Figure E-6. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days the Shoreline 

(counties and parishes) as a Result of Alternative C.
Oil Spill Risk Analysis Figures E-7 

Figure E-7. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days the Shoreline 

(counties and parishes) as a Result of Alternative C.

Figure E-8. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days Nearshore 

(“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to outer jurisdiction) 

Polygons as a Result of the Low Case in Resource Estimates for Alternative A. 
E-8 Gulf of Mexico Multisale EIS

Figure E-9. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days Nearshore 

(“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to outer jurisdiction) 

Polygons as a Result of the High Case in Resource Estimates for Alternative A. 

Figure E-10. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days Nearshore 

(“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to outer jurisdiction) 

Polygons as a Result of the Low Case in Resource Estimates for Alternative A. 
Oil Spill Risk Analysis Figures E-9 

Figure E-11. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days Nearshore 

(“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to outer jurisdiction) 

Polygons as a Result of the High Case in Resource Estimates for Alternative A. 

Figure E-12. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days Nearshore 

(“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to outer jurisdiction) 

Polygons as a Result of the Low Case in Resource Estimates for Alternative B. 
E-10 Gulf of Mexico Multisale EIS

Figure E-13. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days Nearshore 

(“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to outer jurisdiction) 

Polygons as a Result of the High Case in Resource Estimates for Alternative B. 

Figure E-14. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days Nearshore 

(“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to outer jurisdiction) 

Polygons as a Result of the Low Case in Resource Estimates for Alternative B. 
Oil Spill Risk Analysis Figures E-11

Figure E-15. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days Nearshore 

(“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to outer jurisdiction) 

Polygons as a Result of the High Case in Resource Estimates for Alternative B. 

Figure E-16. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days Nearshore 

(“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to outer jurisdiction) 

Polygons as a Result of the Low Case in Resource Estimates for Alternative C. 
E-12 Gulf of Mexico Multisale EIS

Figure E-17. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days Nearshore 

(“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to outer jurisdiction) 

Polygons as a Result of the High Case in Resource Estimates for Alternative C. 

Figure E-18. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days Nearshore 

(“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to outer jurisdiction) 

Polygons as a Result of the Low Case in Resource Estimates for Alternative C. 
Oil Spill Risk Analysis Figures E-13

Figure E-19. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 30 Days Nearshore 

(“N”, 0-20 m), Shelf (“S”, 20-300 m), and Deepwater (“D”, 300 m to outer jurisdiction) 

Polygons as a Result of the High Case in Resource Estimates for Alternative C. 

Figure E-20. Probabilities of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days and 30 Days 

State Offshore Waters as a Result of Alternative A, B, or C. (Note: The limits of State 

waters are defined by the States and range from 3 to 9 nmi [3.45 to 10.36 mi; 5.56 to

16.67 km]. Texas and Florida State offshore waters extend 3 marine leagues [just over 

9 nmi] seaward from the shoreline [1 marine league = 18,228.3 ft; 5,556 m]. Louisiana 

State offshore waters extend 3 imperial nautical miles seaward of the shoreline [1 imperial 

nautical mile = 6,080 ft; 1,853 m]). 

APPENDIX F 

 

AIR QUALITY: 

WRF MODEL PERFORMANCE

Table of Contents F-iii

TABLE OF CONTENTS

Page

F.1 INTRODUCTION................................................................................................................... F-1

F.2 WRF MODELING METHODOLOGY .................................................................................... F-5

F.2.1 Gulf of Mexico OCS Region Air Quality Meteorological Modeling ............................. F-5

F.2.2 Model Domain Configuration ...................................................................................... F-6

F.2.3 Model Application........................................................................................................ F-7

F.2.3.1 Model Vertical Resolution............................................................................. F-7

F.2.3.2 Topographic Inputs....................................................................................... F-8

F.2.3.3 Vegetation Type and Land Use Inputs......................................................... F-9

F.2.3.4 Atmospheric Data Inputs .............................................................................. F-9

F.2.3.5 Time Integration............................................................................................ F-9

F.2.3.6 Diffusion Options .......................................................................................... F-9

F.2.3.7 Lateral Boundary Conditions........................................................................ F-9

F.2.3.8 Top and Bottom Boundary Conditions ....................................................... F-10

F.2.3.9 Sea-Surface Temperature Inputs............................................................... F-10

F.2.3.10 FDDA Data Assimilation............................................................................. F-10

F.2.3.11 WRF Physics Options................................................................................. F-11

F.2.3.12 WRF Application Methodology................................................................... F-11

F.3 WRF MODEL PERFORMANCE EVALUATION RESULTS ............................................... F-12

F.3.1 Quantitative Evaluation Using Metstat...................................................................... F-12

F.3.1.1 Quantitative Statistics................................................................................. F-13

F.3.1.2 METSTAT Evaluation Using Integrated Surface Hourly Observations 

and Offshore Buoy Observations ............................................................... F-15

F.3.2 Qualitative Evaluation Using Wind Roses ................................................................ F-22

F.3.3 Qualitative Evaluation Using Upper-Air Data............................................................ F-27

F.3.4 Qualitative Evaluation Using Precipitation................................................................ F-29

F.3.4.1 Evaluation Over Land Using PRISM Precipitation..................................... F-29

F.3.4.2 Evaluation Over Water Using Satellite Precipitation.................................. F-43

F.3.4.3 Evaluation Using Tropical Cyclone Precipitation Events ........................... F-56

F.4 SUMMARY AND CONCLUSIONS...................................................................................... F-59

F.5 REFERENCES.................................................................................................................... F-59

List of Tables F-v 

LIST OF TABLES

Page

Table F-1. Nonattainment and Maintenance Areas in the Southeastern U.S.................................. F-3

Table F-2. BOEM Gulf of Mexico OCS Region WRF Domain Configuration................................... F-6

Table F-3. BOEM Gulf of Mexico OCS Region WRF Dataset Model Levels................................... F-8

Table F-4. BOEM Gulf of Mexico OCS Region WRF Physics Options.......................................... F-11

Table F-5. Meteorological Model Performance Benchmarks for Simple and Complex 

Conditions...................................................................................................................... F-12

LIST OF FIGURES

Page

Figure F-1. Location of the “Air Quality Modeling in the Gulf of Mexico Region” Study with 

Class I Areas and Platform Locations.......................................................................... F-1

Figure F-2. Ozone Nonattainment Areas in the Southeastern U.S................................................ F-2

Figure F-3. Overview of the “Air Quality Modeling in the Gulf of Mexico Region” Study 

Tasks............................................................................................................................ F-4

Figure F-4. WRF 36-km CONUS (d01), 12-km SE Regional (d02), and 4-km Gulf of Mexico 

Region (d03) Domains ................................................................................................. F-7

Figure F-5. BOEM Gulf of Mexico OCS Region WRF 36-km METSTAT Wind Direction 

Performance for 2012 ................................................................................................ F-16

Figure F-6. BOEM Gulf of Mexico OCS Region WRF 36-km METSTAT Wind Speed 

Performance for 2012 ................................................................................................ F-16

Figure F-7. BOEM Gulf of Mexico OCS Region WRF 36-km METSTAT Temperature 

Performance for 2012 ................................................................................................ F-17

Figure F-8. BOEM Gulf of Mexico OCS Region WRF 36-km METSTAT Humidity 

Performance for 2012 ................................................................................................ F-17

Figure F-9. BOEM Gulf of Mexico OCS Region WRF 12-km METSTAT Wind Direction 

Performance for 2012 ................................................................................................ F-18

Figure F-10. BOEM Gulf of Mexico OCS Region WRF 12-km METSTAT Wind Speed 

Performance for 2012 ................................................................................................ F-18

Figure F-11. BOEM Gulf of Mexico OCS Region WRF 12-km METSTAT Temperature 

Performance for 2012 ................................................................................................ F-19

Figure F-12. BOEM Gulf of Mexico OCS Region WRF 12-km METSTAT Humidity 

Performance for 2012 ................................................................................................ F-19

Figure F-13. BOEM Gulf of Mexico OCS Region WRF 4-km METSTAT Wind Direction 

Performance for 2012 ................................................................................................ F-20

Figure F-14. BOEM Gulf of Mexico OCS Region WRF 4-km METSTAT Wind Speed 

Performance for 2012 ................................................................................................ F-20

Figure F-15. BOEM Gulf of Mexico OCS Region WRF 4-km METSTAT Temperature 

Performance for 2012 ................................................................................................ F-21
F-vi Gulf of Mexico Multisale EIS

Figure F-16. BOEM Gulf of Mexico OCS Region WRF 4-km METSTAT Humidity 

Performance for 2012 ................................................................................................ F-21

Figure F-17. Wind Rose Locations for Port Isabel, TX (PTIT), Calcasieu, LA (CAPL), 

Gulfport, MS (KGPT), and Naples, FL (NPSF).......................................................... F-22

Figure F-18. 2012 WRF Wind Rose Compared to 2012 Observation Wind Rose from 

Gulfport, MS in 4-km Domain..................................................................................... F-23

Figure F-19. 2012 WRF Wind Rose Compared to 2012 Observation Wind Rose from 

Naples, FL in 4-km Domain ....................................................................................... F-24

Figure F-20. 2012 WRF Wind Rose Compared to 2012 Observation Wind Rose from 

Port Isabel, TX in 4-km Domain................................................................................. F-25

Figure F-21. 2012 WRF Wind Rose Compared to 2012 Observation Wind Rose from 

Calcasieu, LA in 4-km Domain................................................................................... F-26

Figure F-22. Vertical Profile Soundings Comparing the 4-km WRF to Upper-Air 

Observations Data for Brownsville, TX on August 3, 2012, and Key West, FL 

on January 4, 2012, at 00 UTC.................................................................................. F-28

Figure F-23. January 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain............... F-31

Figure F-24. February 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain ............. F-32

Figure F-25. March 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain.................. F-33

Figure F-26. April 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain .................... F-34

Figure F-27. May 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain..................... F-35

Figure F-28. June 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain.................... F-36

Figure F-29. July 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain ..................... F-37

Figure F-30. August 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain ................ F-38

Figure F-31. September 2012 PRISM Precipitation and WRF Precipitation, 4 km Domain.......... F-39

Figure F-32. October 2012 PRISM Precipitation and WRF Precipitation, 4 km Domain............... F-40

Figure F-33. November 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain........... F-41

Figure F-34. December 2012 PRISM Precipitation and WRF Precipitation, 4-km Domain........... F-42

Figure F-35. January 2012 TRMM Precipitation Average and Corresponding WRF 

Precipitation Average in the 12 km Domain............................................................... F-44

Figure F-36. February 2012 TRMM Precipitation Average and Corresponding WRF 

precipitation Average in the 12-km Domain............................................................... F-45

Figure F-37. March 2012 TRMM Precipitation Average and Corresponding WRF 

Precipitation Average in the 12-km Domain .............................................................. F-46

Figure F-38. April 2012 TRMM Precipitation Average and Corresponding WRF Precipitation 

Average in the 12-km Domain ................................................................................... F-47

Figure F-39. May 2012 TRMM Precipitation Average and Corresponding WRF Precipitation 

Average in the 12-km Domain ................................................................................... F-48

Figure F-40. June 2012 TRMM Precipitation Average and Corresponding WRF Precipitation 

Average in the 12-km Domain ................................................................................... F-49

Figure F-41. July 2012 TRMM Precipitation Average and Corresponding WRF Precipitation 

Average in the 12-km Domain ................................................................................... F-50

Figure F-42. August 2012 TRMM Precipitation Average and Corresponding WRF 

Precipitation Average in the 12-km Domain .............................................................. F-51
List of Figures F-vii

Figure F-43. September 2012 TRMM Precipitation Average and Corresponding WRF 

Precipitation Average in the 12-km Domain .............................................................. F-52

Figure F-44. October 2012 TRMM Precipitation Average and Corresponding WRF 

Precipitation Average in the 12-km Domain .............................................................. F-53

Figure F-45. November 2012 TRMM precipitation average and Corresponding WRF 

Precipitation Average in the 12-km Domain .............................................................. F-54

Figure F-46. December 2012 TRMM precipitation average and Corresponding WRF 

Precipitation Average in the 12-km Domain .............................................................. F-55

Figure F-47. Daily Precipitation Plots from WRF, PRISM, and TRMM on August 30, 2012 ......... F-57

Figure F-48. Daily Precipitation Plots from WRF, PRISM, and TRMM Databases on June 25, 

2012............................................................................................................................ F-58

Air Quality: WRF Model Performance F-ix

ABBREVIATIONS AND ACRONYMS

ARW Advanced Research WRF

BOEM Bureau of Ocean Energy Management

CAI Climatologically Aided Interpolation

CAAA Clean Air Act Amendments

CAMx Comprehensive Air Quality Model with Extensions

CFL Courant-Friedrichs-Lewy

CFSR Climate Forecast System Reanalysis

CFSv2 Climate Forecast System Version 2

CMAQ Community Multi-scale Air Quality model

ECMWF European Center for Medium-Range Weather Forecasting

EIS Environmental Impact Statement

ERA European Center for Medium-Range Weather Forecasting Re-Analysis

ERG Eastern Research Group, Inc.

ESRL Earth System Research Laboratory

FDDA Four-Dimensional Data Assimilation

FNMOC Fleet Numerical Meteorology and Oceanography Center

IC/BC Initial Conditions/Boundary Conditions

IOA Index of Agreement

ISHO Integrated Surface Hourly Observation

KBRO Meteorological Call Sign for Brownsville

KSIL Meteorological Call Sign for Slidell

KTPA Meteorological Call Sign for Tampa

KEYW Meteorological Call Sign for Key West

LCC Lambert Conformal Conic 

LSM Land-Surface Model

MADIS Meteorological Assimilation Data Ingest System

METSTAT Meteorological Statistical Program

MM5 Mesoscale Meteorological Model version 5

MMIF Mesoscale Model Interface Program 

MPE Model Performance Evaluation

NAAQS National Ambient Air Quality Standards

NAM North American Model

NASA National Aeronautics and Space Administration

NCAR National Center for Atmospheric Research

NCDC National Climatic Data Center

NCEP National Centers for Environmental Prediction

NDBC National Data Buoy Center

NEPA National Environmental Policy Act

NMM Nonhydrostatic Mesoscale Model
F-x Gulf of Mexico Multisale EIS

NOAA National Oceanographic Atmospheric Administration 

NWS National Weather Service

OCS Outer Continental Shelf

OCSLA OCS Lands Act

PBL Planetary Boundary Layer

PGM Photochemical Grid Model

PRISM Parameter-elevation Regressions on Independent Slopes Model

RMSE Root Mean Square Error

RRTMG Rapid Radiative Transfer Model for GCMs

SCAS-OSU Spatial Climate Analysis Service at Oregon State University

SST Sea-Surface Temperature

TRMM Tropical Rainfall Measurement Mission

USEPA United States Environmental Protection Agency

USDOC United States Department of Commerce

USGS United States Geological Survey

UTC Universal Time Coordinate

WPS WRF Pre-processing System

WRAP Western Regional Air Partnership

WRF Weather Research and Forecasting model
Air Quality: WRF Model Performance F-1 

F AIR QUALITY: WRF MODEL PERFORMANCE

F.1 INTRODUCTION

The U.S. Department of the Interior’s Bureau of Ocean Energy Management (BOEM) is 

required under the Outer Continental Shelf Lands Act (OCSLA) (43 U.S.C. § 1334(a)(8)) to comply 

with the National Ambient Air Quality Standards (NAAQS) to the extent that Outer Continental Shelf 

(OCS) offshore oil and gas exploration, development, and production sources do not significantly 

affect the air quality of any state. The Gulf of Mexico OCS Region’s area of possible influence 

includes the States of Texas, Louisiana, Mississippi, Alabama, and Florida. BOEM’s Gulf of Mexico 

Region manages the responsible development of oil, gas, and mineral resources for the 430 million 

acres in the Western, Central, and Eastern Planning Areas on the OCS, including the areas under 

moratoria (shown in Figure F-1). The Clean Air Act Amendments (CAAA) of 1990 designate air 

quality authorities, giving BOEM air quality jurisdiction westward of 87°30'W. longitude and the U.S. 

Environmental Protection Agency (USEPA) air quality jurisdiction eastward of 87°30'W. longitude. In 

2006, oil and gas leasing operations within 125 miles (201 kilometers [km]) of the Florida coastline 

were banned until 2022 under the Gulf of Mexico Energy Security Act (GOMESA). The GOMESA 

moratoria area is depicted on Figure F-1. 

Figure F-1. Location of the “Air Quality Modeling in the Gulf of Mexico Region” Study with Class I 

Areas (purple) and Platform Locations (gray dots). 

The USEPA has set NAAQS for six regulated air quality pollutants: ozone; particulate matter 

with an aerodynamic diameter of 2.5 micrometers and smaller (PM2.5); particulate matter with an 
F-2 Gulf of Mexico Multisale EIS

aerodynamic diameter of 10 micrometers and smaller (PM10); sulfur dioxide (SO2); nitrogen dioxide 

(NO2); carbon monoxide (CO); and lead (Pb). After promulgation of a NAAQS, the USEPA 

designates areas that fail to achieve the NAAQS as nonattainment areas (NAAs) and States are 

required to submit State Implementation Plans (SIPs) to the USEPA that contain emission control 

plans and a demonstration that the NAA will achieve the NAAQS by the required date. After an area 

comes into attainment of the NAAQS, the area can be redesignated as a maintenance area and 

must continue to demonstrate compliance with the NAAQS.

In 1997, the USEPA promulgated the first 8-hour ozone NAAQS with a threshold of 

0.08 parts per million (ppm) (84 parts per billion [ppb]). On March 12, 2008, the USEPA 

promulgated a more stringent 0.075 ppm (75 ppb) 8-hour ozone NAAQS. Figure F-2 presents the 

current ozone nonattainment areas in the southeastern U.S. On October 1, 2015, the USEPA 

strengthened the 8-hour NAAQS for ozone to 0.07 ppm (70 ppb). Under this more stringent ozone 

NAAQS, there may be more areas in the southeastern U.S. that will be in nonattainment. The 

USEPA plans to make attainment and nonattainment designations for the revised standards by 

October 2017, with the designations based on 2014-2016 air quality data.

Figure F-2. Ozone Nonattainment Areas in the Southeastern U.S. (USEPA, 2016a). 

On December 14, 2012, the USEPA revised the PM2.5 primary NAAQS by lowering the 

annual PM2.5 NAAQS threshold from 15.0 micrograms per cubic meter (μg/m3

) to 12.0 μg/m3. The 

USEPA retained the 24-hour PM2.5 primary NAAQS at 35 μg/m3

. The 24-hour coarse PM NAAQS 

(PM10) was also retained at 150 μg/m3

. 

In February 2010, the USEPA issued a new 1-hour NO2 NAAQS with a threshold of 100 ppb 

(98th percentile daily maximum average over three-years) and a new 1-hour SO2 NAAQS was 

promulgated in June 2010 with a threshold of 75 ppb (99th percentile averaged over 3 years). The 

USEPA has not yet designated the nonattainment areas for the 1-hour NO2 and 1 hour SO2 NAAQS.
Air Quality: WRF Model Performance F-3 

A new lead NAAQS was issued in 2008; NAAs for lead are associated with specific industrial 

sources. As oil and gas sources in the Gulf of Mexico OCS region produce negligible amounts of 

lead emissions and to be consistent with onshore oil and gas analysis, which does not include lead, 

lead was not included in the air quality analysis. The NAAQS for carbon monoxide has remained 

essentially unchanged since it was originally promulgated in 1971. As of September 27, 2010, all 

NAAs for carbon monoxide have been redesignated as maintenance areas. Table F-1 summarizes 

the nonattainment and maintenance areas in the southeastern U.S.

Table F-1. Nonattainment and Maintenance Areas in the Southeastern U.S.

State Area 8-hr O3

(1997)

8-hr O3

(2008)

SO2

(2010)

Lead 

(2008)

Alabama Troy, AL NAAa

Florida

Tampa, FL NAA

Hillsborough County, FL NAA

Nassau County, FL NAA

Louisiana Baton Rouge, LA Mb NAA

St. Bernard Parish, LA NAA

Texas

Beaumont-Port Arthur, TX M

Houston-Galveston-Brazoria, 

TX NAA NAA

Frisco, TX NAA a NAA = nonattainment area

b M = maintenance area

Blank cells indicate the area is in attainment of the NAAQS.

The CAAA designated 156 Class I areas consisting of National Parks and Wilderness Areas 

that are offered special protection for air quality and air quality-related values (AQRVs). The Class I

areas, compared to Class II areas, have lower Prevention of Significant Deterioration (PSD) air 

quality increments that new sources may not exceed and are protected against excessive increases 

in several AQRVs, including visibility impairment, acid (sulfur and nitrogen) deposition, and nitrogen 

eutrophication. The Regional Haze Rule (RHR) has a goal of natural visibility conditions by 2064 at 

Class I areas, and States must submit RHR SIPs that demonstrate progress towards that goal. 

Figure F-1 displays the locations of the mandatory Class I areas (in purple) in the Gulf of Mexico 

OCS region. In addition to the Class I areas, Federal Land Management (FLM) agencies have 

designated certain other areas as sensitive Class II areas for tracking PSD increment consumption 

and AQRV impacts.

On August 26, 2014, BOEM contracted with Eastern Research Group, Inc. (ERG) and team 

members Ramboll Environ US Corporation (Ramboll Environ) and Alpine Geophysics, LLC to 

complete a comprehensive air quality modeling study in the Gulf of Mexico OCS region. Under 

BOEM Contract Number M14PC00007, air quality photochemical grid modeling (PGM) will be 

conducted in the region to assess the impacts to nearby States of OCS oil and gas exploration, 

development, and production as required under OCSLA. This assessment is used by BOEM in the 

cumulative and visibility impacts analyses of the National Environmental Policy Act (NEPA) 
F-4 Gulf of Mexico Multisale EIS

environmental impact statement (EIS), which is the Gulf of Mexico OCS Oil and Gas Lease Sales: 

2017-2022; Gulf of Mexico Lease Sales 249, 250, 251, 252, 253, 254, 256, 257, 259, and 261—

Final Multisale Environmental Impact Statement (2017-2022 GOM Multisale EIS). These analyses 

address both current and proposed NAAQS.

Air quality modeling requires several input datasets, including meteorology, emissions 

inventories, and ambient pollutant concentrations. Figure F-3 presents an overview of how these 

project datasets fit together for the “Air Quality Modeling in the Gulf of Mexico Region” study. 

Figure F-3. Overview of the “Air Quality Modeling in the Gulf of 

Mexico Region” Study Tasks. 

This report details the meteorological modeling performance evaluation (MPE) of a Weather 

and Research Forecast (WRF) model for 2012, the PGM year. A separate report (referred to herein 

as the “full WRF modeling report”) will provide a more comprehensive evaluation of the full 5-year 

WRF dataset.

Meteorological information is needed for air quality modeling. Parameters such as wind 

speed, wind direction, air temperature, and humidity are required by models to determine the rate 

that pollutants disperse and react in the atmosphere. Sources of meteorological information include 

datasets of measurements gathered at various locations within the Gulf of Mexico OCS Region’s

domain. However, the spatial coverage of measurements is insufficient to describe the threedimensional structure of the atmosphere away from measurement locations. Using measurement 

data as inputs, gridded meteorological models capable of simulating the fluid dynamics of the 

atmospheric data can be used to estimate meteorological conditions over a complete modeling 

domain—including regions far from measurement sites—in a physically consistent fashion. The 

results of these models are often used to establish conditions near remote pollutant sources or 
Air Quality: WRF Model Performance F-5 

remote locations downwind of pollutant sources. Within the domain of the Gulf of Mexico OCS 

Region, the WRF meteorological model has been identified and was used to provide meteorological 

inputs for the air quality models.

Ramboll Environ previously evaluated the existing meteorological datasets and concluded 

that enough deficiencies were present in the datasets and there were not enough positive attributes 

to select any of them for air quality modeling in the study area (Brashers et al., official 

communication, 2014) and, therefore, new meteorological modeling was required. One purpose of 

the modeling is to provide the meteorological dataset for the 2012 simulation using PGM modeling in 

the OCS region. 

F.2 WRF MODELING METHODOLOGY

Over the past decade, emergent requirements for numerical simulation of urban and regional 

scale air quality have led to intensified efforts to construct high-resolution emissions, meteorological 

and air quality datasets. It is now possible, for example, to exercise sophisticated mesoscale 

prognostic meteorological models and Eulerian and Lagrangian photochemical/aerosol models for 

multi-seasonal periods over near-continental scale domains in a matter of weeks with the application 

tailored to a specific air quality modeling project.

The WRF model is the current preferred model for atmospheric research and operational 

forecasting needs at mesoscale resolution (approximately 5 to several hundred km). The model is 

the state-of-the-art atmospheric simulation system, commonly used to drive air quality dispersion 

models on the regional level.

The operational version of the model is the Nonhydrostatic Mesoscale Model (NMM) WRF 

core version 3, developed and maintained by the U.S. Department of Commerce’s National Oceanic 

and Atmospheric Administration (NOAA) and the National Centers for Environmental Prediction 

(NCEP). The Advanced Research WRF (ARW) core, currently version WRF 3.7.1, is supported by 

the National Center for Atmospheric Research (NCAR), Mesoscale and Microscale Meteorology 

Division (NCAR, 2015). The modeling described in this report used WRF version 3.7.

The WRF model contains separate modules to compute different physical processes such as 

surface energy budgets and soil interactions, turbulence, cloud microphysics, and atmospheric 

radiation. Within WRF, the user has many options for selecting the different schemes for each type 

of physical process. There is a WRF Pre-processing System (WPS) that generates the initial and 

boundary conditions used by WRF, based on topographic datasets, land use information, and largerscale atmospheric and oceanic models.

F.2.1 Gulf of Mexico Region Air Quality Meteorological Modeling

The USEPA CONUS WRF and Ramboll Environ Training WRF datasets were previously 

examined in detail and evaluated using both quantitative and qualitative techniques. Both datasets 

were identified as being inadequate for the study area, particularly in the offshore portions (Brashers
F-6 Gulf of Mexico Multisale EIS

et al., official communication, 2014). The development of a new high-resolution dataset was 

necessary to more accurately represent meteorological conditions in the over-water portions of the 

OCS region for use in air quality modeling.

F.2.2 Model Domain Configuration

The WRF domain configuration is comprised of a system of simultaneous nested grids. 

Figure F-3 shows the WRF modeling grids at 36/12/4 km. All WRF grids are defined on a Lambert 

Conformal Conic (LCC) projection centered at 40°N. latitude, 97°W. longitude with true latitudes at 

33°N. and 45°N. (the “standard RPO” projection). The outermost domain (outer box) with 36-km 

resolution includes the entire continental U.S. and parts of Canada and Mexico, and captures 

synoptic-scale (storm system-scale) structures in the atmosphere. The inner 12-km regional grid 

(d02) covers the southeastern U.S. and was used to ensure that large-scale meteorological patterns 

across the region are adequately represented and to provide boundary conditions to the 4-km 

domain.

The 4-km domain (d03) shown in Figure F-4 is centered on the coastal areas of the 

southeastern U.S. and over-water portions of the Gulf of Mexico. Table F-2 provides the input 

configurations for this WRF domain. The NX and NY are the number of east-west and north-south 

staggered grid points, respectively, in each domain. I-start and J-start indicate the western and 

southern nested grid starting indices with respect to the parent grid. Geographic resolution relates to 

the geographic datasets employed for each grid in terms of minutes or seconds of degrees. 

The 36-, 12-, and 4-km grids were run simultaneously with one-way nesting, meaning that 

meteorological information flows down-scale via boundary conditions introduced from the coarser to 

finer grids without feedback from the finer to coarser grids. The WRF modeling domain was defined 

to be slightly larger than the CAMx/CMAQ PGM modeling domains to eliminate boundary artifacts in 

the meteorological fields. Such boundary artifacts occur for both numerical reason (the 3:1 grid 

spacing ratio) and because the imposed boundary conditions require some time/space to come into 

dynamic balance with WRF’s atmospheric equations. 

Table F-2. BOEM’s Gulf of Mexico OCS Region WRF Domain Configuration. 

Grid Resolution NX NY I-start J-start Geographic Resolution Coverage

36 km 165 129 1 1 10 minute CONUS

12 km 265 187 55 9 2 minute SE CONUS

4 km 481 211 72 27 30 second OCS Region

 
Air Quality: WRF Model Performance F-7 

Figure F-4. WRF 36-km CONUS (d01), 12-km SE Regional (d02), and 4-km Gulf of Mexico Region 

(d03) Domains. 

F.2.3 Model Application

The publicly available version of WRF, version 3.7, was used in the Gulf of Mexico OCS 

Region’s meteorological modeling. The WRF pre-processor programs, including GEOGRID, 

UNGRIB, METGRID, and OBSGRID, were used to develop model inputs. 

F.2.3.1 Model Vertical Resolution

The dataset was tested using both 33 and 37 vertical layers. Thirty-seven vertical layers 

allowed for higher vertical resolutions near the surface, which enabled the model to more accurately 

capture low-level inversions frequently present during winter. Additional layers in the mid-levels also 

allowed the model to more accurately re-create the convective updraft velocities seen in the summer 

months. The dataset model levels are shown in Table F-3. 
F-8 Gulf of Mexico Multisale EIS

Table F-3. BOEM Gulf of Mexico OCS Region WRF Dataset Model Levels.

Level eta Pressure (mb) Height (m) Mid Height (m) Thickness (m)

0 1 1,000 0.0

1 0.9985 999 12.2 6.1 12.2

2 0.9970 997 24.5 18.4 12.2

3 0.9950 995 40.8 32.7 16.4

4 0.9930 993 57.2 49.0 16.4

5 0.9910 991 73.6 65.4 16.4

6 0.9880 989 98.3 85.9 24.7

7 0.9850 986 123.0 110.6 24.7

8 0.9800 981 164.3 143.6 41.3

9 0.9700 972 247.4 205.9 83.1

10 0.9600 962 331.2 289.3 83.8

11 0.9500 953 415.7 373.4 84.5

12 0.9400 943 500.8 458.2 85.1

13 0.9300 934 586.6 543.7 85.8

14 0.9100 915 760.5 673.5 173.8

15 0.8900 896 937.2 848.8 176.8

16 0.8700 877 1,117.1 1,027.1 179.8

17 0.8400 848 1,392.8 1,254.9 275.8

18 0.8000 810 1,772.4 1,582.6 379.6

19 0.7600 772 2,166.7 1,969.6 394.3

20 0.7200 734 2,577.0 2,371.9 410.3

21 0.6800 696 3,005.0 2,791.0 427.9

22 0.6400 658 3,452.2 3,228.6 447.3

23 0.6000 620 3,921.0 3,686.6 468.7

24 0.5500 573 4,540.7 4,230.8 619.8

25 0.5000 525 5,203.7 4,872.2 662.9

26 0.4500 478 5,917.1 5,560.4 713.4

27 0.4000 430 6,690.5 6,303.8 773.4

28 0.3500 383 7,536.4 7,113.5 846.0

29 0.3000 335 8,472.3 8,004.4 935.8

30 0.2500 288 9,522.5 8,997.4 1,050.2

31 0.2000 240 10,724.1 10,123.3 1,201.6

32 0.1500 193 12,136.7 11,430.4 1,412.6

33 0.1000 145 13,866.9 13,001.8 1,730.1

34 0.0600 107 15,621.6 14,744.2 1,754.7

35 0.0270 76 17,503.4 16,562.5 1,881.8

36 0.0000 50 19,594.2 18,548.8 2,090.8

F.2.3.2 Topographic Inputs

Topographic information for WRF was developed using the standard WRF terrain databases 

available from NCAR. The 36-km CONUS domain was based on the 10-min (18-km) global data. 

The 12-km southeastern CONUS domain was based on the 2 min (~4-km) data. The 4-km Gulf of 

Mexico OCS region domain was based on the 30-sec (~900-m) data.
Air Quality: WRF Model Performance F-9 

F.2.3.3 Vegetation Type and Land Use Inputs

Vegetation type and land-use information was developed using the U.S. Department of the 

Interior, Geological Survey (USGS) land-use database from the most recently released WRF 

databases provided with the WRF distribution. The number of land categories in input data was the 

USGS default of 24. Standard WRF surface characteristics corresponding to each land-use 

category were employed.

F.2.3.4 Atmospheric Data Inputs

The WRF relies on some other model or re-analysis output to provide initial and boundary 

conditions (IC/BC). Sensitivity tests were performed on several datasets to evaluate their 

effectiveness over the Gulf of Mexico. The datasets tested include the ERA-Interim reanalysis 

product, available from the European Center for Medium-range Weather Forecasting (ECMWF) Data 

Portal website; the Climate Forecast System Reanalysis (CFSR, ended in 2010), and the Climate 

Forecast System model version 2 (CFSv2, after 2010) (Saha et al., 2014); and the 12-km North 

American Model (NAM) archives available from the National Climatic Data Center (NCDC) NOMADS 

server. 

The NAM dataset was chosen for the lowest bias and error in model performance and was 

used as first guess fields for WRF. This dataset was objectively re-analyzed using traditional 

observation site data (meteorological towers) to the higher resolution of each WRF grid, using the 

OBSGRID program. These fields are then used both to initialize the model and to conduct analysis 

nudging to guide the model to best match the observations.

F.2.3.5 Time Integration

Adaptive time stepping was used to maximize the time step that the model can use while 

keeping the model numerically stable. The model time step was adjusted based on the domain-wide 

horizontal and vertical stability Courant-Friedrichs-Lewy (CFL) target value of 0.8.

F.2.3.6 Diffusion Options

Horizontal Smagorinsky first-order closure (km_opt = 4) with sixth-order numerical diffusion 

and suppressed up-gradient diffusion (diff_6th_opt = 2) was used.

F.2.3.7 Lateral Boundary Conditions

Lateral boundary conditions were specified from the initialization dataset on the 36-km 

domain with continuous updates nested from the 36-km domain to the 12-km domain and from the 

12-km domain to the 4-km domain, using one-way nesting (feedback = 0). 
F-10 Gulf of Mexico Multisale EIS

F.2.3.8 Top and Bottom Boundary Conditions

The top boundary condition was selected as an implicit Rayleigh dampening for the vertical 

velocity. Consistent with the model application for non-idealized cases, the bottom boundary 

condition was selected as physical, not free-slip.

F.2.3.9 Sea-Surface Temperature Inputs

High-resolution, sea-surface temperature (SST) inputs aid in improving meteorological 

conditions for the over-water portions of the Gulf of Mexico OCS region. The Fleet Numerical 

Meteorology and Oceanography Center (FNMOC) dataset, available from the Global Ocean Data 

Assimilation Experiment (GODAE) archives, was selected after extensive testing of several SST 

databases. The FNMOC high-resolution database is updated every 6 hours using satellite-derived 

(AVHRR) SST and in-situ SST from ships and buoys with resolutions, ranging from 12 km at the 

equator to 9 km at the mid-latitudes. The FNMOC SST database was chosen for the lowest SST 

bias and error in model performance evaluation tests, which used open water observations from the 

National Data Buoy Center (NDBC) archives. 

F.2.3.10 FDDA Data Assimilation

The WRF was created as a forecast tool, but it can also be applied in “hindcast” mode. In 

forecast mode, the initial conditions for a run might be the most recent analysis (a gridded version of 

the current state of the atmosphere). In hindcast mode, we know the state of the atmosphere both 

at the beginning and end of (and during) the WRF run. Using these 6-hourly analyses, an extra error 

term is introduced into the WRF equations, nudging the WRF atmosphere toward the real 

atmosphere. This is known as Four Dimensional Data Assimilation (FDDA) or analysis nudging and 

is applied to every grid cell in the domain. It works best at larger grid spacing scales and for larger 

domains.

Observational nudging is the process of nudging just the single grid cell toward a single-point 

observation. The observation could be taken at a traditional meteorological tower or by a weather 

balloon or other non-traditional sources. Observation nudging works best at finer grid spacing 

scales and could have been performed on higher resolution domains using the Meteorological 

Assimilation Data Ingest System (MADIS) observation archive.

The WRF model was run with analysis nudging and no observation nudging. For winds and 

temperature, analysis nudging coefficients of 5x10-4 and 3.0x10-4 were used on the 36- and 12-km 

domains, respectively. For mixing ratio, an analysis nudging coefficient of 1.0x10-5 was used for 

both the 36- and 12-km domains. Analysis nudging of winds was applied both at near the surface 

and aloft, but nudging for temperature and mixing ratio was not performed in the lower atmosphere 

(i.e., within the boundary layer). 

Significant sensitivity testing was used to evaluate impacts of observational nudging on the 

4-km domain. The observational nudging coefficients for winds were tested at values set from 0 to 
Air Quality: WRF Model Performance F-11

1.2x10-3 with a radius of influence at 50 km. Ramboll Environ concluded that any observational 

nudging coefficient for winds above zero caused excessive convection in the offshore portions of the 

Gulf of Mexico, resulting in an extreme overstatement of precipitation. Additionally, humidity nudging 

was tested at values ranging from 0 to 1.0x10-5. The lower nudging values also prevented excess 

moisture in the model, primarily through the summer months. Setting wind, temperature, and 

moisture coefficients all to zero produced the most accurate precipitation results and are very similar 

to the nudging used in the USEPA 2011 CONUS WRF dataset (Gilliam and Pleim, 2010). 

F.2.3.11 WRF Physics Options

The WRF model contains many different physics options. Model tests for the months of 

January and July 2012 were performed to evaluate various cumulus parameterizations, times 

between radiation physics calls, and land surface models to achieve the best WRF performance in 

the dataset. Table F-4 lists the BOEM Gulf of Mexico OCS Region WRF physics options.

Table F-4. BOEM Gulf of Mexico OCS Region WRF Physics Options. 

Option Scheme Notes

Microphysics Thompson State-of-the-art microphysics model

Longwave Radiation RRTMG

Rapid Radiative Transfer Model for GCMs 

includes random cloud overlap and 

improved efficiency over RRTM.

Shortwave Radiation RRTMG Same as above, but for shortwave 

radiation.

Land Surface Model 

(LSM) Noah Four-layer scheme with vegetation and sub-grid tiling.

Planetary Boundary 

Layer (PBL) scheme YSU

Yonsie University (Korea) Asymmetric 

Convective Model with non-local upward 

mixing and local downward mixing.

Cumulus 

Parameterization

Kain-Fritsch in the 36-km and 

12-km domains.

Deep and shallow convection sub-grid 

scheme using a mass flux approach with 

downdrafts and CAPE removal time scale.

Analysis Nudging

Nudging applied to winds, 

temperature and moisture in the 

36-km and 12-km domains.

Temperature and moisture nudged above 

PBL only.

Observation Nudging No nudging applied

Surface wind and moisture observational 

nudging can induce excessive convection, 

leading to increased rainfall.

Surface Layer Revised MM5 Monin-Obukhov 

scheme In conjunction with YSU PBL scheme.

F.2.3.12 WRF Application Methodology

The WRF model was executed in 5-day blocks initialized at 12Z every 5 days for calendar 

year 2012. Model results are output every 60 minutes and output files are split at 12-hour intervals. 

Twelve (12) hours of spin-up were included in each 5-day block before the data were used in the 

subsequent evaluation. 
F-12 Gulf of Mexico Multisale EIS

F.3 WRF MODEL PERFORMANCE EVALUATION RESULTS

A quantitative and qualitative evaluation of the BOEM Gulf of Mexico OCS Region WRF 

simulation was conducted. The quantitative evaluation compared integrated surface hourly 

meteorological observations and offshore buoy observations with WRF predictions matched by time 

and location. The qualitative evaluation compared twice daily vertical profiles with upper-air data 

with WRF predictions matched by time and location and wind roses of coastal sites. Additionally, 

monthly and daily total spatial precipitation fields based on observations and satellite were compared 

with the WRF gridded monthly and daily total precipitation fields. Below, we summarize the main 

features of the WRF simulation model performance evaluation.

F.3.1 Quantitative Evaluation Using Metstat

A quantitative model performance evaluation of the BOEM Gulf of Mexico OCS Region WRF 

simulation was performed using integrated hourly surface and on-site meteorological measurements 

and the publicly available METSTAT software (Ramboll Environ, 2015) evaluation tool. METSTAT 

calculates statistical performance metrics for bias, error and correlation for surface winds, 

temperature, and mixing ratio (i.e., water vapor or humidity). To evaluate the performance of a 

meteorological model simulation for air quality model applications, a number of performance 

benchmarks for comparison are typically used. Table F-5 lists the meteorological model 

performance benchmarks for simple (Emery et al., 2001) and complex (Kemball-Cook et al., 2005) 

situations. The simple benchmarks were developed by analyzing well-performing meteorological 

model evaluation results for simple, mostly flat terrain conditions and simple meteorological 

conditions (e.g., stationary high pressure) that were mostly conducted to support air quality modeling 

studies (e.g., ozone SIP modeling). The complex benchmarks were developed during the Western 

Regional Air Partnership (WRAP) regional haze modeling and are performance benchmarks for 

more complex conditions, such as the complex terrain of the Rocky Mountains and Alaska (KemballCook et al., 2005). McNally (2009) analyzed multiple annual runs that included complex terrain 

conditions and suggested an alternative set of benchmarks for temperature under more complex 

conditions. The purpose of the benchmarks is to understand how good or poor the results are 

relative to other model applications run for the U.S. 

In this section, Ramboll Environ compare the WRF meteorological variables to the 

benchmarks as an indication of the BOEM Gulf of Mexico OCS Region WRF model performance. 

These benchmarks include bias and error in temperature, wind direction, and mixing ratio, as well as 

the wind speed bias and Root Mean Squared Error (RMSE) between the models and databases.

Table F-5. Meteorological Model Performance Benchmarks for Simple and Complex Conditions. 

Parameter Emery et al. (2001) Kemball-Cook et al. (2005) McNally (2009)

Conditions Simple Complex Both

Temperature Bias ≤ ±0.5 K ≤ ±2.0 K ≤ ±1.0 K

Temperature Error ≤ 2.0 K ≤ 3.5 K ≤ 3.0 K

Temperature IOA ≥ 0.8 (not addressed) (not addressed)

Humidity Bias ≤ ±1.0 g/kg ≤ ±0.8 g/kg ≤ ±1.0 g/kg
Air Quality: WRF Model Performance F-13

Parameter Emery et al. (2001) Kemball-Cook et al. (2005) McNally (2009)

Humidity Error ≤ 2.0 g/kg ≤ 2.0 g/kg ≤ 2.0 g/kg

Humidity IOA ≥ 0.6 (not addressed) (not addressed)

Wind Speed Bias ≤ ±0.5 m/s ≤ ±1.5 m/s (not addressed)

Wind Speed RMSE ≤ 2.0 m/s ≤ 2.5 m/s (not addressed)

Wind Speed IOA ≥ 0.6 (not addressed) (not addressed)

Wind Dir. Bias ≤ ±10 degrees (not addressed) (not addressed)

Wind Dir. Error ≤ 30 degrees ≤ 55 degrees (not addressed)

The output from the BOEM Gulf of Mexico OCS Region WRF simulation was compared 

against the NCDC’s global-scale, quality-controlled DS3505 integrated surface hourly observational 

(ISHO) data (USDOC, NOAA, NCDC, 2015) and the NDBC’s buoy database (USDOC, NOAA, 

NDBC, 2015) as verification data. Global hourly and synoptic observations are compiled from 

numerous sources into a single common ASCII format and common data model. The DS3505 

database contains records of most official surface meteorological stations from airports, military 

bases, reservoirs/dams, agricultural sites, and other sources dating from 1901 to the present, and 

quality control has corrected well over 99% of the errors present in the original data. The NDBC 

database contains records of moored buoys, coastal-marine automated network stations, and other 

sources dating from 1970 to the present.

F.3.1.1 Quantitative Statistics

Several statistical measures are calculated as part of the meteorological model evaluation. 

Additional plots and graphs are used to present these statistics on both hourly and daily timeframes. 

These measures are calculated for wind speed, wind direction, temperature, and humidity at the 

surface. The various statistical measures used for this evaluation are described below. 

The statistics used to evaluate meteorological model performance are all given in absolute 

terms (e.g., wind speed error in meters per second [m/s]) rather than in relative terms (percent error) 

as is commonly shown for air quality assessments. The major reason for this is that a very different 

significance is associated with a given relative error for different meteorological parameters. For 

example, a 10 percent error for wind speed measured at 10 m/s is an absolute error of 1 m/s, a 

minor error. Yet a 10 percent error for temperature at 300 K is an absolute error of 30 K, an 

unacceptably large error. On the other hand, pollutant concentration errors of 10 percent at 1 ppb or 

10 ppm carry practically the same significance.

Statistical Measures

Mean Observation (Mo): Calculated from all sites with valid data within a given analysis region and 

for a given time period (hourly or daily):
F-14 Gulf of Mexico Multisale EIS

∑∑= =

=

J

j

I

i

i

o Oj IJ

M

1 1

1

where Oi

j is the individual observed quantity at site i and time j, and the summations are over all 

sites (I) and over time periods (J).

Mean Prediction (Mp): Calculated from simulation results that are interpolated to each observation 

used to calculate the mean observation (hourly or daily):

∑∑= =

=

J

j

I

i

i

p Pj IJ

M

1 1

1

where Pi

j is the individual predicted quantity at site i and time j. Note that mean observed and 

predicted winds are vector-averaged (for east-west component u and north-south component v), 

from which the mean wind speed and mean resultant direction are derived. 

Least Square Regression: Performed to fit the prediction set to a linear model that describes the 

observation set for all sites with valid data within a given analysis region and for a given time 

period (daily or episode). The y-intercept a and slope b of the resulting straight line fit is 

calculated to describe the regressed prediction for each observation:

i

j

i

j += bOaP

The goal is for a 1:1 slope and a “0” y-intercept (no net bias over the entire range of 

observations), and a regression coefficient of 1 (a perfect regression). The slope and intercept 

facilitate the calculation of several error and skill statistics described below.

Bias Error (B): Calculated as the mean difference in prediction-observation pairings with valid data 

within a given analysis region and for a given time period (hourly or daily):

∑∑( ) = =

= −

J

j

I

i

i

j

i

j OP

IJ

B

1 1

1

Gross Error (E): Calculated as the mean absolute difference in prediction-observation pairings with 

valid data within a given analysis region and for a given time period (hourly or daily):

∑∑= =

= −

J

j

I

i

i

j

i

j OP

IJ

E

1 1

1

Note that the bias and gross error for winds are calculated from the predicted-observed residuals 

in speed and direction (not from vector components u and v). The direction error for a given 

prediction-observation pairing is limited to range from 0 to 180.

Root Mean Square Error (RMSE): Calculated as the square root of the mean squared difference in 

prediction-observation pairings with valid data within a given analysis region and for a given time 

period (hourly or daily):
Air Quality: WRF Model Performance F-15

( )

2/1

1 1

1 2





 



 = ∑∑ − = =

J

j

I

i

i

j

i

j OP

IJ

RMSE

The RMSE, as with the gross error, is a good overall measure of model performance. However, 

since large errors are weighted heavily (due to squaring), large errors in a small sub-region may 

produce a large RMSE even though the errors may be small and quite acceptable elsewhere.

It is important that RMSE is analyzed. For example, if only RMSE is estimated (and it 

appears acceptable), it could consist largely of the systemat¬ic component. This error might be 

removed through improvements in the model inputs or use of more appropriate options, thereby 

reducing the error transferred to the photochemical model. On the other hand, if the RMSE consists 

largely of the unsystematic component, this indicates that further error reduction may require model 

refinement (new algorithms, higher resolution grids, etc.) or that the phenomena to be replicated 

cannot be fully addressed by the model. It also provides error bars that may be used with the inputs 

in subsequent sensitivity analyses.

F.3.1.2 METSTAT Evaluation Using Integrated Surface Hourly Observations and Offshore 

Buoy Observations

The METSTAT results for 2012 are presented in Figures F-5 through F-16. The WRF wind 

direction performed very well, with the majority of months falling within the simple conditions 

threshold for all spatial domains (36, 12, and 4 km). For all domains, WRF wind speed, temperature, 

and humidity also performed very well. For most months, there are slight positive biases in wind 

speed and humidity in all three spatial domains. Overall, the WRF model performed exceptionally 

well in the 36- and 12-km domains and well in the 4-km domain for onshore surface wind direction, 

wind speed, humidity and temperature observation comparisons. 

METSTAT was also used to evaluate WRF performance in the innermost 4-km domain using 

observations from meteorological buoys throughout the Gulf of Mexico for 2012. Overall, WRF wind 

direction performed well with over half of all months falling with the simple conditions benchmark. 

Wind speed performance was acceptable with all months falling within the complex conditions 

benchmark. Temperature bias and error is slightly higher (warmer) in the winter months compared 

to the summer months, suggesting that the model is over-forecasting surface temperatures, or is an 

influence from the SST database input to WRF. Humidity performed well with a majority of months, 

falling within the simple conditions benchmark. In general, the offshore METSTAT evaluation is very 

similar to the onshore evaluation, suggesting consistent performance over both the land and sea 

portions of the Gulf of Mexico OCS region. 
F-16 Gulf of Mexico Multisale EIS

Figure F-5. BOEM Gulf of Mexico OCS Region WRF 36-km METSTAT Wind Direction 

Performance for 2012. 

Figure F-6. BOEM Gulf of Mexico OCS Region WRF 36-km METSTAT Wind Speed 

Performance for 2012. 
Air Quality: WRF Model Performance F-17

Figure F-7. BOEM Gulfof Mexico OCS Region WRF 36-km METSTAT Temperature 

Performance for 2012. 

Figure F-8. BOEM Gulf of Mexico OCS Region WRF 36-km METSTAT Humidity Performance 

for 2012. 
F-18 Gulf of Mexico Multisale EIS

Figure F-9. BOEM Gulf of Mexico OCS Region WRF 12-km METSTAT Wind Direction 

Performance for 2012. 

Figure F-10. BOEM Gulf of Mexico OCS Region WRF 12-km METSTAT Wind Speed 

Performance for 2012. 
Air Quality: WRF Model Performance F-19

Figure F-11. BOEM Gulf of Mexico OCS Region WRF 12-km METSTAT Temperature 

Performance for 2012. 

Figure F-12. BOEM Gulf of Mexico OCS Region WRF 12-km METSTAT Humidity Performance 

for 2012. 
F-20 Gulf of Mexico Multisale EIS

Figure F-13. BOEM Gulf of Mexico OCS Region WRF 4-km METSTAT Wind Direction 

Performance for 2012. 

Figure F-14. BOEM Gulf of Mexico OCS Region WRF 4-km METSTAT Wind Speed Performance 

for 2012. 
Air Quality: WRF Model Performance F-21

Figure F-15. BOEM Gulf of Mexico OCS Region WRF 4-km METSTAT Temperature 

Performance for 2012. 

Figure F-16. BOEM Gulf of Mexico OCS Region WRF 4-km METSTAT Humidity Performance for 

2012. 
F-22 Gulf of Mexico Multisale EIS

F.3.2 Qualitative Evaluation Using Wind Roses

The coastal sites of Gulfport, MS (KGPT); Naples, FL (NPSF); Port Isabel, TX (PTIT); and 

Calcasieu, LA (CAPL) were chosen to evaluate the frequency and intensity of onshore and offshore 

wind flow and WRF’s performance at the land-sea interface. The locations of these sites are shown 

in Figure F-17. The 5-year comparisons of observed and modeled wind direction at each coastal 

site will be provided in the full WRF modeling report. Below, in Figures F-17 through F-21, the 

comparisons are made for only 2012. Wind direction observations were obtained from the DS3505 

meteorological dataset, and modeled surface wind speed and wind direction were extracted from the 

4-km WRF domain dataset using the Mesoscale Model Interface (MMIF) program (Brashers and 

Emery, 2015). Overall, WRF performs just satisfactorily at forecasting the frequency and intensity of 

onshore and offshore wind flow at the coastal sites. The WRF simulates the predominant NE wind 

direction at NPSF, as well as the strong SE winds at port PTIT and CAPL. However, WRF wind 

direction does not compare particularly well to KGPT in 2012 and does not replicate much of the NW 

wind at PTIT, or the SW wind at NPSF. The decline in apparent wind direction performance for 

2012, compared to the 5-year analysis, is largely due to the shorter evaluation period.

Figure F-17. Wind Rose Locations for Port Isabel, TX (PTIT), Calcasieu, LA (CAPL), Gulfport, MS 

(KGPT), and Naples, FL (NPSF). 
Air Quality: WRF Model Performance

F-23

Figure F-18. 2012 WRF Wind Rose (left) Compared to 2012 Observation Wind Rose from Gulfport, MS (right) in 4-km Domain. 
F-24 Gulf of Mexico Multisale EIS

Figure F-19. 2012 WRF Wind Rose (left) Compared to 2012 Observation Wind Rose from Naples, FL (right) in 4-km Domain. 
Air Quality: WRF Model Performance

F-25

Figure F-20. 2012 WRF Wind Rose (left) Compared to 2012 Observation Wind Rose from Port Isabel, TX (right) in 4-km Domain. 
F-26 Gulf of Mexico Multisale EIS

Figure F-21. 2012 WRF Wind Rose (left) Compared to 2012 Observation Wind Rose from Calcasieu, LA (right) in 4-km Domain. 
Air Quality: WRF Model Performance F-27

F.3.3 Qualitative Evaluation Using Upper-Air Data

Plots of the sounding profiles of temperature and dew point for the vertical atmosphere were 

created using observational data from the Brownsville, TX (KBRO) and Key West, FL (KEYW) 

airports and the corresponding WRF data points. A random selection of upper air profiles was taken 

from the year-long dataset for a sampling of several different atmospheric situations. These are 

qualitatively compared, paying particular attention to how well the WRF model reproduces the 

observed near-surface inversion layers.

The KBRO and KEYW radiosonde datasets are collected by and maintained by the National 

Weather Service (NWS). Radiosondes are launched twice per day, at approximately 00 and 

12 UTC. Radiosondes provide high-resolution vertical profiles of temperature, humidity, wind speed, 

and wind direction throughout the troposphere. The data are made publicly available by NOAA’s 

Earth System Research Laboratory (USDOC, NOAA, ESRL, 2015). Ramboll Environ downloaded 

and stored the radiosonde data twice daily for 2012 for each upper air station in FSL format for use 

in WRF model dataset comparisons. 

For the qualitative analysis, Figure F-22 shows the vertical profiles of temperature and 

humidity from the observational and 4 km WRF datasets for Brownsville, TX and Key West, FL. The 

analysis focuses on how well the WRF model reproduces the vertical atmosphere structure using 

upper air observations from the selected sites within the 4-km domain, which have timeframes that 

overlap with the WRF model. The left panel in Figure F-22 shows an evening sounding in August 

for Brownville, TX, which contains a weak elevated subsidence inversion. The WRF forecasts the 

base of the inversion well at around 900 meters. The right panel of Figure F-22 shows observed 

and modeled vertical profiles for January in Key West, FL. The WRF forecasts the elevated 

subsidence inversion well, with a mixing height top at around 1,000 meters on the left panel. The 

dry air above the inversion is also represented well in the evening sounding at Key West, FL. 
F-28 Gulf of Mexico Multisale EIS

Figure F-22. Vertical Profile Soundings Comparing the 4-km WRF (blue lines) to Upper-Air Observations Data (red lines) for 

Brownsville, TX on August 3, 2012, and Key West, FL on January 4, 2012, at 00 UTC. 
Air Quality: WRF Model Performance F-29

F.3.4 Qualitative Evaluation Using Precipitation

Precipitation removes chemicals and particulates from the air via wet deposition, and thus is 

an important parameter for high-quality dispersion modeling. Several precipitation datasets were 

evaluated for use in model comparisons. Ramboll Environ has used the Parameter-elevation 

Regressions on Independent Slopes Model (PRISM) dataset for rainfall extensively in the past, but it 

only covers the over-land portion of the modeling domain. Land-based RADAR retrievals of 

precipitation typically have larger uncertainty and are limited in geographic coverage to the area 

relatively near the coast and, as a result, were not chosen for this performance evaluation. Satellitebased retrievals are typically lower resolution and also feature larger uncertainty, but cover the entire 

Gulf of Mexico OCS region. Ramboll Environ performed comparisons between the BOEM Gulf of 

Mexico OCS Region WRF modeled precipitation output with the PRISM and Tropical Rainfall 

Measurements Mission (TRMM) satellite datasets.

The Oregon State University PRISM Climate Group gathers temperature and precipitation 

data from a range of monitoring networks, applies sophisticated quality control methods, and uses 

the data to produce spatial grids of climate parameters (Daly et al., 2008). The time series datasets 

are modeled using climatologically-aided interpolation (CAI), which uses the long-term average 

pattern as first-guess of the spatial pattern of climatic conditions. Both a daily product and a monthly 

product are available. The precipitation observations used in the daily PRISM product includes 

radar measurements, which the monthly product does not take into account. This may cause 

dramatic local differences between the two datasets in monthly totals.

TRMM was a joint mission being flown by the National Aeronautics and Space 

Administration (NASA, U.S.) and the Japan Aerospace Exploration Agency (JAXA, Japan) to 

improve our quantitative knowledge of the 3-dimensional distribution of precipitation in the tropics. 

TRMM had a passive microwave radiometer (TRMM Microwave Imager, TMI), the first active spaceborne Precipitation Radar (PR), a Visible-Infrared Scanner (VIRS), and other instruments. 

Coordinated observations are intended to result in a "flying raingauge" capability. The TRMM 

dataset is coarser than the PRISM data (0.5 degrees, or about 55 km, vs. 4km) but is available every 

3 hours.

F.3.4.1 Evaluation Over Land Using PRISM Precipitation

High-resolution (4 km) PRISM datasets cover the contiguous U.S. in both monthly and daily 

output versions (Daly et al., 2008). Here WRF precipitation output is compared to the PRISM overland portions of the Gulf of Mexico. Ramboll Environ re-projected and aggregated the PRISM data 

to the WRF projection’s grid cell locations, and the resulting gridded data was plotted and the 

gridded fields saved. This allows for consistent visual qualitative comparison. 

The full WRF modeling report will display 5-year average (2010-2014) monthly precipitation 

plots constructed from BOEM Gulf of Mexico OCS Region WRF output, masked to only display overland measurements, and compared to PRISM 5-year average (2010-2014) monthly plots for January 

through December in the 4-km domain. Below, WRF monthly precipitation totals are compared to 
F-30 Gulf of Mexico Multisale EIS

corresponding PRISM totals for 2012 only. The results are mostly representative of the 5-year 

monthly averages and are briefly summarized in the following paragraph. 

For the months of January through March, shown in Figures F-23 through F-25, WRF 

represents the spatial extent of the precipitation well, recreating the comparatively drier areas of 

central Texas and southern Florida. However, the model does under-estimate the total amount of 

average monthly rainfall across a small portion of southern Mississippi and south central Louisiana 

during this period. In April and May, Figures F-26 and F-27, the model shifts to overestimating 

rainfall in the same region, but otherwise depicts both the spatial distribution and amount of 

precipitation well over land, compared to PRISM. During the summer months of June through 

August, shown in Figures F-28 through F-30, WRF performs exceptionally well in re-creating the 

precipitation extent across the land portions of the domain, including the convergence zones across 

the east and west coasts of Florida. The model does slightly over-predict the amount of rainfall 

accumulations in the southern Georgia and southern Alabama areas. This is likely due to the higher 

humidity rates in the model during the summertime period. In September, shown in Figure F-31, 

WRF slightly under-predicts averaged precipitation rates over the land portion of the domain but 

over-forecasts the extent of rainfall over the northern Florida area. The WRF performed 

exceptionally well from October through December, shown in Figures F-32 through F-34, 

reproducing the extent and amount of rainfall very accurately, compared to PRISM totals. Overall, 

WRF performed very well in reproducing the spatial extent of precipitation over the land portions of 

Gulf of Mexico OCS region throughout 2012.
Air Quality: WRF Model Performance F-31

Figure F-23. January 2012 PRISM Precipitation (top) and WRF Precipitation (bottom), 4-km Domain. 
F-32 Gulf of Mexico Multisale EIS

Figure F-24. February 2012 PRISM Precipitation (top) and WRF Precipitation (bottom), 4-km Domain. 
Air Quality: WRF Model Performance F-33

Figure F-25. March 2012 PRISM Precipitation (top) and WRF Precipitation (bottom), 4-km Domain. 
F-34 Gulf of Mexico Multisale EIS

Figure F-26. April 2012 PRISM Precipitation (top) and WRF Precipitation (bottom), 4-km Domain. 
Air Quality: WRF Model Performance F-35

Figure F-27. May 2012 PRISM Precipitation (top) and WRF Precipitation (bottom), 4-km Domain. 
F-36 Gulf of Mexico Multisale EIS

Figure F-28. June 2012 PRISM Precipitation (top) and WRF Precipitation (bottom), 4-km Domain. 
Air Quality: WRF Model Performance F-37

Figure F-29. July 2012 PRISM Precipitation (top) and WRF Precipitation (bottom), 4-km Domain. 
F-38 Gulf of Mexico Multisale EIS

Figure F-30. August 2012 PRISM Precipitation (top) and WRF Precipitation (bottom), 4-km Domain. 
Air Quality: WRF Model Performance F-39

Figure F-31. September 2012 PRISM Precipitation (top) and WRF Precipitation (bottom), 4-km Domain. 
F-40 Gulf of Mexico Multisale EIS

Figure F-32. October 2012 PRISM Precipitation (top) and WRF Precipitation (bottom), 4-km Domain. 
Air Quality: WRF Model Performance F-41

Figure F-33. November 2012 PRISM Precipitation (top) and WRF Precipitation (bottom), 4-km Domain. 
F-42 Gulf of Mexico Multisale EIS

Figure F-34. December 2012 PRISM Precipitation (top) and WRF Precipitation (bottom), 4-km Domain. 
Air Quality: WRF Model Performance F-43

F.3.4.2 Evaluation Over Water Using Satellite Precipitation

In this analysis, WRF precipitation data are also compared to TRMM satellite precipitation 

data to assess the accuracy of the WRF precipitation. Ramboll Environ re-projected and aggregated 

the TRMM data to the WRF projection’s grid cell locations, and the resulting gridded data was 

plotted and the gridded fields saved. This allows for a consistent visual qualitative comparison, 

although the 0.5 degree (~55 km) TRMM dataset is at a lower resolution than the 4-km PRISM

dataset and as a result, the satellite precipitation fields appear much coarser in the 4-km domain. 

Additionally, near the end of the WRF modeling period, the satellite hosting the TRMM sensor ran 

out of propellant. This caused its orbit to slowly decay, casting into doubt the validity of the derived 

rainfall quantities and is the reason only a qualitative comparison is presented below. Below, 

Figures F-35 through F-46 show monthly WRF precipitation averages compared to TRMM 

precipitation averages throughout 2012 in the 12-km domain.

The WRF under-predicts precipitation over the offshore portions of the domain, compared to 

TRMM for the averaging months of January through May, as shown in Figures F-35 through F-39. 

From June through October, WRF performs well at predicting precipitation spatially and numerically, 

shown in Figures F-40 through F-44. The increased amount of rainfall over the southeast Gulf 

Coast States, stretching out over the coastlines, is well represented through the summertime 

months. The WRF slightly under-predicts the amount of rainfall in the offshore portions of the Gulf, 

compared to the TRMM precipitation averages for November and December, shown in Figures F-45

and F-46. Even with the coarse TRMM resolution, it appears the model has a slight dry bias in the 

over-water portions of the domain in the colder months. 

Given the coarser resolution of the TRMM plots, WRF tends to under-forecast precipitation 

intensity overall in the offshore portions of the Gulf throughout the winter and spring months and 

does a satisfactory job at forecasting the amount of rainfall over water in the summer and fall months 

in the 4-km domain. 
F-44 Gulf of Mexico Multisale EIS

Figure F-35. January 2012 TRMM Precipitation Average (top) and 

Corresponding WRF Precipitation Average (bottom) in the 

12-km Domain. 
Air Quality: WRF Model Performance F-45

Figure F-36. February 2012 TRMM Precipitation Average (top) and 

Corresponding WRF Precipitation Average (bottom) in the 

12-km Domain. 
F-46 Gulf of Mexico Multisale EIS

Figure F-37. March 2012 TRMM Precipitation Average (top) and 

Corresponding WRF Precipitation Average (bottom) in the 

12-km Domain. 
Air Quality: WRF Model Performance F-47

Figure F-38. April 2012 TRMM Precipitation Average (top) and 

Corresponding WRF Precipitation Average (bottom) in the 

12-km Domain. 
F-48 Gulf of Mexico Multisale EIS

Figure F-39. May 2012 TRMM Precipitation Average (top) and 

Corresponding WRF Precipitation Average (bottom) in the 

12-km Domain. 
Air Quality: WRF Model Performance F-49

Figure F-40. June 2012 TRMM Precipitation Average (top) and 

Corresponding WRF Precipitation Average (bottom) in the 

12-km Domain. 
F-50 Gulf of Mexico Multisale EIS

Figure F-41. July 2012 TRMM Precipitation Average (top) and 

Corresponding WRF Precipitation Average (bottom) in the 

12-km Domain. 
Air Quality: WRF Model Performance F-51

Figure F-42. August 2012 TRMM Precipitation Average (top) and 

Corresponding WRF Precipitation Average (bottom) in the 

12-km Domain. 
F-52 Gulf of Mexico Multisale EIS

Figure F-43. September 2012 TRMM Precipitation Average (top) and 

Corresponding WRF Precipitation Average (bottom) in the 

12-km Domain. 
Air Quality: WRF Model Performance F-53

Figure F-44. October 2012 TRMM Precipitation Average (top) and 

Corresponding WRF Precipitation Average (bottom) in the 

12-km Domain. 
F-54 Gulf of Mexico Multisale EIS

Figure F-45. November 2012 TRMM Precipitation Average (top) and 

Corresponding WRF Precipitation Average (bottom) in the 

12-km Domain. 
Air Quality: WRF Model Performance F-55

Figure F-46. December 2012 TRMM Precipitation Average (top) and 

Corresponding WRF Precipitation Average (bottom) in the 

12-km Domain. 
F-56 Gulf of Mexico Multisale EIS

F.3.4.3 Evaluation Using Tropical Cyclone Precipitation Events

In order to evaluate the accuracy of the WRF model for precipitation performance, short-term 

rainfall events were also analyzed for local and regional scale impacts. Daily precipitation plots were 

created for every 24-hour period from the WRF, PRISM and TRMM databases. Tropical cyclone 

events were chosen as each storm system typically produces a wide area of enhanced rainfall for 

both onshore and offshore areas. 

A tropical cyclone is a warm-core, non-frontal synoptic-scale cyclone, originating over 

tropical or subtropical waters, with organized deep convection and a closed surface wind circulation 

about a well-defined center (NHC, 2015). Increased rainfall events from two cyclones, Hurricane 

Isaac and Tropical Storm Debby, are presented in a qualitative comparison.

Hurricane Isaac made landfall along the coast of southern Louisiana on August 29, 2012, 

and moved northward, where it was downgraded to a tropical storm on August 30th. Daily 

precipitation plots from each dataset on August 30th are shown in Figure F-47. The WRF depicts 

the large cyclonic rotation and enhanced precipitation bands from Isaac over southeast Louisiana 

very well, compared to the PRISM dataset. Compared to TRMM, the model does appear to overforecast the rainfall intensity for this 24-hour period.

Figure F-48 shows daily precipitation plots as Tropical Storm Debby’s outer rain bands begin 

to impact Florida’s west coast on June 25, 2012. The WRF performed very well in comparison to 

both PRISM and TRMM, forecasting the spatial extent of the large storm throughout the eastern Gulf 

of Mexico. The model did slightly under-predict the rainfall accumulations in this 24-hour period, 

compared to the observational and satellite databases.

Overall, WRF performed very well in recreating the daily precipitation events in these two 

scenarios. The daily precipitation plots from each WRF, PRISM and TRMM dataset are available by 

request from Ramboll Environ.
Air Quality: WRF Model Performance F-57

Figure F-47. Daily Precipitation Plots from WRF, PRISM, and TRMM on August 30, 2012. 
F-58 Gulf of Mexico Multisale EIS

Figure F-48. Daily Precipitation Plots from WRF, PRISM, and TRMM Databases on June 25, 

2012. 
Air Quality: WRF Model Performance F-59

F.4 SUMMARY AND CONCLUSIONS

The BOEM Gulf of Mexico OCS Region WRF meteorological model simulation for January 

through December 2012 reproduced the observed surface and upper-air meteorological variables 

very well. The WRF performed exceptionally well in the onshore METSTAT analysis for the 36-km 

and 12-km domains and well in the onshore and offshore analysis for the 4-km domain, with a small 

bias in wind direction. This performance shows a very strong agreement overall between the model 

and surface observations.

Comparisons of selected wind roses along the Gulf Coast, which will be presented in the full 

WRF model evaluation, show WRF was able to forecast the offshore and onshore wind speed and 

wind direction very well in the 4-km domain. This suggests the model was able to accurately 

reproduce the land-sea breeze circulation.

Upper air performance in the 4-km (d03) domain for the two selected locations throughout 

the Gulf of Mexico reflects accurate predictions of the vertical atmosphere, as shown in comparisons 

between WRF and radiosonde data, especially in mixing layer heights and cases of surface-based 

temperature inversions.

The monthly precipitation analysis for the 4-km (d03) domain indicates there is a strong 

agreement between the model and observation-based precipitation measurements over land, 

including convergence zone and enhanced rainfall areas. The comparison with the 12-km (d02) 

WRF and satellite-based precipitation accumulations does indicate some understatement of 

precipitation over water, most notably in the winter months.

Based on our experience, the BOEM Gulf of Mexico OCS Region WRF modeling’s superior 

performance throughout 2012 provides a substantial basis for developing meteorological inputs for 

air quality modeling in the Gulf of Mexico region. 

F.5 REFERENCES

Brashers, B. and C. Emery. 2015. The Mesoscale Model Interface Program (MMIF), Version 3.2, 

2015-07-24, Draft User’s Manual. Prepared for USEPA, Office of Air Quality Planning and 

Standards. Ramboll Environ US Corporation (Ramboll Environ). Internet website: 

http://www.epa.gov/ttn/scram/models/relat/mmif/MMIFv3.2_Users_Manual.pdf. 

Brashers, B., J. Knapik, and R. Morris. 2014. Official communication. Technical memorandum 

concerning BOEM Contract No. M14PC00007, Task 2 WRF Meteorological Model Dataset 

Assessment for the Air Quality Modeling in the Gulf of Mexico Region to Holli Ensz, Bureau of 

Ocean Energy Management, Gulf of Mexico Region. Prepared by ENVIRON International 

Corporation, Lynnwood, WA.

Daly, C., M. Halbleib, J.I. Smith, W.P. Gibson, M.K. Doggett, G.H. Taylor, J. Curtis, and 

P.P. Pasteris. 2008. Physiographically sensitive mapping of climatological temperature and 

precipitation across the conterminous United States. International Journal of Climatology. 
F-60 Gulf of Mexico Multisale EIS

Internet website: http://prism.nacse.org/documents/Daly2008_PhysiographicMapping_

IntJnlClim.pdf. 

Emery, C.A., E. Tai, and G. Yarwood. 2001. Enhanced Meteorological Modeling and Performance 

Evaluation for Two Texas Ozone Episodes. Prepared for the Texas Natural Resource 

Conservation Commission (now TCEQ) by ENVIRON International Corp, Novato, CA. Internet 

website: http://www.tceq.texas.gov/assets/public/implementation/air/am/contracts/reports/mm/

EnhancedMetModelingAndPerformanceEvaluation.pdf. 

Gilliam, R.C. and J.E. Pleim. 2010. Performance assessment of new land-surface and planetary 

boundary layer physics in the WRF-ARW. Journal of Applied Meteorology and Climatology 49, 

760-774.

Kemball-Cook, S., Y. ia, C. Emery, and R. Morris. 2005. Alaska MM5 Modeling for the 2002 

Annual Period to Support Visibility Modeling. Prepared for the Western Regional Air Partnership, 

by ENVIRON International Corp., Novato, CA. Internet website: http://pah.cert.ucr.edu/

aqm/308/docs/alaska/Alaska_MM5_DraftReport_Sept05.pdf. 

McNally, D.E. 2009. 12 km MM5 Performance Goals. Presentation to the Ad-Hoc Meteorology 

Group. June 25, 2009. Internet website: http://www.epa.gov/scram001/adhoc/mcnally2009.pdf. 

NCAR. 2015. National Center for Atmospheric Research. Retrieved from 

http://www2.mmm.ucar.edu/wrf/users/download/get_source.html. 

Ramboll Environ US Corp. 2015. METSTAT. Internet website: http://www.camx.com/download/

support-software.aspx. 

Saha, S., S. Moorthi, X. Wu, J. Wang, S. Nadiga, P. Tripp, D. Behringer, Y-T. Hou, H-y. Chuang, 

M. Iredell, M. Ek, J. Meng, R. Yang, M. Peña Mendez, H. van den Dool, Q. Zhang, W. Wang, 

M. Chen, and E. Becker. 2014. The NCEP Climate Forecast System Version 2. Journal of 

Climate 27, 2185-2208. doi:http://dx.doi.org/10.1175/JCLI-D-12-00823.1. 

SCAS-OSU. 2001. Climate Mapping with PRISM. Oregon State University (OSU)

U.S.Dept. of Commerce, National Oceanic and Atmospheric Administration, Earth System Research 

Laboratory. 2015. NOAA/ESRL Radiosonde Database. Internet website: 

www.esrl.noaa.gov/raobs. 

U.S. Dept. of Commerce, National Oceanic and Atmospheric Administration, National Climatic Data 

Center. 2014. NOAA NCDC Integrated Surface Database. Internet website: 

www.ncdc.noaa.gov/isd. 
APPENDIX G 

 

AIR QUALITY: 

EMISSIONS FOR THE CUMULATIVE AND VISIBILITY IMPACTS

Table of Contents G-iii

TABLE OF CONTENTS

Page

G.1 INTRODUCTION ...................................................................................................................... G-1

G.2 DEVELOPMENT OF EMISSION INVENTORIES.................................................................... G-4

G.2.1 Pollutants...................................................................................................................... G-5

G.2.2 Base Case Year........................................................................................................... G-5

G.2.3 Geographical Domain .................................................................................................. G-5

G.2.4 Inventory Sources ........................................................................................................ G-6

G.2.5 Spatial Resolution ........................................................................................................ G-8

G.2.6 Temporal Resolution.................................................................................................... G-8

G.2.7 Speciation..................................................................................................................... G-8

G.3 BASE CASE EMISSION ESTIMATES..................................................................................... G-8

G.3.1 Point Sources............................................................................................................... G-8

G.3.2 Nonpoint Area Sources................................................................................................ G-9

G.3.3 Mobile Sources............................................................................................................. G-9

G.3.4 Offshore Helicopters .................................................................................................. G-10

G.3.5 Offshore Oil and Gas Production Sources—Western and Central/Eastern 

Planning Areas in the Gulf of Mexico......................................................................... G-10

G.3.6 Offshore Vessels........................................................................................................ G-13

G.3.6.1 Oil and Gas Production Support Vessels................................................... G-14

G.3.6.2 Non-oil and Gas Production Offshore Vessels .......................................... G-17

G.3.7 Biogenic and Geogenic Sources................................................................................ G-19

G.3.8 Sources In Mexico...................................................................................................... G-19

G.3.9 Sources In Canada .................................................................................................... G-19

G.4 FUTURE YEAR MODELING SCENARIO EMISSION ESTIMATES ..................................... G-19

G.4.1 Western, Central, and Eastern Planning Areas OCS Offshore Oil and Gas 

Production Sources.................................................................................................... G-20

G.4.1.1 Oil and Natural Gas Offshore Production Platforms .................................. G-21

G.4.1.2 Offshore Support Helicopters..................................................................... G-22

G.4.1.3 Oil and Gas Production Offshore Support Vessels.................................... G-22

G.4.1.4 Future Year Emission Estimates and Selection of Future Modeling 

Year ............................................................................................................ G-24

G.4.1.5 Spatial Allocation........................................................................................ G-28

G.4.2 Onshore Sources and Marine Vessels ...................................................................... G-30

G.4.3 Other Sources ............................................................................................................ G-30

G.5 SOURCE APPORTIONMENT................................................................................................ G-31

G.6 REFERENCES ....................................................................................................................... G-32

List of Tables G-v 

LIST OF TABLES

Page

Table G-1. Nonattainment and Maintenance Areas in the Southeastern U.S. ............................... G-3

Table G-2. Gulf of Mexico Air Quality Modeling Study Source Categories..................................... G-7

Table G-3. Base Case Offshore Oil and Gas Production Source Emissions Estimates for 

the Western and Central/Eastern Planning Areas in the Gulf of Mexico.................... G-10

Table G-4. Future Year Production Platform Emission Factors.................................................... G-21

Table G-5. Summary of Vessel Characteristics ............................................................................ G-23

Table G-6. Load Factors to be Used in the Future Year Projections............................................ G-24

Table G-7. Marine Vessel Emission Factors (g/kW-hr)................................................................. G-24

Table G-8. Emission Estimates for Western, Central, and Eastern Planning Areas, All 

Depths, By Year and Pollutant .................................................................................... G-25

Table G-9. Emission Estimates for Western, Central, and Eastern Planning Areas, 

Emissions Estimations for Western, Central, and Eastern Planning Areas, All 

Depths, By Year and Pollutant .................................................................................... G-26

LIST OF FIGURES

Page

Figure G-1. Location of the “Air Quality Modeling in the Gulf of Mexico Region” Study, with 

Class I Areas and Platform Locations......................................................................... G-1

Figure G-2. Ozone Nonattainment Areas in the Southeastern U.S............................................... G-2

Figure G-3. Overview of the “Air Quality Modeling in the Gulf of Mexico Region” Study 

Tasks........................................................................................................................... G-4

Figure G-4. WRF 36-km CONUS (d01), 12-km SE Regional (d02), and 4-km Gulf of 

Mexico (d03) Domains Along With the PGM Grids .................................................... G-6

Figure G-5. 2012 Platform NOx Emissions Aggregated by Lease Block..................................... G-11

Figure G-6. 2012 Platform VOC Emissions Aggregated by Lease Block.................................... G-12

Figure G-7. 2012 Platform PM2.5 Emissions Aggregated by Lease Block................................... G-13

Figure G-8. 2012 Non-platform NOx Emissions ........................................................................... G-15

Figure G-9. 2012 Non-platform VOC Emissions.......................................................................... G-16

Figure G-10. 2012 Non-platform PM2.5 Emissions......................................................................... G-17

Figure G-11. Emission Estimates for all Planning Areas and Future Activities ............................. G-27

Figure G-12. Combined Annual NOx Emissions............................................................................. G-27

Figure G-13. Combined Annual VOC Emissions ........................................................................... G-28

Figure G-14. Combined Annual PM2.5 Emissions .......................................................................... G-28

Figure G-15. BOEM OCS Planning Areas and Water Depths....................................................... G-29

Air Quality: Emissions for the Cumulative and Visibility Impacts G-1 

G AIR QUALITY: EMISSIONS FOR THE CUMULATIVE AND 

VISIBILITY IMPACTS

G.1 INTRODUCTION

The U.S. Department of the Interior’s Bureau of Ocean Energy Management (BOEM) is 

required under the Outer Continental Shelf Lands Act (OCSLA) (43 U.S.C. § 1334(a)(8)) to comply 

with the National Ambient Air Quality Standards (NAAQS) to the extent that Outer Continental Shelf 

(OCS) offshore oil and gas exploration, development, and production sources do not significantly 

affect the air quality of any state. The Gulf of Mexico OCS Region’s OCS area of possible influence 

includes the States of Texas, Louisiana, Mississippi, Alabama, and Florida. BOEM’s Gulf of Mexico

OCS Region manages the responsible development of oil, gas, and mineral resources for the 

430 million acres in the Western, Central, and Eastern Planning Areas on the OCS comprising the 

Gulf of Mexico OCS Region, including the areas under moratoria (shown in Figure G-1). The Clean 

Air Act Amendments (CAAA) of 1990 designate air quality authorities in the Gulf of Mexico OCS 

Region, giving BOEM air quality jurisdiction westward of 87°30'W. longitude and the U.S. 

Environmental Protection Agency (USEPA) air quality jurisdiction eastward of 87°30'W. longitude. In 

2006, oil and gas leasing operations within 125 miles (201 kilometers [km]) of the Florida coastline 

were banned until 2022 under the Gulf of Mexico Energy Security Act (GOMESA). The GOMESA 

moratoria area is depicted on Figure G-1. 

Figure G-1. Location of the “Air Quality Modeling in the Gulf of Mexico Region” Study, with Class I 

Areas (purple) and Platform Locations (gray dots). 
G-2 Gulf of Mexico Multisale EIS

The USEPA has set NAAQS for six regulated air quality pollutants: ozone; particulate matter 

with an aerodynamic diameter of 2.5 micrometers and smaller (PM2.5); particulate matter with an 

aerodynamic diameter of 10 micrometers and smaller (PM10); sulfur dioxide (SO2); nitrogen dioxide 

(NO2); carbon monoxide (CO); and lead (Pb). After promulgation of a NAAQS, the USEPA 

designates areas that fail to achieve the NAAQS as nonattainment areas (NAAs) and States are 

required to submit State Implementation Plans (SIPs) to the USEPA that contain emission control 

plans and a demonstration that the NAA will achieve the NAAQS by the required date. After an area 

comes into attainment of the NAAQS, the area can be redesignated as a maintenance area and 

must continue to demonstrate compliance with the NAAQS.

In 1997, the USEPA promulgated the first 8-hour ozone NAAQS with a threshold of 0.08 

parts per million (ppm) (84 parts per billion [ppb]). On March 12, 2008, the USEPA promulgated a 

more stringent 0.075 ppm (75 ppb) 8-hour ozone NAAQS. Figure G-2 presents the current ozone 

nonattainment areas in the southeastern U.S. On October 1, 2015, the USEPA strengthened the 

8-hour NAAQS for ozone to 0.07 ppm (70 ppb). Under this more stringent ozone NAAQS, there may 

be more areas in the southeastern U.S. that will be in nonattainment. The USEPA plans to make 

attainment and nonattainment designations for the revised standards by late 2017, with the 

designations based on 2014-2016 air quality data.

On December 14, 2012, the USEPA revised the PM2.5 primary NAAQS by lowering the 

annual PM2.5 NAAQS threshold from 15.0 micrograms per cubic meter (μg/m3

) to 12.0 μg/m3. The 

USEPA retained the 24-hour PM2.5 primary NAAQS at 35 μg/m3

. The 24-hour coarse PM NAAQS 

(PM10) was also retained at 150 μg/m3

. 

Figure G-2. Ozone Nonattainment Areas in the Southeastern U.S. (USEPA, 2016a). 

In February 2010, the USEPA issued a new 1-hour NO2 NAAQS with a threshold of 100 ppb 

(98th percentile daily maximum average over 3 years) and a new 1-hour SO2 NAAQS was 
Air Quality: Emissions for the Cumulative and Visibility Impacts G-3 

promulgated in June 2010 with a threshold of 75 ppb (99th percentile averaged over 3 years). The 

USEPA has not yet designated the nonattainment areas for the 1-hour NO2 and 1 hour SO2 NAAQS.

A new lead NAAQS was issued in 2008; NAAs for lead are associated with specific industrial 

sources. The NAAQS for carbon monoxide has remained essentially unchanged since it was 

originally promulgated in 1971. As of September 27, 2010, all NAAs for carbon monoxide have been 

redesignated as maintenance areas. Table G-1 summarizes the nonattainment and maintenance 

areas in the southeastern U.S.

Table G-1. Nonattainment and Maintenance Areas in the Southeastern U.S.

State Area 8-hr O3

(1997)

8-hr O3

(2008)

SO2

(2010)

Lead 

(2008)

Alabama Troy, AL NAAa

Florida

Tampa, FL NAA

Hillsborough County, FL NAA

Nassau County, FL NAA

Louisiana Baton Rouge, LA Mb NAA

St. Bernard Parish, LA NAA

Texas

Beaumont-Port Arthur, TX M

Houston-Galveston-Brazoria, 

TX NAA NAA

Frisco, TX NAA a NAA = nonattainment area

b M = maintenance area

Blank cells indicate the area is in attainment of the NAAQS.

The CAAA designated 156 Class I areas consisting of National Parks and Wilderness Areas 

that are offered special protection for air quality and air quality-related values (AQRVs). The Class I 

areas, compared to Class II areas, have lower Prevention of Significant Deterioration (PSD) air 

quality increments that new sources may not exceed and are protected against excessive increases 

in several AQRVs including visibility impairment, acid (sulfur and nitrogen) deposition, and nitrogen 

eutrophication. The Regional Haze Rule (RHR) has a goal of natural visibility conditions by 2064 at 

Class I areas, and States must submit RHR SIPs that demonstrate progress towards that goal. 

Figure G-1 displays the locations of the mandatory Class I areas (in purple) in the Gulf of Mexico 

OCS Region. In addition to Class I areas, Federal Land Management (FLM) agencies have 

designated certain other areas as sensitive Class II areas for tracking PSD increment consumption 

and AQRV impacts.

On August 26, 2014, BOEM contracted with Eastern Research Group, Inc. (ERG) and team 

members Ramboll Environ US Corporation (Ramboll Environ) and Alpine Geophysics, LLC to 

complete a comprehensive air quality modeling study in the Gulf of Mexico OCS Region. Under 

BOEM Contract Number M14PC00007, air quality photochemical grid modeling (PGM) will be 

conducted in the Gulf of Mexico OCS Region to assess the impacts to nearby States of OCS oil and 

gas exploration, development, and production as required under OCSLA. This assessment is used 
G-4 Gulf of Mexico Multisale EIS

by BOEM in the cumulative and visibility impacts analyses of the National Environmental Policy Act 

(NEPA) environmental impact statement (EIS), which is the Gulf of Mexico OCSOil and Gas Lease 

Sales: 2017-2022; Gulf of Mexico Lease Sales 249, 250, 251, 252, 253, 254, 256, 257, 259, and 

261—Final Multisale Environmental Impact Statement (2017-2022 GOM Multisale EIS). These 

analyses address both current and proposed NAAQS.

Air quality modeling requires several input datasets, including meteorology, emissions 

inventories, and ambient pollutant concentrations. Figure G-3 presents an overview of how these 

project datasets fit together for the “Air Quality Modeling in the Gulf of Mexico Region” study. 

Figure G-3. Overview of the “Air Quality Modeling in the Gulf of 

Mexico Region” Study Tasks. 

G.2 DEVELOPMENT OF EMISSION INVENTORIES

A key step in performing the “Air Quality Modeling in the Gulf of Mexico Region” study in 

support of the subsequent cumulative and visibility impacts analyses is development of 

comprehensive air emission inventories that accurately depict the base case emissions within the 

study area, and emissions associated with the 2017-2022 GOM Multisale EIS scenario (the future 

year).

The scope of the air pollutant emissions inventory development effort for the “Air Quality 

Modeling in the Gulf of Mexico Region” study includes selection of pollutants, base case year, 

geographical domain, sources, spatial resolution, temporal resolution, speciation, and development 

of the base case and future year emission estimates. These elements are described below.
Air Quality: Emissions for the Cumulative and Visibility Impacts G-5 

G.2.1 Pollutants

Pollutants for the “Air Quality Modeling in the Gulf of Mexico Region” study consist of criteria 

air pollutants as defined by CAA Title I: CO; lead; NOx (stated as equivalent mass of nitrogen 

dioxide [NO2]); PM2.5; PM10; and SO2, as well as volatile organic compounds (VOCs, which are 

precursors to ozone formation) and ammonia (NH3, a precursor to PM formation).

G.2.2 Base Case Year

In determining the base case year for the “Air Quality Modeling in the Gulf of Mexico Region” 

study emissions inventory, 2011 was initially selected based on data availability. Calendar year 

2011 emissions data are readily available for most sources from the USEPA National Emissions 

Inventory (NEI) (USEPA, 2015a), and BOEM’s Year 2011 Gulfwide Emissions Inventory Study

(Wilson et al., 2014), hereby called the “2011 Gulfwide Inventory.” However, 2011 was an unusually 

hot and dry year in the Gulf of Mexico OCS Region, particularly in Texas, which experienced record 

heat and dry conditions during the summer of 2011 and had a very high incidence of wildfires. 

Therefore, 2012 was selected as the base case year as more representative of “typical” conditions in 

the Gulf of Mexico OCS Region. 

G.2.3 Geographical Domain

The domain of the “Air Quality Modeling in the Gulf of Mexico Region” study emissions 

inventory is the area depicted in Figure G-4, particularly the 4-kilometer (km) domain encompassing 

the Gulf of Mexico OCS. This area, which includes parts of Alabama, Georgia, Louisiana, 

Mississippi, and Texas; all of Florida; as well as the Western, Central, and Eastern Planning Areas in 

the Gulf of Mexico and part of the Atlantic Ocean, are the main focus of the emissions inventory 

efforts. Emissions data were also required for the 36- and 12-km expanded domains depicted in 

Figure G-4, which include parts of Mexico and Canada. The outermost domain with 36-km 

resolution includes the entire continental U.S. and parts of Canada and Mexico, and captures 

synoptic-scale (storm system-scale) structures in the atmosphere. The inner 12-km regional grid 

covers the southeastern U.S. and is used to ensure that large-scale meteorological patterns across 

the region are adequately represented and to provide boundary conditions to the 4-km domain.
G-6 Gulf of Mexico Multisale EIS

Figure G-4. WRF 36-km CONUS (d01), 12-km SE Regional (d02), and 4-km Gulf of Mexico Region 

(d03) Domains Along With the PGM Grids. 

G.2.4 Inventory Sources

Emissions from anthropogenic (i.e., human caused) sources, including stationary point and 

nonpoint area sources located both onshore and offshore, onroad motor vehicles, nonroad 

equipment, locomotives, marine vessels and other offshore sources, and airports, were compiled for 

the “Air Quality Modeling in the Gulf of Mexico Region” study emissions inventory. Table G-2 lists 

the source groups and categories included in the emissions inventory, along with the pollutants 

applicable to each source, and the spatial and temporal resolution. Note that emissions from nonanthropogenic sources (i.e., biogenic and geogenic sources) are also included as part of the “Air 

Quality Modeling in the Gulf of Mexico Region” study cumulative and visibility analyses.
Air Quality: Emissions for the Cumulative and Visibility Impacts G-7 

Table G-2. Gulf of Mexico Air Quality Modeling Study Source Categories. 

Group and Source Category CO NOx SO2 VOC Pb PM2.5 PM10 NH3

Spatial 

Resolutiona

NEI 

Onshore 

Sources

Point Sources         P

Nonpoint Area 

Sources         A 

Onroad Mobile 

Sources        A 

Commercial Marine 

Vessels         P, Ab

Locomotives         P, Ac

Aircraft and Airports         P

Other Nonroad Mobile 

Sources        A 

Offshore Oil & Gas Sources

Platforms in State 

Waters       P 

Platforms in Central 

and Western GOM 

OCS Planning Areas

        P 

Drilling Rigs         LB

Pipe-Laying Vessels         LB

Support Helicopters       LB

Support Vessels         LB

Survey Vessels         LB

Non-oil and Gas 

Offshore Vessels and Activities

Commercial Fishing 

Vessels         LB

Commercial Marine 

Vessels         LB

Louisiana Offshore Oil 

Port         P 

Military Vessels         LB

Recreational Vessels        LB

Vessel Lightering         P

Biogenic and Geogenic Sources

Subsurface Oil Seeps  LB

Mud Volcanoes  LB

Onshore Vegetation   A

Wildfires and 

Prescribed Burning        P 

Windblown Dust   A

Lightning  A

Sea Salt Emissions   A 

Sources in Mexico and Canada

Point Sources        P

Nonpoint Area 

Sources       A 

Mobile Sources       A 

a A = Area source (modeling grid cell, spatial surrogate); P = Point source (UTM coordinates, stack 

parameters); LB = Offshore lease block (modeling grid cell, spatial surrogate) 

b Larger ports and shipping will be represented as shape files; smaller ports as point sources.

c Rail yards will be represented as point sources; railway segments as area sources.
G-8 Gulf of Mexico Multisale EIS

G.2.5 Spatial Resolution

The spatial resolution of the emissions inventory is source-specific. For example, sources 

such as power plants are identified based on their geographic coordinates (i.e., latitude and 

longitude), while other sources such as nonroad mobile sources (e.g., construction equipment) are 

spatially distributed using surrogates within the county in which they are reported and that are 

typically related to the activity distribution of the category (e.g., construction sites).

The resolution of the geographical area covered by the emissions inventory is based on the 

grid cell size needed for photochemical modeling. Furthermore, the photochemical model grid 

resolution is dependent on the grid resolution of the WRF meteorological model output used.

G.2.6 Temporal Resolution

Emissions for all sources were estimated on an annual basis (i.e., emissions generated 

during 2012). For electric generating units (EGUs), emissions were allocated on a sub-annual basis 

to reflect variations in activity using data from the USEPA.

Emissions were allocated on an hourly, daily, and seasonal basis using default temporal 

allocation factors provided with the Sparse Matrix Operator Kernel Emissions (SMOKE) emissions 

model for some sources; other temporal allocations were source-specific, and profiles were 

developed and applied within the SMOKE model.

G.2.7 Speciation

When applying the PGM modeling, PM emissions were allocated to individual PM species as 

part of the SMOKE emissions processing using PM speciation factors obtained from the USEPA’s 

SPECIATE database (USEPA, 2014a) for each source category (as defined by the Source 

Classification Code). This resulted in the PM mass being broken into the mass associated with 

elemental carbon (EC), organic carbon (OC), and other elements, and particle-bound VOCs, such as 

polycyclic aromatic hydrocarbons (PAHs). The model predictions of EC will undergo further analysis 

and will be discussed in the “Air Quality Modeling in the Gulf of Mexico Region” study final report.

SMOKE was also used to convert VOC emissions into the photochemical mechanismspecific (e.g., CB05 or CB6r2h) model species used in air quality models.

G.3 BASE CASE EMISSION ESTIMATES

This section presents an overview of the methodologies used to compile the base case 2012 

emission estimates for all source categories in the emissions inventory.

G.3.1 Point Sources

Calendar year 2011 emissions data are available for onshore point sources from the USEPA 

NEI (USEPA, 2015a). In a separate modeling effort, the USEPA prepared a criteria pollutant 
Air Quality: Emissions for the Cumulative and Visibility Impacts G-9 

calendar 2012 year emissions inventory for some sectors, including onshore point sources (USEPA, 

2015b). The ERG obtained the USEPA 2012 point sources emissions inventory, conducted quality 

assurance/quality control (QA/QC) on the data, and supplemented and revised the criteria pollutant 

estimates, as needed. The USEPA prepared the 2012 point source emissions inventory as follows:

1. 2012 data compiled by the USEPA from annual criteria pollutant reporting of 

Type A (large) sources that are submitted by responsible State and local air 

agencies;

2. 2012 EGU emissions from the USEPA Clean Air Markets Division (CAMD) 

hourly emissions data;

3. 2011 NEI data for other, smaller point sources that are not identified above; and

4. 2011 airport and aircraft emission estimates developed by the USEPA updated 

to 2012 as needed.

Although the emissions data are likely complete for most point sources, ERG confirmed that 

offshore platforms within State boundaries are included in the NEI. Data from the USEPA’s 2012 

Toxics Release Inventory (TRI) for lead and ammonia were also used to supplement the inventory 

as needed (USEPA, 2015c).

G.3.2 Nonpoint Area Sources

The starting point for the 2012 nonpoint area source inventory was the data submitted by 

State and local agencies for the 2011 NEI. In addition, for completeness, the USEPA develops 

emission estimates for a number of nonpoint source categories (up to 165) for inclusion in the NEI if 

agencies do not provide estimates. The USEPA did not develop 2012 emission estimates for 

nonpoint area sources. The ERG prioritized key top-emitting source categories of NOx, PM, SO2, 

and VOCs in AL, FL, GA, LA, MS, and TX, and developed 2012 emission estimates using the 

USEPA nonpoint area source category tools (USEPA, 2014b). These categories are as follows: 

consumer products, architectural surface coatings, industrial maintenance coatings, open burning: 

municipal solid waste (MSW), residential and institutional/commercial/industrial (ICI) heating, 

upstream oil and gas, open burning, land clearing debris, paved and unpaved roads, and gasoline 

distribution Stage I. The ERG also conducted point source reconciliation for ICI heating, oil and gas, 

and gasoline distribution Stage I to verify that there are no gasoline distribution Stage II records in 

USEPA’s nonpoint file (now reported with onroad mobile sources).

G.3.3 Mobile Sources

The onroad mobile source category includes exhaust and evaporative emissions from 

onroad motor vehicles (e.g., automobiles, light-duty trucks, heavy-duty trucks) and exhaust and 

evaporative emissions from nonroad mobile sources. The ERG team ran the MOVES2014 model 

for onroad sources (USEPA, 2014c), and the USEPA ran the NONROAD model for nonroad sources 

to develop 2012 emission estimates for these categories. Locomotive emissions in the 2011 NEI 
G-10 Gulf of Mexico Multisale EIS

were not adjusted to represent 2012 activities because it was confirmed that the 2011 and 2012 fuel 

usage data from the Surface Transportation Board’s R-1 Class 1 railroad annual reporting data 

(Surface Transportation Board, 2015) show only a slight (2%) reduction in 2012 levels from 2011 

levels.

G.3.4 Offshore Helicopters

The Gulf of Mexico has more helicopter traffic than any other region of the U.S., primarily 

associated with offshore oil and gas support. Offshore support helicopter emission estimates were 

obtained from the 2011 Gulfwide inventory (Wilson et al., 2014). The estimates were supplemented 

with 2011 NEI helicopter data for onshore airports. The two datasets map out the full route between 

offshore platforms equipped with helipads and the closest onshore support facility; the NEI 

addresses emissions only at each airport and only for operations up to 3,000 feet of elevation (i.e., 

local mixing height). The two datasets were evaluated to ensure that the helicopter traffic data 

between the two are comparable and that there is no double counting of emissions.

G.3.5 Offshore Oil and Gas Production Sources—Western and Central/Eastern 

Planning Areas in the Gulf of Mexico

The starting point for offshore oil and gas production platforms in the Western and 

Central/Eastern Planning Areas (WPA and CPA//EPA) was the 2011 Gulfwide inventory. The ERG 

team supplemented the 2011 Gulfwide inventory with NH3 and Pb emission estimates for all 

applicable emission sources using USEPA emission factors. The ERG team conducted research to 

determine if the 2011 emissions values for platform sources should be adjusted to be more 

representative of 2012 emissions values. Offshore oil and gas production values for 2011 and 2012 

were obtained from the BOEM Part A Oil and Gas Operations Reports (OGOR) (USDOI, BOEM, 

2015). The OGOR data are presented at the lease level. Production of both oil and gas (including 

deepwater production) decreased from 2011 to 2012; thus, the 2011 emission estimates were 

modeled without adjustment in order to be conservative. Table G-3 presents the base case 

emission estimates for offshore oil and gas production sources in the WPA and CPA//EPA. Figures 

G-5 through G-7 show the NOx, VOC, and PM2.5 emissions from platform sources. Platform 

sources include the following emission source types: amine units, boilers/heater/burners, diesel and 

gasoline engines, drilling equipment, combustion flares, fugitives, glycol dehydrators, losses from 

flashing, mud degassing, natural gas engines, natural gas turbines, pneumatic pumps, 

pressure/level controllers, storage tanks, and cold vents.

Table G-3. Base Case Offshore Oil and Gas Production Source Emissions Estimates for the GOM 

Western and Central/Eastern Planning Areas. 

NOX

(TPY)

SO2

(TPY)

PM10

(TPY)

PM2.5

(TPY)

VOC 

(TPY)

CO 

(TPY)

Pb 

(TPY)

NH3

(TPY)

Platform 

Sources 84,128 3,197 838 835 54,724 70,339 <1 40

Non-platform 

Sources 232,765 22,977 8,632 8,225 7,937 41,880 701 70,139

Total 316,893 26,174 9,470 9,060 62,661 112,219 701 70,179
Air Quality: Emissions for the Cumulative and Visibility Impacts G-11

Figure G-5. 2012 Platform NOx Emissions Aggregated by Lease Block. (Note: This figure does 

not indicate the platform source count, location, or emissions at the time of publication 

of the 2017-2022 GOM Multisale EIS.)
G-12 Gulf of Mexico Multisale EIS

Figure G-6. 2012 Platform VOC Emissions Aggregated by Lease Block. (Note: This figure does not 

indicate the platform source count, location, or emissions at the time of publication of the 

2017-2022 GOM Multisale EIS.)
Air Quality: Emissions for the Cumulative and Visibility Impacts G-13

Figure G-7. 2012 Platform PM2.5 Emissions Aggregated by Lease Block. (Note: This figure does not 

indicate the platform source count, location, or emissions at the time of publication of the 

2017-2022 GOM Multisale EIS.)

G.3.6 Offshore Vessels

Offshore vessels can be grouped into vessels that support the construction, operation, and 

decommissioning of oil and gas platforms; and vessels involved in other commercial, recreational, 

and military operations. All marine vessels included in this study operate using diesel engines. 

These include very large propulsion engines as well as smaller auxiliary diesel engines that provide 

power for electricity generation, winches, pumps, and other onboard equipment. Smaller engines 

tend to use distillate grade diesel fuel, while large engines are able to combust heavier residual 

blends.

40 CFR § 1043.109(b) created the North American Emission Control Area (ECA), which 

includes the Gulf of Mexico (USEPA, 2010). This regulation limits marine fuel sulfur content to 1% 

after August 1, 2012, for any vessel with a gross tonnage greater than 400. Vessels below this 

threshold tend to use distillate fuels, which are already at or below the 1% limit.
G-14 Gulf of Mexico Multisale EIS

G.3.6.1 Oil and Gas Production Support Vessels

The offshore oil and gas production sector requires a wide variety of vessels to support the 

exploration, development, and extraction of oil and gas, including the following: 

• seismic survey vessels; 

• drilling vessels; 

• pipe-laying vessels; 

• crewboats; and

• supply vessels. 

For the 2011 Gulfwide inventory, Automatic Identification System (AIS) data from PortVision 

were used to map spatial aspects of vessel movements (PortVision, 2012). The AIS is an 

automated tracking system that allows exchanges of location and contact data with other nearby 

ships, offshore platforms, satellites, and AIS base stations, enhancing navigation and reducing atsea collisions.

On October 22, 2003, the U.S. harmonized the AIS mandates of the Safety of Life at Sea 

Convention with the Maritime Transportation Security Act of 2002 (MTSA), which requires the 

following vessels, including offshore support vessels, to participate in the AIS program:

(1) passenger vessels of 150 gross tonnage or more;

(2) tankers, regardless of tonnage; and

(3) vessels other than passenger vessels or tankers of 300 gross tonnage or more.

Vessels that do not meet these thresholds, such as crew boats and smaller support vessels, 

can still participate in AIS on a voluntary basis. The Offshore Marine Service Association (OMSA) is 

encouraging its membership to equip their vessels with AIS transponders, allowing for more efficient 

and safer ship movements in the highly congested central and western areas of the Gulf of Mexico.

The ERG team used the spatially distributed support vessel emission estimates from 

BOEM’s 2011 Gulfwide inventory. While the USEPA 2011 NEI also includes marine vessel emission 

estimates for the Gulf of Mexico, the emission estimates were derived from national vessel activity 

data. During QA/QC of the 2011 BOEM Gulfwide estimates, ERG found and corrected an error in 

the vessel power rating for a number of smaller vessels.

As discussed above for offshore oil and gas production platforms, the 2011 emission 

estimates for these vessels were not adjusted to reflect 2012 production levels. SOx and PM 

(associated with sulfates) were not adjusted to account for the introduction of low sulfur ECA 

compliant fuel in the last 5 months of 2012 because it was determined that most support vessels are 
Air Quality: Emissions for the Cumulative and Visibility Impacts G-15

Category 1 or 2, which already use ECA compliant fuels. Emission estimates for NH3 and Pb were 

also developed for vessels. Table G-3 presents the base case emission estimates for drilling rigs, 

pipe-laying operations, support helicopters, support vessels, and survey vessels. Figures G-8

through G-10 show the NOx, VOC, and PM2.5 emissions from non-platform sources.

Figure G-8. 2012 Non-platform NOx Emissions. (Note: This figure does not indicate the nonplatform source count, location, or emissions at the time of publication of the 2017-2022 

GOM Multisale EIS.)
G-16 Gulf of Mexico Multisale EIS

Figure G-9. 2012 Non-platform VOC Emissions. (Note: This figure does not indicate the 

non-platform source count, location, or emissions at the time of publication of the 

2017-2022 GOM Multisale EIS.)
Air Quality: Emissions for the Cumulative and Visibility Impacts G-17

Figure G-10. 2012 Non-platform PM2.5 Emissions. (Note: This figure does not indicate the 

non-platform source count, location, or emissions at the time of publication of the 

2017-2022 GOM Multisale EIS.)

The ERG team obtained drilling vessel data from BSEE to confirm that there was no drilling 

activity in the eastern Gulf of Mexico OCS Region in 2012, and reviewed the permits granted by the 

USEPA for offshore platforms in the eastern Gulf of Mexico OCS Region to confirm there were no 

active production platform activities in 2012.

G.3.6.2 Non-oil and Gas Production Offshore Vessels

Vessels not directly associated with the offshore oil and gas activities include the following: 

• commercial marine vessels; 

• Louisiana Offshore Oil Port-associated vessels; 

• commercial and recreational fishing vessels; 

• ferries; 

• research vessels; 
G-18 Gulf of Mexico Multisale EIS

• harbor craft; and

• military vessels. 

Commercial marine vessels (CMVs) include large ships involved in international trade that 

visit coastal ports and operate in deep waters, as well as smaller general cargo ships and tugs that 

move barges along waterways and rivers. For the Federal waters of the central and western of the 

Gulf of Mexico, the ERG team used the commercial marine vessel data from the 2011 Gulfwide 

inventory. For completeness, for all other areas of the Gulf of Mexico, Atlantic Ocean, and State 

waters, the USEPA’s NEI data were used (which were developed from national vessel activity data 

as noted above). These inventories cover different geographical areas than the BOEM inventory, as 

well as different vessel types. BOEM’s data include large deepwater vessels as does the USEPA 

data beyond the Federal/State boundary, but they also include vessels such as ferries, dredging 

vessels, tugs, towboats, and harbor craft that tend to operate only in State waters.

The Louisiana Offshore Oil Port (LOOP) is a pumping platform for tankers to discharge 

imported crude oil to the mainland without having to maneuver through port traffic. Similarly, there 

are four offshore lightering zones in the Gulf of Mexico (i.e., Southtex, Gulfmex No. 2, Offshore 

Pascagoula No. 2, and South Sabine Point) where smaller shuttle tankers can move product from

very large crude carriers, bringing the oil to port while the large tankers remain off the coast. 

Tankers that visit the LOOP or the lightering zones along with the shuttle tankers were identified in 

the 2011 Gulfwide inventory. The inventory also accounts for evaporative emissions from unloading 

and loading activities, and emissions from the operation of generators and pumps at the LOOP; 

adjustments were made to the 2011 LOOP emission estimates to reflect the 18% decline in crude 

imports in 2012.

Emissions from the operation of commercial and recreational fishing vessels are also 

included in the 2011 Gulfwide inventory for Federal waters. These were supplemented with the 

USEPA’s 2011 NEI data for these fishing vessels for operations in the Eastern Planning Area in the 

Gulf of Mexico, Atlantic Ocean, and State waters. For military vessels, the ERG team used the 2011 

Gulfwide inventory Navy and Coast Guard vessel emission estimates and the NEI’s Coast Guard 

emission estimates for State waters, as well as Federal waters in the eastern part of the Gulf of 

Mexico and the Atlantic Coast. The ERG team conducted research to determine that activity levels 

from 2011 to 2012 were similar for the other non-oil and gas vessels (e.g., tankers, container ships, 

bulk, and general cargo). Based on the most recent International Maritime Organization data (IMO, 

2015), fuel combustion is projected to remain constant from 2010 to 2015. Thus, no adjustments 

were needed to approximate activities in 2012.

The SO2 and PM (associated with sulfates) emission estimates were adjusted for Category 3 

vessels to account for the introduction of low sulfur ECA-compliant fuel in the last 5 months of 2012.
Air Quality: Emissions for the Cumulative and Visibility Impacts G-19

G.3.7 Biogenic and Geogenic Sources

For completeness, it is important to include non-anthropogenic emission sources in the 

inventory. The ERG team also estimated emissions for the sources listed below.

• Onshore vegetation (biogenic): MEGAN (version 2.1) biogenic emission model

• Wildfires, prescribed burns, and agricultural burning: USEPA’s SMARTFIRE 

emissions inventory for the U.S.

• Windblown dust: Windblown dust (WBD) modeling using the WRF 

meteorological dataset

• Lightning: WRF data (preprocessor)

• Subsurface oil seeps: 2011 Gulfwide inventory

• Mud volcanoes: 2011 Gulfwide inventory

• Sea salt emissions: WRF data (preprocessor)

The ERG team used fire emission estimates from the National Center for Atmospheric 

Research (NCAR) Fire INventory (FINN) for Mexico and Canada.

G.3.8 Sources In Mexico

The ERG team developed the 2012 emission inventories for the portions of Mexico within the 

36-km modeling inventory domain using the municipality-level emission files from the 2008 Mexico 

National Emissions Inventory (MNEI) (SEMARNAT, 2014) combined with projection factors for point, 

nonpoint area, and nonroad mobile sources. Mexico onroad motor vehicle emissions were 

generated using a version of the USEPA vehicle emissions model MOVES, updated to reflect 

conditions in Mexico. MOVES2014 was the most recent version of the model available at the time of 

the analysis and reflects USEPA’s latest estimate of vehicle emissions and default U.S. activity data 

(USEPA, 2014c). The ERG also conducted research on the offshore oil production activities off the 

coast of Mexico. Based on a report published by the Congressional Research Service, it was 

determined that there was no offshore production within the 36-km modeling domain in 2012 (Seelke 

et al., 2015).

G.3.9 Sources In Canada

Emissions from the USEPA’s most recent modeling platform (2010) were used for sources in 

Canada.

G.4 FUTURE YEAR MODELING SCENARIO EMISSION ESTIMATES

Emission estimates were also needed as inputs for additional modeling scenarios that will 

predict future impacts from implementation of the 2017-2022 GOM Multisale EIS. For modeling the 

future year impacts, the ERG team forecast emissions estimates based on information provided by 
G-20 Gulf of Mexico Multisale EIS

BOEM, combined with USEPA projected emission estimates and other data for onshore sources and 

marine vessels and other sources outside of the GOM region. The ERG team confirmed that 

offshore drilling in the EPA under USEPA air quality jurisdiction is included in BOEM’s 2017-2022 

Outer Continental Shelf Oil and Gas Leasing: Proposed Final Program (Five-Year Program) 

spreadsheets. The ERG also reviewed the USEPA’s offshore oil and gas production permits to 

confirm that no production platforms were permitted to be constructed prior to or during 2017. 

Projected emission estimates were developed for anticipated offshore drilling off the coast of Mexico.

G.4.1 Western, Central, and Eastern Planning Areas OCS Offshore Oil and Gas 

Production Sources

The ERG team developed annual emission estimates for all categories and pollutants for 

each year of activity for OCS offshore oil and gas production sources associated with the Five-Year 

Program using BOEM’s spreadsheet-based data analyses tools. BOEM provided information on the 

predicted levels of activity, sources, and locations (by planning area and water depth) to depict 

offshore oil and gas activities in the future scenario. The emissions estimates are based on a midprice oil case scenario and cover the WPA, CPA, and EPA, which are under BOEM’s jurisdiction.

After completion of the OCS offshore oil and gas production source emission estimates, the 

resulting cumulative emissions for each pollutant were assessed to determine which emission 

estimates should be selected for PGM modeling to support the cumulative and visibility impacts 

analyses.

Based on information provided by BOEM, it was assumed that emissions for the following 

sources occur during the total period of proposed activity based on the 2017-2022 GOM Multisale 

EIS scenario (2017-2056)1

: 

• exploration and delineation well drilling activities (1,671 wells drilled); 

• development and production well drilling activities (1,135 wells drilled); 

• platform installation activities (535 platforms installed); 

• FPSO installation (1 FPSO installed); 

• FPSO operation (1 FPSO operating); 

• FPSO removal (1 FPSO removed); 

• pipeline installation excluding State waters (7,251 km of pipeline installed); 

• platform oil and gas production (535 platforms in operation); 

 

1 Excluding the Gulf of Mexico Energy Security Act (GOMESA) moratorium area.
Air Quality: Emissions for the Cumulative and Visibility Impacts G-21

• platform removal (535 platforms removed); 

• support helicopters (642,000 round trips); and

• support vessels (1,062,000 operations). 

The BOEM data analyses tools provide information on each of these anticipated activities by 

year, as well as water depth. The anticipated water depths by planning area were used to spatially 

allocate the emissions.

The ERG used this information to develop emission estimates for each source category 

based on emission estimation methods used in past Gulfwide emissions inventory studies and other 

data compiled for BOEM in order to determine which estimates should be selected for 

photochemical modeling to support the cumulative and visibility impacts analyses.

The following sections discuss the emission estimation methods that the ERG team used to 

estimate emissions for the BOEM oil and gas production sources in the future scenario.

G.4.1.1 Oil and Natural Gas Offshore Production Platforms

In order to develop reasonably foreseeable emission estimates for projected oil and natural 

gas production platforms, the emission factors presented in Table G-4 were developed based on the 

2011 Gulfwide inventory (Wilson et al., 2014). Because deepwater operations may significantly 

differ from conventional operations in shallower waters, are technologically more sophisticated, and 

produce at much higher rates, two sets of emission factors were developed and assigned to each 

projected platform based on water depth. Depths below 200 meters (656 feet) were assigned the 

shallow-water emission factors, and depths above were assigned deepwater emission factors.

Emission estimates for platform sources were developed based on platform installation and 

carried forward until the projected platform removal dates (provided by planning area and water 

depth).

Table G-4. Future Year Production Platform Emission Factors. 

Pollutant

Shallow Water 

Emission Factors (<200 m) 

(tons/platform/yr)

Deepwater 

Emission Factors (>200 m) 

(tons/platform/yr)

CO 56 192

NOx 46 582

PM10-PRI 0.5 5.17

PM2.5-PRI 0.50 5.15

SO2 0.51 44

VOC 22 96

Pb 2.38E-05 3.79E-03

NH3 0.0349 0.49

Source: Developed from the Year 2011 Gulfwide Emissions Inventory (Wilson et al., 

2014).
G-22 Gulf of Mexico Multisale EIS

G.4.1.2 Offshore Support Helicopters

The ERG team obtained helicopter emission factors from the Switzerland Federal Office of 

Civil Aviation (FOCA) Guidance on Determination of Helicopter Emissions (FOCA, 2009). However, 

the landing and takeoff (LTO) cycle used by FOCA was determined to be too short for typical trips 

taken in the Gulf of Mexico. The time-in-mode values were therefore adjusted based on the 

International Civil Aviation Organization (ICAO) test cycles, which are considered to be appropriate 

for offshore operations in the Gulf of Mexico. Because the future fleet mix is unknown, ERG 

weighted the emission factors using fleet profile data from the Helicopter Safety Advisory 

Conference (HSAC, 2015). The VOC emission factors were developed by converting the 

hydrocarbon (HC) emission factors using data from the USEPA’s Procedures for Emission Inventory 

Preparation Volume IV: Mobile Sources (USEPA, 1992). The aggregated general aviation 

conversion factor of 1.0631 for turbine engines was used because the GOM support helicopter fleet 

is primarily equipped with turbine engines. The PM2.5 emission factors were speciated from PM10

factors using USEPA aircraft speciation data, and the SO2 emission factors were developed based 

on a typical jet fuel sulfur concentration of 0.05% (UNEP, 2012).

G.4.1.3 Oil and Gas Production Offshore Support Vessels

Four components are needed to estimate future offshore vessel emissions:

• vessel characteristics (engine power and speed); 

• engine operating load (percent of maximum engine power); 

• hours of operation (typically determined by the distance the vessel travels divided 

by the vessel speed); and

• appropriate emission factors (grams per kW-hr). 

Because there is uncertainty about the location of future activities, it was assumed that a 

typical vessel trip is 200 nautical miles, which is the round-trip distance from shore to the mid-point 

of Federal waters.

In projecting future year activity, it is not always possible to identify specific vessels that will 

be used. Therefore, the use of larger vessels that represent the upper bound of each vessel type 

was assumed, such that actual future year emissions should be similar to or lower than emission 

estimates developed using this fleet profile. These vessels were identified based on data compiled 

from the Information Handling Service (IHS) Register of Ships (IHS, 2015). Vessels from the global 

fleet were used because these larger ships move internationally based on local demand. It should 

also be noted that these larger vessels tend to be involved in deepwater activities because they are 

designed for extended open-water operations. As trends to develop deeper water locations in the 

Gulf of Mexico continue into the future, it is likely that these larger or similar vessels will support 

future year activities.
Air Quality: Emissions for the Cumulative and Visibility Impacts G-23

The selected vessels and their characteristics are presented in Table G-5. In order to 

correctly match the vessel to the appropriate emission factors, the vessel engine category is 

required. The USEPA vessel category was determined by calculating the cylinder volume based on 

the stroke length and diameter of the cylinder. The USEPA categories are defined by the following 

cylinder volumes:

• Category 1: Cylinder displacement less than 5 liters; 

• Category 2: Cylinder displacement from 5 to 30 liters; and

• Category 3: Cylinder displacement greater than 30 liters.

If a vessel’s cylinder volume was unknown, it was assumed that the vessel was powered by 

a Category 3 propulsion engine. It should also be noted that all of the selected vessels are foreign 

flagged, but it is assumed that they refuel using U.S.-regulated marine fuels as they shift equipment 

and supplies from nearby U.S. ports.

Table G-5. Summary of Vessel Characteristics. 

Vessel Type Total Main Power 

(kW) Vessel Name Propulsion Engine Category

Speed 

(knots)

Drillship 48,666 Rowan 

Renaissance 3 12

Jackup 12,485 Bob Palmer 2

(auxiliary) Not self-propelled

Platform Rig 8,100 Nabors Mods 087 2

(auxiliary) Not self-propelled

Semisubmersible 22,371 ENSCO 7500 2 3.5

Submersible 3,691 Hercules 78 2

(auxiliary) Not self-propelled

FPSO 14,1101 Terra Nova FPSO 2 12.0

FSO 51,519 Africa 3 16.5

Stimulation Vessel 15,840 Norshore Atlantic 2 14

Oil Tanker 13,369 SPT Explorer 3 15

Anchor Handling 

Vessel 27,000 KL Sandefjord 3 17

Crew Boat 11,520 R. J. Coco Mccall 3 23

Supply Vessel 18,000 Aleksey Chirikov 3 15

Tug Boat 19,990 Yury Topchev 3 15

Pipe-Laying Vessel 67,200 Castorone 3 14

1 Only distillate oil main engine kW included (430 kW & 2 x 6840 kW). Topside emissions are 

included in the deepwater production platform estimates. 

A vessel’s engine power varies relative to the type of operation that is implemented. While 

cruising in open waters, the propulsion engine load is typically 84% of maximum load; during 

maneuvering, it can be 60% or lower; and when stationary,. it can be 10% or lower. Table G-6
G-24 Gulf of Mexico Multisale EIS

presents the aggregated load factors that will be used in this Study for propulsion and auxiliary 

engines.

Table G-6. Load Factors to be Used in the Future Year Projections. 

Vessel Type Load Factor

Propulsion Cruising 0.8-0.85

Propulsion Idle 0.1

Propulsion Crew/Supply Boat 0.45

Propulsion Drill Ship and Semi-Submersible 0.83

Propulsion Pipe-Laying Vessel 0.16

Propulsion Tug 0.68

Auxiliary Emergency Generator 0.75

Drilling Equipment 1

The future year emission factors were developed in terms of grams of pollutant emitted per 

load-adjusted engine kW-hours based on the emission factors used in the USEPA’s 2014 NEI 

(Table G-7). The factors presented below are applicable for foreign-flagged vessels that are not 

required to comply with USEPA exhaust standards but that must comply with international Emission 

Control Area (ECA) standards. These future year factors account for the reduction in fuel sulfur level 

associated with the ECA. Because Category 2 foreign-flagged offshore support vessels will be 

refueling at U.S. ports, it was anticipated that these vessels will use low sulfur compliant U.S. fuels. 

Also, the NOx emission factors were adjusted to account for the 2016 ECA Tier III standard that 

requires high efficiency, after-treatment technology, and is applicable for U.S. and foreign-flagged 

vessels. The Category 3 PM emission factors were not adjusted to account for reductions in PM as 

sulfate compounds because the USEPA’s adjustment equation provided a PM factor lower than the 

PM emission factor for Category 2 powered vessels.

Table G-7. Marine Vessel Emission Factors (g/kW-hr). 

Engine Category NOx SO2 PM10 PM2.5 VOC CO HC NH3 Pb

2 3.4 0.006 0.320 0.310 0.141 2.48 0.13 0.005 0.00003

3 3.4 0.362 0.450 0.437 0.632 1.40 0.60 0.003 0.00003

Source: USEPA, 2016b.

G.4.1.4 Future Year Emission Estimates and Selection of Future Modeling Year

The emission estimates developed for the future BOEM oil and gas production sources were 

reviewed to determine the most suitable future year emissions to model. The PGM modeling for the 

cumulative and visibility impacts analysis was conducted based on the emissions anticipated to have 

the greatest impact on the air quality of any state. This was determined based on the estimated 

annual emission trends. The future highest NOx emission year for all activities in all planning areas 

coincided with the highest PM, CO, NH3, and Pb emissions. These emissions are driven by support 

vessel activity for the most part. The future highest VOC emission year for all activities in all 

planning areas coincided with the highest SO2 emissions and is driven by production platform 

emissions. Table G-8 presents the resulting emission estimates, and Figure G-11 presents a 
Air Quality: Emissions for the Cumulative and Visibility Impacts G-25

graphical depiction of the annual emission estimates for all pollutants. Figures G-12 through G-14

present graphical depictions of the annual emission estimates for NOx, VOC, and PM2.5 by source 

category.

It was concluded that BOEM would model the activity data and resulting emission estimates 

for year 2033 for non-platform sources, and year 2036 activity data and resulting emission estimates 

for platform sources. 

Table G-8. Emission Estimates for the Western, Central, and Eastern Planning Areas, All Depths, By 

Year and Pollutant. 

Year NOx 

(TPY)

SO2

(TPY)

PM10

(TPY)

PM2.5

(TPY)

VOC 

(TPY)

CO 

(TPY)

Pb 

(TPY)

NH3

(TPY)

2017 3,693 40 360 349 200 2,591 0.03 10

2018 19,328 118 1,813 1,759 1,213 14,058 0.17 80

2019 34,958 158 3,199 3,104 2,150 25,462 0.30 98

2020 46,119 268 4,124 4,001 3,042 33,293 0.39 111

2021 50,126 379 4,368 4,238 3,807 35,937 0.42 125

2022 54,328 446 4,605 4,469 4,535 38,906 0.45 139

2023 57,639 527 4,888 4,743 5,311 41,426 0.48 154

2024 59,979 484 5,030 4,881 5,872 43,637 0.49 170

2025 64,527 523 5,413 5,252 6,543 47,198 0.53 189

2026 70,601 598 5,870 5,696 7,510 51,762 0.57 209

2027 76,146 704 6,305 6,118 8,419 55,747 0.61 228

2028 79,863 742 6,609 6,414 9,125 58,701 0.64 244

2029 85,277 803 7,012 6,805 10,034 62,750 0.68 262

2030 90,332 876 7,381 7,163 11,010 66,523 0.72 280

2031 97,123 984 7,860 7,628 12,185 71,365 0.77 298

2032 100,564 1,022 8,057 7,820 13,228 74,107 0.79 315

2033 108,4471 1,199 8,590 8,338 14,709 79,486 0.85 334

2034 101,673 1,193 7,919 7,687 14,939 74,742 0.79 329

2035 102,443 1,253 7,923 7,691 15,484 75,167 0.79 327

2036 103,354 1,395 7,865 7,635 15,940 75,096 0.79 318

2037 96,715 1,343 7,274 7,062 15,254 70,088 0.74 298

2038 92,539 1,327 6,935 6,732 14,560 66,732 0.71 283

2039 84,787 1,280 6,269 6,087 13,443 60,725 0.65 247

2040 79,475 1,235 5,841 5,672 12,317 56,455 0.61 226

2041 77,705 1,294 5,652 5,488 11,544 54,267 0.60 209

2042 71,710 1,292 5,110 4,962 10,485 49,266 0.55 187
G-26 Gulf of Mexico Multisale EIS

Table G-8. Emission Estimates for the Western, Central, and Eastern Planning Areas, Emissions 

Estimations for Western, Central, and Eastern Planning Areas, All Depths, By Year and 

Pollutant (continued). 

Year NOx

(TPY)

SO2

(TPY)

PM10

(TPY)

PM2.5

(TPY)

VOC 

(TPY)

CO 

(TPY)

Pb 

(TPY)

NH3

(TPY)

2043 51,254 1,094 3,390 3,293 8,643 34,736 0.38 157

2044 46,692 1,077 3,018 2,932 7,842 31,076 0.35 143

2045 42,933 1,009 2,752 2,673 7,115 28,358 0.32 128

2046 39,227 974 2,433 2,364 6,492 25,503 0.29 117

2047 37,540 965 2,313 2,247 6,006 24,050 0.28 108

2048 34,738 954 2,083 2,024 5,495 21,808 0.26 98

2049 32,995 904 1,995 1,939 5,020 20,615 0.25 90

2050 28,873 849 1,688 1,640 4,403 17,665 0.22 82

2051 26,286 796 1,524 1,481 3,872 15,834 0.20 73

2052 24,303 747 1,406 1,367 3,475 14,510 0.18 67

2053 15,585 598 757 737 2,610 8,716 0.11 23

2054 13,131 592 542 527 2,333 6,838 0.09 17

2055 12,062 502 548 533 2,010 6,479 0.09 16

2056 10,119 453 434 422 1,615 5,185 0.07 12

2057 9,083 450 340 331 1,528 4,407 0.06 9

2058 8,519 405 344 335 1,321 4,185 0.06 8

2059 7,182 316 321 313 1,031 3,653 0.05 7

2060 6,052 314 215 209 984 2,829 0.04 5

2061 5,765 270 237 231 877 2,852 0.04 5

2062 5,075 268 180 176 760 2,305 0.04 4

2063 4,614 224 186 181 646 2,201 0.03 3

2064 3,524 136 183 178 433 1,872 0.03 2

2065 1,906 46 130 126 175 1,157 0.02 1

2066 1,392 46 81 79 153 782 0.01 1

1 Bold numbers are the highest emissions per year per pollutant. These were the amounts modeled.
Air Quality: Emissions for the Cumulative and Visibility Impacts G-27

Figure G-11. Emission Estimates for all Planning Areas and Future Activities. 

Figure G-12. Combined Annual NOx Emissions. 
G-28 Gulf of Mexico Multisale EIS

Figure G-13. Combined Annual VOC Emissions. 

Figure G-14. Combined Annual PM2.5 Emissions. 

G.4.1.5 Spatial Allocation

The estimated emissions were allocated by planning area (WPA vs. CPA/EPA) and water 

depth (i.e., 0-60 m, 60-200 m, 200-800 m, 800-1,600 m, 1,600-2,400 m, and >2,400 m). 

Figure G-15 depicts the planning area boundaries and water depth contours. (Note that the 

GOMESA Congressional Moratoria Area is not indicated in Figure G-15.) Emissions were not 

allocated to the GOMESA. The emission estimates were allocated spatially based on the 

anticipated future year activities provided by BOEM. Because helicopters, support vessels, and 
Air Quality: Emissions for the Cumulative and Visibility Impacts G-29

tankers transit multiple water depths, their emissions were allocated across multiple water depth 

contours based on assumed installed platform locations.

For some sources, emissions were assigned to unleased blocks in each area (i.e., WPA and 

CPA/EPA) relative to the water depth where the activity is anticipated to occur. These categories 

include the following: 

• exploratory drilling vessels; 

• development/production drilling vessels; and

• production platforms. 

Figure G-15. BOEM OCS Planning Areas and Water Depths. 

Production platforms were located as point sources with randomly selected locations. Using 

GIS, each lease block in the Gulf of Mexico was assigned to a water depth bin. Blocks with an 

active lease and that have contained a platform were then removed. Blocks that have had a 

platform suggest that they were leased at some point in time, and therefore are less desirable for 

future exploration. Once the inactive blocks with no history of production were identified, random 

blocks were selected throughout each water depth for each future platform as depicted in Figure 

G-15. Each platform was placed in a separate block at the centroid. Pipe-laying vessel activities 
G-30 Gulf of Mexico Multisale EIS

were assigned to leased and unleased blocks as their operations were not limited to just the 

unleased blocks.

Emissions associated with BOEM’s existing OCS oil and gas production sources were held 

constant at 2012 levels.

G.4.2 Onshore Sources and Marine Vessels

In support of the proposed ozone NAAQS revisions, the USEPA released the 2011 air quality 

modeling platform (2011v6.1), with projections to 2018 and 2025, for point, nonpoint area, and 

mobile sources in the United States (USEPA, 2014d). In addition, the USEPA released the 2011 air 

quality modeling platform (2011v6.2), with projections to 2017, to support ozone transport modeling 

for the 2008 NAAQS as well as the 2015 ozone NAAQS (USEPA, 2015d). In early October, 2015, 

the USEPA also released the 2011v6.2 calendar year 2025 projected inventory (USEPA, 2015d). 

The ERG team used the 2011v6.2 platform for calendar year 2017, primarily because the platform is 

based on the most recent version of the NEI (2011v.2). Calendar year 2017 data were selected 

rather than 2025 data because there is less uncertainty associated with the 2017 estimated 

emissions because most of the controls factored in by the USEPA are already “on the books” and 

not speculative. The Technical Support Document (TSD) Preparation of Emissions Inventories for 

the Version 6.2, 2011 Emissions Modeling Platform (USEPA 2015d) provides details on the 

development of the 2011v6.2 future year modeling platforms.

G.4.3 Other Sources

For sources in Mexico, the USEPA air quality modeling platform 2011v6.2 includes projected 

2018 emissions for onshore sources. The USEPA held emissions constant for sources in Canada.

For completeness, projected emissions estimates were also developed for platforms off the 

coast of Mexico; the ERG team researched the impacts of the restructuring of the energy sector in 

Mexico, which is predicted to include deepwater drilling within the modeling domain. Emissions 

were estimated based on projected deepwater production (PEMEX, 2012) and using productionbased emission factors developed from the 2011 Gulfwide Inventory (Wilson et al., 2014).

For the LOOP and vessel lightering, emissions were held at 2012 levels because of 

uncertainties in future crude oil imports, which involve the very large crude carriers that visit the 

LOOP and lightering zones. The ERG team also investigated the need to include a liquefied natural 

gas (LNG) port to be located in Federal waters and originally expected to be operational in 2019. On 

September 18, 2015, however, the Maritime Administration (MARAD) and the U.S. Coast Guard 

stopped the permit application process, as Delphin LNG, LLC is amending the application. This 

potential source was not included in the future scenario given this uncertainty.
Air Quality: Emissions for the Cumulative and Visibility Impacts G-31

G.5 SOURCE APPORTIONMENT

Source apportionment, as applied in PGM modeling, provides a means of assessing the 

contributions of specified sources or source groups to predicted ozone and PM concentrations under 

the air quality conditions being simulated. Source contributions can be calculated for ozone and for 

PM using ozone or PM source apportionment routines included in the CAMx PGM modeling. In this 

Study, the primary receptor locations of interest for examining source contributions lie both along the 

shoreline and the State seaward boundary, although the PGM source apportionment output is for the 

entire modeling domain. Source apportionment analyses with the PGM will be applied to the future 

year scenario in order to analyze the pre- and postlease OCS oil and gas impacts to short-term and 

annual NAAQS. This will afford BOEM the opportunity to discern which source groups have the 

largest impacts and potentially need to be examined for control strategies. BOEM selected the 

following source groups for source apportionment:

• fires (U.S., Canada, and Mexico); 

• biogenic and other natural sources (e.g., lighting NOx and sea salt); 

• additional BOEM OCS oil and gas production platforms associated with the 

Five-Year Program; 

• additional BOEM oil and gas production support vessels and helicopters 

associated with the Five-Year Program; 

• BOEM OCS oil and gas production platforms, support vessels, and helicopters 

under No Action (base case) alternative; 

• all other marine vessel activity in the Gulf of Mexico; 

• other anthropogenic U.S. sources; 

• Mexican and Canadian anthropogenic sources; and

• initial and boundary conditions (IC and BC). 

These source groups aggregate similar sources based on jurisdiction (i.e., sources under 

BOEM control versus other Federal agencies) and sources beyond control (e.g., natural emission 

sources and foreign sources). This is helpful in showing whether BOEM’s sources are significantly 

contributing to any modeled air quality issues onshore and at the State seaward boundary, or if a 

source category regulated by another Federal agency is the more likely the problem source.

Having the additional OCS oil and gas production platforms, support vessels, and helicopters 

associated with the 2017-2022 GOM Multisale EIS scenario as separate source groups allows 

BOEM to quantify the impact of these sources on the onshore air quality and at the State seaward 

boundary.
G-32 Gulf of Mexico Multisale EIS

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Air Quality: Emissions for the Cumulative and Visibility Impacts G-33

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Ozone Nonattainment Areas (2008 Standard). Internet website: https://www3.epa.gov/

airquality/greenbook/map8hr_2008.html. 

U.S. Environmental Protection Agency (USEPA). 2016b. 2014 National Emissions Inventory (NEI) 

Documentation. U.S. Environmental Protection Agency, Office of Air Quality Planning and 

Standards, Research Triangle Park, NC. Internet website: https://www.epa.gov/air-emissionsinventories/2014-national-emissions-inventory-nei-documentation. 
G-34 Gulf of Mexico Multisale EIS

Wilson, D., R. Billings, R. Chang, H. Perez, and J. Sellers. 2014. Year 2011 Gulfwide Emissions 

Inventory Study. U.S. Department of the Interior, Bureau of Ocean Energy Management, Gulf of 

Mexico OCS Region, New Orleans, LA. OCS Study BOEM 2014-666. 182 pp.
APPENDIX H 

 

AIR QUALITY: 

CUMULATIVE AND VISIBILITY IMPACTS

Table of Contents H-iii

TABLE OF CONTENTS

Page

H.1 Introduction.............................................................................................................................. H-1

H.1.1 Background on Air Quality Impact Analyses and Thresholds.................................... H-2

H.1.1.1 Ambient Air Quality Standards.................................................................... H-3

H.1.1.2 Air Quality Related Values.......................................................................... H-5

H.1.2 Overview of Approach ................................................................................................ H-6

H.2 Meteorology............................................................................................................................. H-7

H.3 Emissions ................................................................................................................................ H-8

H.3.1 Pollutants .................................................................................................................... H-9

H.3.2 Base Year................................................................................................................... H-9

H.3.3 Geographical Domain................................................................................................. H-9

H.3.4 Inventory Sources..................................................................................................... H-10

H.3.5 Spatial Resolution..................................................................................................... H-11

H.3.6 Temporal Resolution ................................................................................................ H-11

H.3.7 Speciation................................................................................................................. H-12

H.3.8 Base Year and Future Year Emission Estimates..................................................... H-12

H.3.9 Emissions Processing for Preparation of Model-Ready Emissions......................... H-12

H.3.9.1 Smoke Processing.................................................................................... H-12

H.3.9.2 Biogenic Emissions................................................................................... H-14

H.3.9.3 Fire Emissions........................................................................................... H-14

H.3.9.4 Sea Salt and Halogen Emissions ............................................................. H-15

H.3.9.5 Lightning NOx Emissions .......................................................................... H-16

H.3.9.6 Windblown Dust ........................................................................................ H-16

H.3.9.7 QA/QC of Processed Emissions............................................................... H-16

H.3.9.8 Development of Model-Ready Emissions................................................. H-17

H.3.9.9 Summary of Processed Emissions........................................................... H-18

H.3.10 Source Apportionment Design ................................................................................. H-33

H.4 Base Case Photochemical Grid Modeling............................................................................. H-34

H.4.1 Overview................................................................................................................... H-34

H.4.2 Model Grid Configuration.......................................................................................... H-35

H.4.3 Meteorology.............................................................................................................. H-37

H.4.4 Configuration of Model Input Parameters ................................................................ H-38

H.5 Model Performance Evaluation ............................................................................................. H-40

H.5.1 Implications of WRF Model Performance on PGM Simulations .............................. H-41

H.5.2 Ambient Data Used In the Model Performance Evaluation ..................................... H-41

H.5.3 Model Performance Statistics................................................................................... H-45

H.5.4 Approach .................................................................................................................. H-47
H-iv Gulf of Mexico Multisale EIS

H.5.5 Initial Model Performance Results............................................................................ H-49

H.5.6 Final Model Performance Results ............................................................................ H-49

H.5.6.1 Ozone........................................................................................................ H-50

H.5.6.2 Particulate Matter...................................................................................... H-57

H.6 Air Resource Assessment Approach .................................................................................... H-69

H.6.1 Future Year Modeling............................................................................................... H-69

H.6.1.1 Source Apportionment Design.................................................................. H-69

H.6.1.2 Future Year Source Apportionment Simulation........................................ H-70

H.6.2 Post-Processing of Future Year Source Apportionment Modeling Results............. H-71

H.6.2.1 Overview ................................................................................................... H-71

H.6.2.2 Comparison against NAAQS .................................................................... H-72

H.6.2.3 Impacts at Class I and Sensitive Class II Areas....................................... H-73

H.6.2.4 PSD Increments........................................................................................ H-80

H.7 Air Resource Assessment Results........................................................................................ H-80

H.7.1 NAAQS Impacts........................................................................................................ H-80

H.7.1.1 Ozone NAAQS Analysis using Relative Model Results ........................... H-80

H.7.1.2 Ozone NAAQS Analysis Using Absolute Modeling Results..................... H-89

H.7.1.3 PM2.5 NAAQS Analysis using Relative Model Results ........................... H-92

H.7.1.4 PM2.5 NAAQS Analysis using Absolute Model Predictions..................... H-99

H.7.1.5 NAAQS Analysis for other Criteria Air Pollutants ................................... H-106

H.7.2 PSD Increments...................................................................................................... H-120

H.7.3 AQRV Impacts........................................................................................................ H-122

H.7.3.1 Visibility ................................................................................................... H-122

H.7.3.2 Acid Deposition ....................................................................................... H-134

H.8 References .......................................................................................................................... H-137
List of Tables H-v 

LIST OF TABLES

Page

Table H-1. Nonattainment and Maintenance Areas in the Southeastern U.S.............................. H-4

Table H-3. 2012 Fire Criteria Air Pollutant Emissions Summary by Fire Type for BOEM’s 

36-, 12-, and 4-km Domains. .................................................................................... H-15

Table H-4. 2012 Base Case and Future Year Emissions Summary by State for BOEM’S 

12-km Domain (only Gulf Coast States: Alabama, Florida, Louisiana, 

Mississippi, and Texas)............................................................................................. H-18

Table H-5. 2012 Base Case and Future Year Emissions Summary by Source Category for 

BOEM’s 4-km Domain............................................................................................... H-26

Table H-6. Changes in Emissions between the 2012 Base Case and Future Year 

Emissions (short tons per year) by Source Category for BOEM’s 4-km Domain..... H-27

Table H-7. Source Categories for Source Apportionment Calculations..................................... H-34

Table H-8. Domain Grid Definitions for the WRF and CAMx/CMAQ Modeling.......................... H-35

Table H-9. Vertical Layer Interface Definition for WRF Simulations (left-most columns) 

and the Layer-collapsing Scheme for the CAMx/CMAQ Layers (right columns). .... H-36

Table H-10. CAMx Model Configuration....................................................................................... H-39

Table H-11. Definitions of Model Performance Evaluation Statistical Metrics. ............................ H-45

Table H-12. Ozone and PM Model Performance Goals and Criteria........................................... H-46

Table H-13. Model Performance Statistics at Different Observed Ozone Concentration 

Screening Thresholds Based on All Monitoring Sites in the 4-km Domain 

(shaded cells indicate values exceeding USEPA performance goals)..................... H-55

Table H-14. NAAQS and PSD Increments. .................................................................................. H-71

Table H-15. Source Group for Incremental Impacts Analysis. ..................................................... H-72

Table H-16. Class I and Sensitive Class II Areas in Gulf Coast and Nearby States.................... H-74

Table H-17. Current Year (DVC) and Future Year (DVF) Ozone Design Values at Ambient 

Air Monitoring Sites within the 4-km Modeling Domain from MATS......................... H-82

Table H-18. Ozone Current (DVC) and Future Year (DVF) Design Values and Reduction in 

DVF with Contributions from Individual Source Groups Removed. ......................... H-84

Table H-19. MATS Ozone Design Value Results for All Monitoring Sites Where Exclusion 

of Contributions from Source Group A or B is Sufficient to Reduce the 

Predicted Future Design Value (DVF) from Above the NAAQS to Below the 

NAAQS (all values in ppb). ....................................................................................... H-86

Table H-20. Current Year (DVC) and Future Year (DVF) 24-Hour PM2.5 Design Values for 

Monitoring Sites in the 4-km Modeling Domain from MATS..................................... H-93

Table H-21. 24-Hour PM2.5 Current (DVC) and Future Year (DVF) Design Values and 

Reduction in DVF with Contributions from Individual Source Groups Removed. .... H-94

Table H-22. Current (DVC) and Projected Future (DVF) Annual Average PM2.5 Design 

Values for Monitoring Sites in the 4-km Modeling Domain (highlighted values 

exceed the 12 μg/m3 NAAQS). ................................................................................. H-95
H-vi Gulf of Mexico Multisale EIS

Table H-23. Annual Average PM2.5 Future Year Design Values (DVF) and Change in DVF 

with Contributions from Individual Source Groups Removed (highlighted 

values exceed the 12 μg/m3 NAAQS)....................................................................... H-96

Table H-24. Maximum Source Group Contributions for PSD Pollutants at Class I and 

Sensitive Class II Areas in the 4-km Modeling Domain.......................................... H-121

Table H-25. Source Group Contributions for PSD Pollutants at All Class I and Sensitive 

Class II Areas in the 4-km Modeling Domain. ........................................................ H-123

Table H-26. Incremental Visibility Impacts Relative to Natural Background Conditions from 

Source Group A. ..................................................................................................... H-124

Table H-27. Incremental Visibility Impacts Relative to Natural Background Conditions from 

Source Group B. ..................................................................................................... H-125

Table H-28. Cumulative Visibility Results for 20% Worst Visibility Days (W20%) at Class I 

Areas for Base (2012) Year (BY) and Future Year (FY) Scenarios with All 

Sources Included and with Contributions from Each Source Group Removed. .... H-128

Table H-29. Differences in Cumulative Visibility Results for 20% Worst Visibility Days 

(W20%) at Class I Areas Between the Future Year (FY) and Base Year (BY) 

Scenarios and Contributions of Each Source Group to the Future Year 

Scenario Visibility.................................................................................................... H-130

Table H-30. Cumulative Visibility Results for 20% Best Visibility Days (B20%) at Class I 

Areas for Base (2012) Year (BY) and Future Year (FY) Scenarios with All 

Sources Included and with Contributions from Each Source Group Removed. .... H-132

Table H-31. Differences in Cumulative Visibility Results for 20% Best Visibility Days 

(B20%) at Class I Areas Between the Future Year (FY) and Base Year (BY) 

Scenarios and Contributions of Each Source Group to the Future Year 

Scenario Visibility.................................................................................................... H-133

Table H-32. Deposition Analysis Threshold Values (kg/ha/yr) as Defined in the Federal 

Land Manager Guidance (FLAG, 2010). ................................................................ H-135

Table H-33. Incremental Deposition Impacts from Source Groups A and B at Class I and 

Sensitive Class II Areas in the 4-km Domain. ........................................................ H-135

Table H-34. Cumulative Nitrogen (N) and Sulfur (S) Deposition Impacts (kg/ha/yr) under 

the Base and Future Year Scenarios (shading indicates values exceeding the 

Critical Load threshold). .......................................................................................... H-136
List of Figures H-vii

LIST OF FIGURES

Page

Figure H-1. Location of the “Air Quality Modeling in the Gulf of Mexico Region” Study, with 

Class I Areas (purple). ................................................................................................ H-1

Figure H-2. Ozone Nonattainment Areas in the Southeastern U.S............................................... H-3

Figure H-3. Class I and Sensitive Class II Areas in the Study Region.......................................... H-5

Figure H-4. Overview of the Gulf of Mexico OCS Region Air Quality Modeling Study Tasks 

(note that the meteorological model takes meteorological observations as 

inputs).......................................................................................................................... H-6

Figure H-5. Meteorological (WRF model) and PGM Modeling Domains Including the 36-km 

Horizontal Grid Resolution CONUS WRF Domain (outer box), 12-km 

Resolution Southeast Regional WRF (white) and PGM (blue) Domains (d02), 

and 4-km Resolution Gulf of Mexico OCS Region WRF (black) and PGM 

(blue) Domains (d03). ................................................................................................. H-8

Figure H-6. BOEM’s 12-km 2012 Base Case NOx Emissions Summary in Tons per Year 

by Source Category and State (Alabama, Florida, Louisiana, Mississippi, and 

Texas). ...................................................................................................................... H-19

Figure H-7. BOEM 12-km 2012 Base Case VOC Emissions Summary in Tons per Year by 

Source Category and State (Alabama, Florida, Louisiana, Mississippi, and 

Texas). ...................................................................................................................... H-20

Figure H-8. BOEM 12-km 2012 Base Case PM2.5 Emissions Summary in Tons per Year by 

Source Category and State (Alabama, Florida, Louisiana, Mississippi, and 

Texas). ...................................................................................................................... H-21

Figure H-9. BOEM 12-km 2012 Base Case SO2 Emissions Summary in Tons per Year by 

Source Category and State (Alabama, Florida, Louisiana, Mississippi, and 

Texas). ...................................................................................................................... H-22

Figure H-10. BOEM 12-km Future Year NOx Emissions Summary in Tons per Year by 

Source Category and State (Alabama, Florida, Louisiana, Mississippi, and 

Texas). ...................................................................................................................... H-23

Figure H-11. BOEM 12-km Future Year VOC Emissions Summary in Tons per Year by 

Source Category and State (Alabama, Florida, Louisiana, Mississippi, and 

Texas). ...................................................................................................................... H-24

Figure H-12. BOEM 12-km Future Year PM2.5 Emissions Summary in Tons per Year by 

Source Category and State (Alabama, Florida, Louisiana, Mississippi, and 

Texas). ...................................................................................................................... H-25

Figure H-13. BOEM 12-km Future Year SO2 Emissions Summary in Tons per Year by 

Source Category and State (Alabama, Florida, Louisiana, Mississippi, and 

Texas). ...................................................................................................................... H-26

Figure H-14. Spatial Distribution of (clockwise starting from top left) NOx, VOC, SO2, and 

PM2.5 Emissions (tons per year) from New OCS Oil and Gas Production 

Platforms under the Proposed Action....................................................................... H-29
H-viii Gulf of Mexico Multisale EIS

Figure H-15. Spatial Distribution of Emissions (tons per year) of (clockwise starting from top 

left) NOx, VOC, SO0, and PM2.5 from BOEM’s OCS Additional Oil and Gas 

Support Vessels and Helicopters under the Proposed Action Scenario.................. H-30

Figure H-16. Spatial Distribution of (clockwise starting from top left) NOx, VOC, SO2, and 

PM2.5 Emissions (tons per year) from BOEM’s OCS Oil and Gas Platforms, 

Support Vessels, and Helicopters under the No Action Alternative in BOEM’s 

4-km Domain............................................................................................................. H-31

Figure H-17. Spatial Distribution of (clockwise starting from top left) NOx, VOC, SO2, and 

PM2.5 Emissions (tons per year) from All Other Marine Vessel Activity in the 

Gulf of Mexico under the Future Year Scenario in BOEM’s 4-km Domain. ............. H-32

Figure H-18. Spatial Distribution of (clockwise starting from top left) NOx, VOC, SO2, and 

PM2.5 Emissions (tons per year) from Other Anthropogenic U.S. Sources for 

the Future Year Scenario within BOEM’s 4-km Domain. ......................................... H-33

Figure H-19. Ozone Monitoring Sites Used in the Model Performance Evaluation: CASTNet 

Sites in the Southeastern U.S. (top) and AQS Sites within the 4-km Modeling 

Domain (bottom) (color coding of AQS monitor locations is arbitrary)..................... H-42

Figure H-20. Speciated PM Monitoring Sites Used in the Model Performance Evaluation: 

CSN Network (top), IMPROVE Network (bottom left), and SEARCH Network 

(bottom right)............................................................................................................. H-44

Figure H-21. Monthly Normalized Mean Bias and Normalized Mean Error for Daily 

Maximum 8-hour Average Ozone at AQS (left) and CASTNet (right) Monitoring 

Sites Located within the 4-km Modeling Domain (top) and the 12-km Domain 

(bottom)..................................................................................................................... H-50

Figure H-22. Fraction of Site-days during Each Month of 2012 with Observed Daily 

Maximum 8-hour Ozone Exceeding 60 (top), 65 (middle), or 70 (bottom) ppb 

Over All Monitoring Sites in the 4-km Domain.......................................................... H-51

Figure H-23. Observed (blue) and Predicted (red) Monthly Mean Daily Maximum 8-hour 

Average Ozone Over All Sites in the 4-km Modeling Domain.................................. H-52

Figure H-24. Scatter (left) and Scatter Density (right) Plots for Observed vs. Predicted Daily 

Maximum 8-hour Ozone in Q2 (top) and Q3 (bottom) for All AQS Monitoring 

Sites in the 4-km Modeling Domain.......................................................................... H-53

Figure H-25. Normalized Mean Bias (NMB) for Daily Maximum 8-hour Ozone for Q2 (top) 

and Q3 (bottom)........................................................................................................ H-54

Figure H-26. Time Series of Daily Maximum 8-hour Ozone at Monitoring Sites with Highest 

Design Values in Harris (top), Brazoria (middle), and Galveston (bottom) 

Counties, Texas, for Q2 (left) and Q3 (right). ........................................................... H-56

Figure H-27. Time Series of Daily Maximum 8-hour Ozone at Monitoring Sites in the Baton 

Rouge Nonattainment Area: LSU (top) and Carville (bottom) for Q2 (left) and 

Q3 (right). .................................................................................................................. H-56

Figure H-28. Time Series of Daily Maximum 8-hour Ozone at the ALC188 (AlabamaCoushatta, Texas) CASTNet Monitoring Site for Q2 (top) and Q3 (bottom)............ H-57

Figure H-29. PM Monitoring Sites in the Southeastern U.S. Domain (triangles – AQS hourly, 

square – IMPROVE, diamond – CSN, circles – AQS FRM daily). ........................... H-59
List of Figures H-ix

Figure H-30. Soccer Plots of Total PM2.5 Mass Model Performance Across the IMPROVE 

(top left), CSN (top right), SEARCH (bottom left), and FRM Daily (bottom right) 

Monitoring Networks for Sites in the Southeastern U.S. Domain............................. H-60

Figure H-31. Comparisons of Predicted with Observed Daily Average PM at CSN Network 

Sites in the Southeastern U.S. for Q2 (left) and Q4 (right) for Total PM2.5 (top), 

Other PM2.5 (middle), and Sodium (bottom). ............................................................ H-61

Figure H-32. Comparisons of Observed vs. Predicted OC (top) and EC (bottom) at 

SEARCH (left) and CSN (right) Network Sites in the Southeastern U.S.................. H-62

Figure H-33. Monthly Normalized Mean Bias and Normalized Mean Error for Hourly NO2

(top) and Daily NOy (bottom) at SEARCH Network Sites (left) and AQS Sites 

(right) in the 4-km Domain. ....................................................................................... H-63

Figure H-34. Monthly Normalized Mean Bias and Normalized Mean Error for NO3 at 

SEARCH Network Monitoring Sites (top left) and AQS Sites (top right) and 

NO3 Deposition at NADP Sites (bottom) in the Southeastern U.S. (Note: 

Additional months for SEARCH NO3 not shown as the NMB and NME exceed 

the upper axis limits.)................................................................................................ H-64

Figure H-35. Monthly Normalized Mean Bias and Normalized Mean Error at Monitoring 

Sites in the 4-km Domain for SO2 (top row, AQS sites left panel, SEARCH 

sites right panel), SO4 (middle row, CSN sites left panel, SEARCH sites right 

panel), and SO4 Deposition Measured at NADP Sites (bottom row). ...................... H-66

Figure H-36. Annual Normalized Mean Bias for Hourly SO2 (based on 12-km resolution 

CAMx results)............................................................................................................ H-67

Figure H-37. Monthly Normalized Mean Bias and Normalized Mean Error for Daily Average 

NH4 at CSN (top) and SEARCH (bottom) Network Sites in the 4-km Modeling 

Domain...................................................................................................................... H-68

Figure H-38. Monthly Normalized Mean Bias and Normalized Mean Error for Hourly CO at 

SEARCH Network Sites (left) and AQS Sites (right). ............................................... H-69

Figure H-39. Class I and Sensitive Class II Areas for Which Incremental AQ/AQRV Impacts 

Were Calculated........................................................................................................ H-73

Figure H-40. Base Scenario Ozone Design Values (DVC, top left), Future Year Ozone 

Design Values (DVF, top right) and Their Differences (DVF – DVC; bottom) 

Calculated Using the MATS UAA Tool. .................................................................... H-87

Figure H-41. MATS UAA Future Year Ozone Design Values (DFV) Calculated After First 

Removing the Hourly Contributions from a Source Group (left column) and the 

Corresponding Contributions of the Source Group to DVF (right column) 

Calculated by Subtracting the DVFs Shown in the Left-hand Column from the 

“All Sources” DVF Shown in the Top Right-hand Corner of Figure H-40................. H-88

Figure H-42. Modeled 4th Highest MDA8 Ozone for the Base Year (upper left) and Future 

Year (upper right) Scenarios and Their Differences (bottom center). ...................... H-89

Figure H-43. Contributions of Source Groups A (top left), B (top right), C (middle left), D 

(middle right), and E (bottom) to Future Year All-sources 4th Highest MDA8

(note different color scales in each panel)................................................................ H-91
H-x Gulf of Mexico Multisale EIS

Figure H-44. Contributions from (left) Source Group F (natural and non-US emission 

sources including boundary conditions) and (right) Boundary Conditions Only, 

to Future Year All-sources 4th Highest MDA8. .......................................................... H-92

Figure H-45. Current Year (DVC) and Future Year (DVF) Annual Average PM2.5 Design 

Values from the MATS Unmonitored Area Analysis (top left and top right, 

respectively) and the Difference, DVF – DVC (bottom)............................................ H-98

Figure H-46. Contributions of Source Groups A (top left), B (top right), C (middle left), D 

(middle right), and E (bottom) to the Future Year All-sources Annual Average 

PM2.5 Concentration Based on the MATS Unmonitored Area Analysis (note 

different color scales used in each panel). ............................................................... H-99

Figure H-47. Modeled 8th Highest Daily Average PM2.5 Concentrations for the Base Year 

(top left), Future Year (top right), and the Future – Base Difference (bottom)....... H-101

Figure H-48. Contributions of Source Groups A (top left), B (top right), C (middle left), D 

(middle right), and E (bottom) to the Future Year All-sources 8th Highest Daily 

Average PM2.5 Concentration (note different color scales used in each panel)..... H-102

Figure H-49. Contributions from (left) Source Group F (natural and non-U.S. emission 

sources including boundary conditions) and (right) Boundary Conditions Only 

to Future Year All-sources 8th Highest 24-hour PM2.5 (note use of different 

color scale in each panel). ...................................................................................... H-103

Figure H-50. Modeled Annual Average PM2.5 Concentrations for the Base Year (top left), 

Future Year (top right), and the Future – Base Difference (bottom). ..................... H-104

Figure H-51. Contributions of Source Group A (top left), B (top right), C (middle left), D 

(middle right), and E (bottom) to the Future Year All-sources Annual Average 

PM2.5 Concentration (note use of different color scales in each panel). ................ H-105

Figure H-52. Contributions from (left) Source Group F (natural and non-U.S. emission 

sources including boundary conditions) and (right) Boundary Conditions Only 

to Future Year All-sources Annual Average PM2.5 (note use of different color 

scale in each panel). ............................................................................................... H-106

Figure H-53. Modeled 2nd Highest 24-hour Average PM10 Concentrations for the Base Year 

(top left), Future Year (top right), and the Future – Base Difference (bottom)....... H-107

Figure H-54. Contributions of Source Groups A (top left), B (top right), C (middle left), D 

(middle right), and E (bottom) to the Future Year All-sources 2nd Highest Daily 

Average PM10 Concentration (note use of different color scales in each panel). .. H-108

Figure H-55. Contributions from (left) Source Group F (natural and non-U.S. emission 

sources including boundary conditions) and (right) Boundary Conditions Only 

to Future Year All-sources 2nd Highest Daily Average PM10 Concentration 

(note use of different color scale in each panel)..................................................... H-109

Figure H-56. Modeled 8th Highest 1-hour NO2 Concentrations for the Base Year (top left), 

Future Year (top right), and the Future – Base Difference (bottom). ..................... H-110

Figure H-57. Contributions of Source Group A (top left), B (top right), C (middle left), D 

(middle right), and E (bottom) to the Future Year All-sources 8th Highest Daily 

Average NO2 Concentrations (note use of different color scales in each panel)... H-111
List of Figures H-xi

Figure H-58. Modeled Annual Average NO2 Concentrations for the Base Year (top left), 

Future Year (top right), and the Future – Base Difference (bottom). ..................... H-112

Figure H-59. Contributions of Source Groups A (top left), B (top right), C (middle left), D 

(middle right), and E (bottom) to the Future Year All-sources Annual Average 

NO2 Concentrations. ............................................................................................... H-113

Figure H-60. Modeled 4th Highest Daily Maximum 1-hour SO2 Concentrations for the Base 

Year (top left), Future Year (top right), and the Future – Base Difference 

(bottom)................................................................................................................... H-115

Figure H-61. Contributions of Source Group A (top left), B (top right), C (middle left), D 

(middle right), and E (bottom) to the Future Year All-sources 4th Highest Daily 

Maximum 1-hour SO2 Concentration (note different color scales used in each 

panel). ..................................................................................................................... H-116

Figure H-62. Modeled Annual 2nd Highest Block 3-hour SO2 Concentrations for the Base 

Year (top left), Future Year (top right), and the Future – Base Difference 

(bottom)................................................................................................................... H-117

Figure H-63. Contributions of Source Group A (top left), B (top right), C (middle left), D 

(middle right), and E (bottom) to the Future Year All-sources 2nd Highest 3-

hour Block Average SO2 Concentration (note different color scales used in 

each panel).............................................................................................................. H-118

Figure H-64. Modeled Annual 2nd Highest Non-overlapping Running 8-hour Average CO 

Concentrations for the Base Year (top left), Future Year (top right), and the 

Future – Base Difference (bottom). ........................................................................ H-119

Figure H-65. Modeled Annual 2nd Highest 1-hour Average CO Concentrations for the Base 

Year (top left), Future Year (top right), and the Future – Base Difference 

(bottom)................................................................................................................... H-120

Abbreviations and Acronyms H-xiii

ABBREVIATIONS AND ACRONYMS

ANC acid neutralizing capacity

AQRV air quality related value(s)

BLM Bureau of Land Management (U.S. Department of the Interior)

CAMx Comprehensive Air quality Model with eXtensions

CH4 methane

CO carbon monoxide

CO2 carbon dioxide

DAT Deposition Analysis Threshold

dv deciview

DVB design value for base year

DVC design value for current (base) year

DVF design value for future year

FLAG Federal Land Managers’ Air Quality Related Values Workgroup

GHG greenhouse gas

HAP(s) hazardous air pollutant(s)

hp horsepower

hr hour(s)

IMPROVE Interagency Monitoring of Protected Visual Environments

kg/ha-yr kilogram(s) per hectare - year

km kilometer(s)

m meter(s)

MATS Modeled Attainment Test Software

mcf Thousand cubic feet

MDA8 Annual 4th highest daily maximum running 8-hour average (concentration)

Mm-1 inverse megameters

N2O Nitrous oxide

NAAQS National Ambient Air Quality Standards

NO2 nitrogen dioxide 

NOx total oxides of nitrogen

O3 ozone

PM2.5 fine particulate matter (less than 2.5 microns in effective diameter)

PM10 inhalable particulate matter (less than 10 microns in effective diameter)

ppb parts per billion

ppm parts per million

PSD Prevention of Significant Deterioration

RRF Relative Reduction Factor

SO2 sulfur dioxide

tpy tons per year

UAA Unmonitored Area Analysis
H-xiv Gulf of Mexico Multisale EIS

USDOI United States Department of the Interior

USEPA United States Environmental Protection Agency

VOC volatile organic compounds

WRF Weather Research and Forecasting model

yr year

μeq/l microequivalent(s) per liter

μg/m3 microgram(s) per cubic meter
Air Quality: Cumulative and Visibility Impacts H-1 

H AIR QUALITY: CUMULATIVE AND VISIBILITY IMPACTS

H.1 INTRODUCTION

The U.S. Department of the Interior’s Bureau of Ocean Energy Management (BOEM) is 

required under the Outer Continental Shelf Lands Act (OCSLA) (43 U.S.C. § 1334(a)(8)) to comply 

with the National Ambient Air Quality Standards (NAAQS) to the extent that Outer Continental Shelf 

(OCS) offshore oil and gas exploration, development, and production sources do not significantly 

affect the air quality of any state. The Gulf of Mexico OCS Region’s area of possible influence 

includes the States of Texas, Louisiana, Mississippi, Alabama, and Florida. BOEM’s Gulf of Mexico 

OCS Region manages the responsible development of oil, gas, and mineral resources for the 

430 million acres in the Western, Central, and Eastern Planning Areas (WPA, CPA, and EPA) on the 

OCS comprising the Gulf of Mexico region, including the areas under moratoria (shown in Figure

H-1). The Clean Air Act Amendments (CAAA) of 1990 designate air quality authorities in the Gulf of 

Mexico OCS Region, giving BOEM air quality jurisdiction westward of 87°30'W. longitude and the 

U.S. Environmental Protection Agency (USEPA) air quality jurisdiction eastward of 87°30'W. 

longitude. In 2006, oil and gas leasing operations within 125 miles (201 kilometers [km]) off the 

Florida coastline were placed under moratoria until 2022 under the Gulf of Mexico Energy Security 

Act (GOMESA). The GOMESA moratoria area is depicted on Figure H-1. 

Figure H-1. Location of the “Air Quality Modeling in the Gulf of Mexico Region” Study, 

with Class I Areas (purple). 

BOEM is currently developing the Gulf of Mexico OCS Oil and Gas Lease Sales: 

2017-2022; Gulf of Mexico Lease Sales 249, 250, 251, 252, 253, 254, 256, 257, 259, and 261—

Final Multisale Environmental Impact Statement (2017-2022 GOM Multisale EIS) for oil and gas 
H-2 Gulf of Mexico Multisale EIS

resources under its jurisdiction within the Gulf of Mexico’s WPA, CPA, and EPA (the Proposed 

Action). 

On August 26, 2014, BOEM contracted with Eastern Research Group, Inc. (ERG) and team 

members Ramboll Environ US Corporation (Ramboll Environ) and Alpine Geophysics, LLC (Alpine) 

to complete a comprehensive air quality modeling study in the Gulf of Mexico OCS region. Under 

BOEM Contract Number M14PC00007, “Air Quality Modeling in the Gulf of Mexico Region,”

photochemical air quality modeling was conducted to assess impacts to nearby states of OCS oil 

and gas exploration, development, and production as required under OCSLA. This assessment is 

being used by BOEM to disclose potential incremental and cumulative air quality impacts of a 

proposed action in the 2017-2022 GOM Multisale EIS. This Technical Support Document (TSD) 

provides a detailed description of the data, modeling procedures, and results of the Air Quality 

Impact Analysis (AQIA). BOEM will use this information to complete its analysis of potential impacts 

of a proposed action on air quality in the 2017-2022 GOM Multisale EIS.

H.1.1 Background on Air Quality Impact Analyses and Thresholds

This analysis examines the potential impacts of the 2017-2022 GOM Multisale EIS scenario 

with respect to the following: 

• the NAAQS for the criteria pollutants ozone (O3), nitrogen dioxide (NO2), sulfur 

dioxide (SO2), carbon monoxide (CO), fine particulate matter with aerodynamic 

diameter less than 2.5 μm (PM2.5) and fine plus coarse particulate matter with 

aerodynamic diameters less than 10 μm (PM10); 

• air quality related values (AQRV), including visibility and acid deposition (sulfur 

and nitrogen) in nearby Class I and sensitive Class II areas (as defined below); 

and 

• incremental impacts of Prevention of Significant Deterioration (PSD) pollutants 

(NO2, PM10, PM2.5) with respect to PSD Class I and Class II increments. 

Note that the PSD increments are provided here for information purposes, but this analysis 

does not constitute a regulatory PSD increment consumption analysis as would be required for 

major sources subject to the New Source Review (NSR) program requirements of the Clean Air Act. 

Results of each impact analysis are compared with applicable “thresholds of concern,” which 

have typically been used in air quality impact evaluations of other Federal actions, including onshore 

oil and gas leasing programs. The applicable comparison thresholds for criteria pollutant impacts 

are the corresponding NAAQS. For acid (i.e., sulfur and nitrogen) deposition impacts, thresholds are 

based on (a) incremental impacts considered sufficiently small as to have no consequential effect on 

the receiving ecosystems, i.e., Deposition Analysis Thresholds, and (b) critical load levels above 

which cumulative ecosystem effects are likely to or have been observed. For visibility impacts, 

thresholds are based on incremental changes in light extinction below the level at which they would 
Air Quality: Cumulative and Visibility Impacts H-3 

be noticeable to the average human observer. Additional information about these various thresholds 

is provided in relevant sections in the remainder of this appendix. 

H.1.1.1 Ambient Air Quality Standards

The USEPA has set NAAQS for six regulated air quality pollutants: ozone, particle pollution 

(PM2.5 and PM10), SO2, NO2, CO, and lead (Pb). After promulgation of a NAAQS, the USEPA 

designates areas that fail to achieve the NAAQS as nonattainment areas (NAAs), and States are 

required to submit State Implementation Plans (SIPs) to the USEPA that contain emission control 

plans and a demonstration that the NAA will achieve the NAAQS by the required date. After an area 

comes into attainment of the NAAQS, the area can be redesignated as a maintenance area and 

must continue to demonstrate compliance with the NAAQS.

In 1997, the USEPA promulgated the first 8-hour ozone NAAQS with a threshold of 

0.08 parts per million (ppm) (84 parts per billion [ppb]). On March 12, 2008, the USEPA 

promulgated a more stringent 0.075 ppm (75 ppb) 8-hour ozone NAAQS. Figure H-2 presents the 

current ozone nonattainment areas in the southeastern U.S. On October 1, 2015, the USEPA 

strengthened the 8-hour NAAQS for ozone to 0.07 ppm (70 ppb). Under this more stringent ozone 

NAAQS, there may be more areas in the southeastern U.S. that will be in nonattainment. The 

USEPA plans to make attainment and nonattainment designations for the revised standards by 

October 2017, with the designations based on 2014-2016 air quality data.

Figure H-2. Ozone Nonattainment Areas in the Southeastern U.S. (Source: USEPA, 2016; 

https://www3.epa.gov/airquality/greenbook/map8hr_2008.html). 

On December 14, 2012, the USEPA revised the PM2.5 primary NAAQS by lowering the 

annual PM2.5 NAAQS threshold from 15.0 micrograms per cubic meter (μg/m3

) to 12.0 μg/m3. The 

USEPA retained the 24-hour PM2.5 primary NAAQS at 35 μg/m3

. The 24-hour course PM NAAQS 

(PM10) was also retained at 150 μg/m3

. 
H-4 Gulf of Mexico Multisale EIS

In February 2010, the USEPA issued a new 1-hour NO2 NAAQS with a threshold of 100 ppb 

(98th percentile daily maximum 1-hour average averaged over 3 years) and a new 1-hour SO2

NAAQS was promulgated in June 2010 with a threshold of 75 ppb (99th percentile daily maximum 

1-hour average averaged over 3 years). No areas are currently in nonattainment of either the 

annual or 1-hour NO2 NAAQS. On July 25, 2013, the USEPA designated 29 areas in 16 states as 

nonattainment for the 1-hour SO2 standard.1

 In June 2016, four additional areas were designated as 

nonattainment (Madison and Williamson Counties in southern Illinois, Anne Arundel-Baltimore 

Counties in Maryland and St. Clair County in Michigan).2

 The USEPA is currently in the process of 

gathering more information needed to complete designation of remaining unclassifiable areas with 

respect to the 1-hour SO2 NAAQS.

A new lead NAAQS was issued in 2008; NAAs for lead are associated with specific industrial 

sources. As oil and gas sources in the Gulf of Mexico OCS region produce negligible amounts of 

lead emissions and to be consistent with onshore oil and gas analysis, which does not include lead, 

lead emissions were calculated but lead was not included in the air quality analysis. The NAAQS for 

carbon monoxide has remained essentially unchanged since it was originally promulgated in 1971. 

As of September 27, 2010, all NAAs for carbon monoxide have been redesignated as maintenance 

areas.

Table H-1 summarizes the nonattainment and maintenance areas in the southeastern U.S. 

SO2 and lead NAAs are focused around specific large industrial sources of SO2 or lead emissions, 

whereas ozone nonattainment areas are more regional in nature, reflecting the formation of ozone 

as a secondary pollutant from emissions of NOx and VOC precursors from a wide range of sources.

Table H-1. Nonattainment and Maintenance Areas in the Southeastern U.S.

State Area 8-hr O3 

(1997)

8-hr O3 

(2008)

SO2

(2010)

CO 

(1971)

Lead 

(2008)

Alabama Troy, AL NAAa

Florida

Tampa, FL NAA

Hillsborough County, FL NAA

Nassau County, FL NAA

Louisiana Baton Rouge, LA Mb NAA

St. Bernard Parish, LA NAA

Texas

Beaumont-Port Arthur, TX M

Houston-GalvestonBrazoria, TX NAA NAA

Frisco, TX NAA

 

1 https://www.epa.gov/sites/production/files/2016-03/documents/20130725fs.pdf 2 https://www.epa.gov/sites/production/files/2016-06/documents/so2d-r2-area-list.pdf
Air Quality: Cumulative and Visibility Impacts H-5 

State Area 8-hr O3 

(1997)

8-hr O3 

(2008)

SO2

(2010)

CO 

(1971)

Lead 

(2008) a NAA = nonattainment area. b

 M = maintenance area. 

Blank cells indicate the area is in attainment of the NAAQS. 

H.1.1.2 Air Quality Related Values

The CAAA designated 156 Class I areas consisting of National Parks and Wilderness Areas 

that are offered special protection for air quality and AQRVs. The Class I areas, compared to Class 

II areas, have lower PSD increments that new sources may not exceed and are protected against 

excessive increases in several AQRVs including visibility impairment, acid (sulfur and nitrogen) 

deposition, and nitrogen eutrophication. The Regional Haze Rule (RHR) specifies a goal of 

achieving “natural” visibility conditions by 2064 in Class I areas, and States must submit RHR SIPs 

that demonstrate progress towards that goal. Figure H-1 displays the locations of the mandatory 

Class I areas (in purple) in the Gulf of Mexico OCS region. 

In addition to the Class I areas described above, Federal Land Management (FLM) agencies 

have designated certain other areas as Class II sensitive areas for tracking PSD increment 

consumption and AQRV impacts. Sensitive Class II areas in the southeastern U.S. Study region are 

shown in Figure H-3. 

Figure H-3. Class I and Sensitive Class II Areas in the Study Region.
H-6 Gulf of Mexico Multisale EIS

H.1.2 Overview of Approach

The Comprehensive Air-quality Model with extensions (CAMx; www.camx.com) and 

Community Multiscale Air Quality (CMAQ; https://www.cmascenter.org/cmaq/) Photochemical Grid 

Models (PGMs) were used to simulate the dispersion and chemical transformation of pollutants over 

the Study area. Similar to other air quality models, CAMx/CMAQ require several input datasets, 

including meteorology and an emissions inventory. Figure H-4 presents an overview of how these 

project datasets fit together for the “Air Quality Modeling in the Gulf of Mexico OCS Region” study. 

Preparation of the required meteorological and emissions data is described briefly in this TSD, along 

with references to more detailed reports.

Photochemical modeling was conducted for two emission scenarios:

• a base case scenario using the 2012 base year (BY) emissions inventory 

described in Section H.3 was used to evaluate model performance and to define 

current baseline air quality conditions; and

• a future year development scenario (FY) using an emissions inventory that 

includes potential new sources associated with the 2017-2022 GOM Multisale 

EIS and projections of emissions to 2017 for all other sources as described in 

Section H.3 was used to estimate the cumulative and incremental air quality and 

AQRV impacts of the 2017-2022 GOM Multisale EIS scenario.

Note that both scenarios used the same meteorological dataset and the same photochemical 

model configuration. 

Figure H-4. Overview of the “Air Quality Modeling in the 

Gulf of Mexico Region” Study Tasks (note that 

the meteorological model takes meteorological 

observations as inputs).
Air Quality: Cumulative and Visibility Impacts H-7 

H.2 METEOROLOGY

Meteorological datasets required to determine the rate that pollutants disperse and react in 

the atmosphere include spatially and temporally varying parameters such as wind speed, wind 

direction, air temperature, and humidity, among others. Sources of meteorological information 

include datasets of measurements gathered at various locations within the Gulf of Mexico OCS 

Region domain. However, the spatial coverage of measurements is insufficient to describe the 

three-dimensional structure of the atmosphere away from measurement locations. Using 

measurement data as inputs, gridded meteorological models capable of simulating the fluid 

dynamics of the atmospheric can be used to estimate meteorological conditions over a complete 

modeling domain—including regions far from measurement sites—in a physically consistent fashion. 

Results of these meteorological models provide the inputs needed to exercise the photochemical 

grid air quality dispersion models used in this Study. For this “Air Quality Modeling in the Gulf of 

Mexico Region” study, the Advanced Research version of the Weather and Research Forecasting 

(WRF) model (version 3.7) was applied over a system of nested modeling grids. Figure H-5 shows 

the WRF modeling grids at horizontal resolutions of 36, 12, and 4 km. All WRF grids were defined 

on a Lambert Conformal Conic (LCC) projection centered at 40°N. latitude, 97°W. longitude with true 

latitudes at 33°N. and 45°N. (the “standard RPO” projection). The outermost domain (outer box) 

with 36-km resolution includes the entire continental U.S. and parts of Canada and Mexico, and 

captures synoptic-scale (storm system-scale) structures in the atmosphere. The inner 12-km 

regional grid (d02) covers the southeastern U.S. and is used to ensure that large-scale 

meteorological patterns across the region are adequately represented and to provide boundary 

conditions to the 4-km domain. The 4-km domain (d03) is centered on the coastal areas of the 

southeastern U.S. and over-water portions of the Gulf of Mexico.
H-8 Gulf of Mexico Multisale EIS

Figure H-5. Meteorological (WRF model) and PGM Modeling Domains 

Including the 36-km Horizontal Grid Resolution CONUS 

WRF Domain (outer box), 12-km Resolution Southeast 

Regional WRF (white) and PGM (blue) Domains (d02), and 

4-km Resolution Gulf of Mexico OCS Region WRF (black) 

and PGM (blue) Domains (d03).

The WRF ran the 36-, 12- and 4-km grids simultaneously with one-way nesting, meaning that 

meteorological information flows down-scale via boundary conditions introduced from the respective 

coarser to finer grids without feedback from the finer to coarser grids. The WRF modeling domain 

was defined to be slightly larger than the CAMx/CMAQ PGM modeling domains to eliminate 

boundary artifacts in the meteorological fields. Such boundary artifacts occur for both numerical 

reason (the 3:1 grid spacing ratio) and because the imposed boundary conditions require some 

time/space to come into dynamic balance with WRF’s atmospheric equations. All meteorological 

modeling domains, techniques, inputs, vertical resolution, parameters, nudging, physics options, and 

application strategy, along with quantitative and qualitative evaluation procedures and statistical 

benchmarks, are discussed in Appendix F. 

H.3 EMISSIONS

Analysis of the cumulative air quality impacts of the 2017-2022 GOM Multisale EIS scenario 

required development of both a contemporary base year emissions inventory for the base case 

analysis and a projected future year inventory that includes emissions from all cumulative sources, 

as well as additional emissions anticipated to occur under the 2017-2022 GOM OCS Multisale EIS 

alternatives in which additional exploratory drilling and construction of new shallow-water and 

deepwater platforms to support oil and gas production would occur. Both the base case and future 
Air Quality: Cumulative and Visibility Impacts H-9 

year cumulative source inventories represent comprehensive compilations of pollutant emissions 

from all human activities, as well as emissions from biogenic and geogenic sources. 

The scope of the air pollutant emissions inventory for the “Air Quality Modeling in the Gulf of 

Mexico Region” study is defined in terms of: pollutants, representative time periods for the base 

case and future year analysis, geographical domain, and sources to be included.

H.3.1 Pollutants

Pollutants included in the inventories were selected to support analysis of air quality impacts 

in terms of impacts on attainment of NAAQS and on AQRVs, including acid deposition and visibility. 

The selected pollutants are: CO, NOx (which includes NO and NO2 and is stated in terms of 

equivalent mass of NO2), PM2.5, fine plus coarse PM (PM10), SO2, volatile organic compounds 

(VOCs, which are precursors to formation of ozone and organic particulates), and ammonia (NH3, a 

precursor to particulate matter formation). Note that lead emissions were calculated since lead is a 

criteria pollutant, but since oil and gas sources have negligible lead emissions, it was not modeled 

in the air quality analysis.

While the cumulative air quality impact analysis did not focus specifically on air toxics, 

compilation of VOC emissions by source type together with VOC speciation profiles by source type 

provides a mechanism for estimating emissions of individual air toxic species. 

H.3.2 Base Year

In determining the base case (base year) for the “Air Quality Modeling in the Gulf of Mexico 

Region” study emissions inventory, 2011 was initially selected based on data availability. Calendar 

year 2011 emissions data are readily available for most sources from the USEPA’s National 

Emissions Inventory (NEI) (USEPA, 2015a) and BOEM’s Year 2011 Gulfwide Emissions Inventory 

Study (Wilson et al., 2014). However, 2011 was an unusually hot and dry year in the Gulf of Mexico 

OCS region, particularly in Texas, which experienced record heat and dry conditions during the 

summer of 2011 and had a very high incidence of wildfires. Therefore, 2012 was selected as the 

base year as more representative of “typical” conditions in the Gulf of Mexico OCS region. 

H.3.3 Geographical Domain

Modeling domains used for the “Air Quality Modeling in the Gulf of Mexico Region” study

emissions inventory are depicted in Figure H-5. Emissions were spatially allocated over the three 

PGM modeling domains: an outer 36-km horizontal grid resolution domain covering all of the U.S. 

and parts of Mexico and Canada; a regional 12-km resolution domain covering the southeastern 

U.S.; and an inner 4-km domain encompassing the CPA and WPA. The influences of global 

emissions on the study area are accounted for by the use of a global air quality model to specify 

domain boundary conditions. 
H-10 Gulf of Mexico Multisale EIS

H.3.4 Inventory Sources

A comprehensive inventory of emissions from anthropogenic (i.e., human caused) sources, 

including stationary point and nonpoint area sources located both onshore and offshore, onroad 

motor vehicles, nonroad equipment, locomotives, marine vessels and other offshore sources, and 

airports, were compiled for the “Air Quality Modeling in the Gulf of Mexico Region” study emissions 

inventory. Table H-2 lists the source categories included in the emissions inventory, along with the 

pollutants applicable to each category, and the source type (area source, point source, offshore 

lease block). Note that emissions from non-anthropogenic sources (biogenic and geogenic sources) 

were developed in conjunction with the emissions modeling procedures described in Section H.3.9. 

Table H-2. Gulf of Mexico OCS Region Air Quality Modeling Study Source Categories. 

Group and Source Category CO NOx SO2 VOC Pb PM2.5 PM10 NH3 Source Typea NEI Onshore Sources

Point Sources         P 

Nonpoint Area 

Sources         A 

Onroad Mobile 

Sources        A 

Commercial Marine 

Vessels         P, Ab

Locomotives         P, Ac

Aircraft and Airports         P

Other Nonroad 

Mobile Sources        A 

Offshore Oil and Gas Sources

Platforms in State 

Waters       P 

Platforms in the CPA 

and WPA         P 

Drilling Rigs         LB

Pipelaying Vessels         LB

Support Helicopters        LB

Support Vessels         LB

Survey Vessels         LB

Non-oil 

& Gas 

Offshore Vessels and 

Activities

Commercial Fishing 

Vessels         LB

Commercial Marine 

Vessels         LB

Louisiana Offshore Oil 

Port         P 

Military Vessels         LB

Recreational Vessels        LB
Air Quality: Cumulative and Visibility Impacts H-11

Group and Source Category CO NOx SO2 VOC Pb PM2.5 PM10 NH3 Source Typea

Vessel Lightering         P

Biogenic and 

Geogenic Sources

Subsurface Oil Seeps  LB

Mud Volcanoes  LB

Onshore Vegetation   A

Wildfires and 

Prescribed Burning        P 

Windblown Dust   A

Lightning  A

Sea Salt Emissions   A

Sources in Mexico 

and Canada

Point Sources        P 

Nonpoint Area 

Sources       A 

Mobile Sources       A 

a A = area source (requires spatial surrogate); P = point source (requires UTM coordinates, stack 

parameters); LB = offshore lease block (requires GIS shape file). b Larger ports and shipping represented as shape files; smaller ports as point sources.

c Rail yards represented as point sources; railway segments as area sources.

H.3.5 Spatial Resolution

The spatial resolution of the emissions inventory is source specific. For example, sources 

such as power plants are identified based on their geographic coordinates (i.e., latitude and 

longitude), while other sources such as nonroad mobile sources (e.g., construction equipment) are 

spatially distributed using surrogates within the county in which they are reported and that are 

typically related to the activity distribution of the category (e.g., construction sites).

The resolution of the geographical area covered by the emissions inventory is based on the 

grid cell size needed for photochemical and dispersion modeling. Furthermore, the photochemical 

model grid resolution is dependent on the grid resolution of the WRF meteorological model output 

used. This is described further in Section H.3.9. 

H.3.6 Temporal Resolution

Emissions for all sources were estimated on an annual basis (i.e., emissions generated 

during 2012). For electric generating units (EGUs), emissions were allocated on a sub-annual basis 

to reflect variations in activity using data from the USEPA. Emissions were allocated on an hourly, 

daily, and seasonal basis during the emissions modeling process (Section H.3.9) using default 

temporal allocation factors provided with the Sparse Matrix Operator Kernel Emissions model 

(SMOKE) emissions model for some sources; other temporal allocations were source specific; and 

profiles were developed and applied within the SMOKE model. 
H-12 Gulf of Mexico Multisale EIS

H.3.7 Speciation

When applying the photochemical grid modeling, PM emissions were allocated to individual 

PM species as part of the SMOKE emissions processing using PM speciation factors obtained from 

the USEPA’s SPECIATE database for each source category (as defined by the Source Classification 

Code). This resulted in the PM mass being broken into the mass associated with elemental carbon 

(EC), organic aerosol (OA), primary sulfate (SO4) and nitrate (NO3) and other elements, and particlebound VOCs, such as polycyclic aromatic hydrocarbon (PAHs). The model predictions of EC will 

undergo for further analysis and discussed in the “Air Quality Modeling in the Gulf of Mexico Region” 

study final report. 

SMOKE was also used to convert VOC emissions into the photochemical mechanismspecific (e.g., CB05 or CB6r2h) model species used in air quality models as described in 

Section H.3.9. The CB6r2h chemical mechanism used in CAMx also models excess methane 

(ECH4) from local sources that is added to the background methane value (1.75 ppm) in the 

chemical mechanism. The excess methane species is calculated as part of the speciation of the 

VOC emissions that are first adjusted to total organic gases (TOG) before calculating the CB6 

chemical species. Thus, the excess methane species only includes methane emissions from local 

VOC sources (e.g., oil and gas) and will not include methane emissions not associated with VOC 

sources. 

H.3.8 Base Year and Future Year Emission Estimates

Details on the development of the base year and future year emission estimates are 

presented in Appendix G. 

H.3.9 Emissions Processing for Preparation of Model-Ready Emissions

H.3.9.1 Smoke Processing

Anthropogenic emissions inventories discussed in the previous section and other data were 

used to prepare PGM model-ready emission files using the Sparse Matrix Operator Kernel 

Emissions (SMOKE) system version 3.6 and other methods as described below. The inventories 

were processed through SMOKE to develop hourly, gridded, and speciated emissions required for 

input to the PGM models at 36-, 12-, and 4-km grid resolutions. During emissions processing, 

annual emissions inventories were speciated to model species, temporally allocated to hourly 

emissions, and spatially allocated to grid cells. 

The latest Carbon Bond 6 revision 2h (CB6r2h) photochemical mechanism with active local 

methane emissions and halogen chemistry was used for the CAMx modeling, whereas the Carbon 

Bond 5 (CB05) with updated toluene and chlorine chemistry photochemical mechanism was used for 

the CMAQ modeling, and emissions were processed accordingly. CMAQ versions 5.0 and later 

contain a thermodynamic equilibrium aerosol mechanism (ISORRPIA v2) that requires detailed 

speciation of PM2.5. This involves splitting PMFINE into additional elemental components. 
Air Quality: Cumulative and Visibility Impacts H-13

The SMOKE emissions model was used to perform the following tasks: 

• Spatial Allocation: Spatial surrogates contained in the USEPA 2011v6.2 

modeling platform3 were used to spatially distribute emissions to modeling grid 

cells. Spatial surrogates are generated by overlaying the PGM modeling grid on 

maps of geospatial indicators appropriate to each source category (e.g., housing 

units). The Surrogate Tool4

, a component of USEPA’s Spatial Allocator system, 

is used to calculate the fraction of geospatial indicator coverage in each model 

grid cell. 

• Temporal Allocation: Air quality modeling systems, such as CMAQ and CAMx, 

require hourly emissions input data. With the exception of a few source types 

(i.e., Continuous Emissions Monitoring data, biogenic emissions, and some fire 

inventories), most inventory data are estimated in the form of annual or daily 

emissions. SMOKE was used to allocate annual emissions to months and 

across the diurnal cycle to account for seasonal, day-of-week and hour-of-day 

effects. Temporal profiles and SCC cross references from the 2011v6.2 

modeling platform were used to incorporate seasonal and monthly variations into 

the development of the PGM model-ready emissions. 

• Chemical Speciation: The emissions inventories for the “Air Quality Modeling in 

the Gulf of Mexico OCS Region” study included the following pollutants: CO, 

NOx, VOC, NH3, SO2, PM10, and PM2.5. Ramboll Environ used SMOKE to 

convert inventoried VOC emissions into the CB6r2 photochemical mechanism 

model species. Chemical speciation profiles were assigned to inventory sources 

using cross-referencing data that match the profiles and inventory sources using 

country/state/county (FIPS) and source classification codes (SCCs). Ramboll 

Environ used NOx, VOC, and PM speciation profiles from the 2011v6.2 platform 

for SMOKE processing. In the 2011v6.2 platform, USEPA-generated emissions 

for Carbon Bond version 6 revision 2 (CB6r2) chemical mechanism used by 

CAMx. In addition, this platform generates the PM2.5 model species associated 

with the CMAQ Aerosol Module, version 6 (AE6). SMOKE also applied sourcespecific speciation profiles to convert inventoried NOx emissions to NO, NO2, and 

HONO components. After SMOKE processing, Ramboll Environ applied 

necessary species mapping to prepare CMAQ-ready emissions in CB05/AE6 

terms and CAMx-ready emissions in CB6r2/CF terms. Note that CB6r2 

chemistry also models local excess methane (ECH4) above background 

concentrations. Sea salt and halogen emissions from the Gulf of Mexico and 

 

3 http://www.epa.gov/ttn/chief/emch/index.html#2011

4 https://www.cmascenter.org/sa-tools/documentation/4.2/html/srgtool/SurrogateToolUserGuide_4_2.pdf
H-14 Gulf of Mexico Multisale EIS

other ocean portions of the modeling domain were also generated for CAMx as 

described below. 

H.3.9.2 Biogenic Emissions

Biogenic emissions were generated using the MEGAN version 2.1 biogenics model 

developed at the National Center for Atmospheric Research (Guenther et al., 2012; 

Sakulyanontvittaya et al., 2008). 

Biogenic emissions depend critically upon landuse/landcover input data. Biogenic VOC and 

NO emissions vary considerably on spatial scales ranging from a few meters to thousands of 

kilometers. The MEGAN model accounts for this variability with high-resolution estimates of 

vegetation type and quantity. The MEGAN landcover variables include total Leaf Area Index (LAI), 

tree fraction, and plant species composition. These variables are determined based primarily on 

satellite observations, such as 2003 1 km2 Moderate Resolution Imaging Spectroradiometer 

(MODIS) and 30-m resolution LANDSAT data (Guenther et al., 2006; Sakulyanontvittaya et al., 

2008). MEGAN driving variables include weather data, LAI, plant functional type (PFT) cover, and 

compound-specific emission factors that are based on plant species composition. All of these 

variables are available at various temporal scales and are provided in a geo-referenced gridded 

database in several formats (e.g., netcdf, ESRI GRID). The MEGAN database has global coverage 

at 30 sec (approximately 1 km) spatial resolution.

The MEGAN model was applied using the specific daily meteorology (e.g., temperature and 

solar radiation) extracted from the 2012 WRF model outputs to generate day-specific biogenic 

emissions for the 2012 calendar year in the 36-, 12-, and 4-km PGM modeling domains.

H.3.9.3 Fire Emissions

Forest fire emissions are highly episodic and very location specific. Using annual average 

fire emissions and temporally and spatially allocating these emissions using generic allocation 

schemes would result in significant inaccuracies. In this modeling study, Ramboll Environ used dayspecific wild and prescribed fire (together called wildland fires [WLFs]) emission estimates 

developed by the USEPA for calendar year 2012.

5

 The emission estimates are based on the 

SMARTFIRE2 (SF2) framework and the BlueSky models.6

 The USEPA fire inventory was 

processed through SMOKE in separate processing streams for CMAQ and CAMx. The CMAQ 

model-ready emissions were developed in “in-line” point format. The term “in-line” means that the 

plume rise calculations are done inside the CMAQ model instead of being computed by SMOKE. To 

prepare CAMx model-ready emissions using a plume rise algorithm that is consistent with the 

algorithms in CMAQ, plume rise calculation was done in SMOKE and 3-D emissions files were 

 

5 ftp://ftp.epa.gov/EmisInventory/fires/

6 http://www.airfire.org/smartfire/
Air Quality: Cumulative and Visibility Impacts H-15

prepared that were converted into a CAMx “PTSOURCE” type file where each grid cell centroid 

represents one virtual stack. The CMAQ2UAM program was used to convert 3-D fire emissions from 

SMOKE into CAMx format. Table H-3 shows total annual criteria air pollutant emissions by fire type 

for all US wildland fires within each of BOEM’s PGM modeling domains.

Table H-3. 2012 Fire Criteria Air Pollutant Emissions Summary by Fire Type for BOEM’s 36-, 12-, and 

4-km Domains.

Fire Type 

(SCC) Domain CO (TPY)

NOx

(TPY)

PM10

(TPY)

PM2.5

(TPY)

SO2

(TPY)

VOC 

(TPY)

Wildfires 

(2810001000)

36 km 59,794 613 5,901 5,001 387 14,050

12 km 6,568 74 654 554 44 1,545

4 km 1,087 6 103 87 6 254

Prescribed fires 

(2810015000)

36 km 27,331 391 2,796 2,370 211 6,453

12 km 20,126 308 2,077 1,760 161 4,757

4 km 7,020 58 680 577 41 1,646

Total

36 km 87,125 1,003 8,698 7,371 598 20,503

12 km 26,694 382 2,731 2,314 206 6,302

4 km 8,107 64 783 664 47 1,900

As noted above, the USEPA wildland fires inventory is restricted to fire sources within the 

lower 48 states and thus does not cover the portions of Canada and Mexico lying within the 36-, 12-, 

and 4-km PGM domains. To fill this gap, we used 2012 day-specific Fire INventory from NCAR 

(FINN) for Canada and Mexico. The FINN provides daily, 1-km resolution, global estimates of the 

trace gas and particle emissions from open burning of biomass, which includes wildfire, agricultural 

fires, and prescribed burning exclusive of biofuel combustion and trash burning. Each fire record 

was treated as a point source and emissions were distributed vertically into multiple model layers to 

better represent each fire plume. The day-specific FINN fire emissions in Canada and Mexico were 

processed to develop elevated "point sources" of fire emissions using plume rise estimates as a 

function of fire size based on the Western Regional Air Partnership (WRAP) 2002 fire plume rise 

approach (Mavko and Morris, 2013). The chemical speciation profile for the MODIS fire emissions 

were derived from a study on biomass burning (Karl et al., 2007). 

H.3.9.4 Sea Salt and Halogen Emissions

Ramboll Environ used an emissions processor that integrates published sea spray flux 

algorithms to estimate sea salt PM emissions for input to CAMx. The gridded data for input to the 

sea salt emissions model is a land-water mask file that identifies each modeling domain grid cell as 

open ocean, surf zone, or land. Additional details on the development and evaluation of the sea salt 

emissions processor that was used for the “Air Quality Modeling in the Gulf of Mexico Region” study

are available in the WestJumpAQMS Sea Salt and Lightning memo (Morris et al., 2012). The CAMx 

sea salt emissions processor was used with the 2012 WRF data to generate sea salt emissions for 

the 36-, 12-, and 4-km modeling domains. The sea salt emissions processor has recently been 

updated to also generate emissions for halogen compounds from the ocean (Yarwood et al., 2014). 

Gridded chlorophyll data is obtained from satellite data is used as input and the processor generated 
H-16 Gulf of Mexico Multisale EIS

gridded hourly emissions of chlorine, bromine, and iodine. Halogen chemistry over the ocean 

depletes ozone concentrations near the surface so is especially important in the Gulf of Mexico OCS 

region. 

The CMAQ model includes inline calculation of sea-salt emissions from the open ocean and 

coastal surf zone so no pre-processing of sea salt emissions is needed. The CMAQ does not treat 

halogen chemistry except for chlorine.

H.3.9.5 Lightning NOx Emissions

The NOx is formed in lightning channels as the heat released by the electrical discharge 

causes the conversion of nitrogen (N2) and oxygen (O2) to NO. Modeling of lightning and its 

emissions is an area of active research. For example, the mechanism for the buildup of electric 

potential within clouds is not well understood, and modeling the production, transport, and fate of 

emissions from lighting is complicated by the fact that the cumulus towers where lightning occurs 

may be sub-grid scale depending on the resolution of the model. Given the importance of lightning 

NOx in the tropospheric NOx budget and in understanding its effect on upper tropospheric ozone and 

OH-, lightning NOx is typically incorporated in global modeling (e.g., Tost et al., 2007; Sauvage et al., 

2007; Emmons et al., 2010) and has also been integrated into many regional modeling studies (e.g., 

Allen et al., 2012; Koo et al., 2010).

For the CMAQ modeling, Ramboll Environ used in-line lightning NOx emissions derived from 

the convective precipitation rate provided in the MCIP files. Since the CMAQ model includes inline 

calculation of lightening NOx emissions, no pre-processing of lightening NOx is needed. The CAMx 

model requires pre-calculated lightening emissions for input. To better facilitate comparisons with 

CMAQ, lightening NOx emissions from the CMAQ modeling were output and converted into a format 

suitable for use in CAMx. 

H.3.9.6 Windblown Dust

Windblown dust emissions are calculated in-line in the CMAQ model based on wind speed 

and soil moisture parameters passed to CMAQ from the WRF model. Spatially and temporally 

resolved CMAQ windblown dust emissions were output for use in CAMx. 

H.3.9.7 QA/QC of Processed Emissions

Emissions were processed by major source category in several different processing 

“streams” to simplify the emissions modeling process and facilitate the QA/QC of results. SMOKE 

includes QA and reporting features to keep track of the adjustments at each step of emissions 

processing and to ensure that data integrity is not compromised. Ramboll Environ carefully 

reviewed the SMOKE log files for significant error messages and ensure that appropriate source 

profiles are being used. In addition, SMOKE output summary reports were reviewed and compared 

with input emission totals. 
Air Quality: Cumulative and Visibility Impacts H-17

H.3.9.8 Development of Model-Ready Emissions

Since the “Air Quality Modeling in the Gulf of Mexico Region” study involved application of 

both the CAMx and CMAQ photochemical grid models, the emissions processing procedure 

included development of emissions ready for input to CMAQ, as well as for input to CAMx. Each 

SMOKE processing stream generates a set of pre-merged model-ready emissions in CMAQ input 

format (netCDF). As specified in the chemical speciation section, species mapping was applied to 

convert SMOKE generated model species to the appropriate input for CMAQ. SMOKE modeling 

generated VOC model species for CB6 chemical mechanism, which were converted into CB05 

model species for CMAQ. All pre-merged gridded emissions inputs were merged together to 

generate the final CMAQ-ready, two-dimensional gridded low-level (layer 1) and point source 

emissions inputs. Since CMAQ provides the option to specify point source emissions separately 

from the gridded emissions from other sources, only distributed sources (mobile sources, area 

sources, natural emissions) were merged in developing the CMAQ-ready emissions files. 

The CAMx requires two types of emissions files, as described below, for every episode day; 

both of the emission files are UAM-based Fortran binary files. 

(1) Surface-level 2D emissions: This file contains two-dimensional gridded fields of 

low-level (i.e. surface) emissions rates for all emitted species to be modeled.

(2) Elevated point source emissions: The elevated point source emissions file 

contains stack parameters and emissions rates for all elevated point sources 

and emitted species to be modeled. 

The merged two-dimensional gridded anthropogenic emissions, which were originally output 

in CMAQ format, were converted into CAMx format using the CMAQ2CAMX program7

. Ramboll 

Environ then merged natural source categories – sea salt, biogenic, fires, lightning and windblown 

dust with the surface-level emissions using the MRGUAM processor to develop CAMx model-ready 

emissions. Ramboll Environ first converted model species from CMAQ to CAMx compatible form 

and then converted CMAQ 2-D and in-line point emissions files to CAMx area-/point-source 

emissions files using the CMAQ2CAMx interface program. The point source emissions files in UAMbased binary format were merged together to develop the final CAMx-ready point-source emissions. 

The elevated point source file is independent of the modeling grid because it contains horizontal 

(X, Y) coordinates for each point source, and so one file includes all point sources in the 12- and 

4-km BOEM modeling grids. In addition, CAMx requires separate emissions inputs for source 

groups being tracked in the source apportionment modeling performed for the future year scenario.

 

7 http://www.camx.com/download/support-software.aspx
H-18 Gulf of Mexico Multisale EIS

H.3.9.9 Summary of Processed Emissions

This section presents 2012 base case and future year scenario emissions summaries for the 

BOEM 12- and 4-km domains. The summary is organized by state and by source category.

Table H-4 summarizes NOx, VOC, SO2, and PM2.5 air pollutant emissions in short tons per 

year for the states that border the Gulf of Mexico (i.e., Texas, Louisiana, Alabama, Mississippi, and 

Florida). The summary data are based on 12-km SMOKE processing of 2012 base case and future 

year inventories as described above. With the exception of fugitive dust and biogenic sources, 

emissions are summarized from the SMOKE reports generated by the SMKMRG program. Fugitive 

dust emissions were adjusted after SMOKE processing to account for fugitive dust correction factors 

derived from the Biogenic Emission Landuse Database version 3 (BELD3). Application of these dust 

transport correction factors accounts for suppression of grid-scale dust emissions via deposition on 

proximate vegetation surfaces such as roadside trees and bushes. As noted above, biogenic 

emissions were generated using the MEGAN model outside of SMOKE and so are generated 

directly on the 36/12/4-km grids rather than by state/county. Across the 5-state region, NOx

emissions were projected to go down 4% but VOC emissions are expected to increase by 3%, with 

PM2.5 emissions increasing by 10%. The largest change in emissions between the current and 

future year is for SO2 that is projected to go down by 39%.

Table H-4. 2012 Base Case and Future Year Emissions Summary by State for BOEM’S 12-km 

Domain (only Gulf Coast States: Alabama, Florida, Louisiana, Mississippi, and Texas). 

States 2012 Base Year Future Year Scenario

NOx

(TPY)

PM2.5

(TPY)

SO2

(TPY)

VOC 

(TPY)

NOX

(TPY)

PM2.5

(TPY)

SO2

(TPY)

VOC 

(TPY)

Alabama 210,701 183,321 201,810 1,763,216 178,015 208,531 104,688 1,744,057

Florida 299,738 182,492 144,640 1,754,031 263,778 201,117 127,170 1,690,680

Louisiana 464,962 299,510 203,154 2,030,042 406,421 301,052 127,260 2,007,720

Mississippi 119,430 216,950 57,466 1,622,369 98,334 277,025 32,403 1,610,893

Texas 911,470 683,209 451,018 5,155,944 970,493 739,791 257,073 5,588,049

Figure H-6 throughFigure H-9 present stacked bar chart summaries for the 2012 base case 

emissions that show BOEM 12-km domain anthropogenic, fire, and biogenic emissions by source 

category and pollutants for Alabama, Florida, Louisiana, Mississippi, and Texas. Note that these 

emission summaries are only for the states (and State waters) that border the Gulf of Mexico. 

Similarly, Figure H-10 throughFigure H-13 present stacked bar chart summaries for the future year 

scenario in short tons per year for the Gulf Coast States. Emission categories used in these 

summaries are defined below: 

Source Category Description

ALM Aircraft, locomotive and smaller commercial marine vessels

Fugitive Dust Anthropogenic fugitive dust from paved and unpaved roads, agricultural, 

construction, and mining sources

C3 CMV Commercial marine vessels with Category 3 (C3) main engines
Air Quality: Cumulative and Visibility Impacts H-19

Source Category Description

Nonpoint Stationary non-point sources

Area Oil and Gas Non-point oil and gas sector onshore sources

Point Oil and Gas Point oil and gas sector onshore sources

Onroad

Motorized vehicles that are normally operated on public roadways (passenger 

cars, motorcycles, minivans, sport-utility vehicles, light-duty trucks, heavy-duty 

trucks, and buses

Nonroad Off-road equipment included in USEPA's nonroad model

EGU Point Electric Generating Unit point sources

NonEGU Point NEI point sources that are not in the EGU or Point oil and gas sectors 

Fires Agricultural fires, wildfires and prescribed burning

Biogenic Vegetation and soils throughout domain

BOEM OCS Support

Vessel with Action 

(State waters only)

All BOEM OCS oil and gas support vessels and helicopter under the 2017-2022 

GOM Multisale EIS’s "Proposed Action" scenario

Figure H-6. BOEM’s 12-km 2012 Base Case NOx Emissions Summary in Tons per Year by Source 

Category and State (Alabama, Florida, Louisiana, Mississippi, and Texas).
H-20 Gulf of Mexico Multisale EIS

Figure H-7. BOEM 12-km 2012 Base Case VOC Emissions Summary in Tons per Year by Source 

Category and State (Alabama, Florida, Louisiana, Mississippi, and Texas).
Air Quality: Cumulative and Visibility Impacts H-21

Figure H-8. BOEM 12-km 2012 Base Case PM2.5 Emissions Summary in Tons per Year by Source 

Category and State (Alabama, Florida, Louisiana, Mississippi, and Texas).
H-22 Gulf of Mexico Multisale EIS

Figure H-9. BOEM 12-km 2012 Base Case SO2 Emissions Summary in Tons per Year by Source 

Category and State (Alabama, Florida, Louisiana, Mississippi, and Texas).
Air Quality: Cumulative and Visibility Impacts H-23

Figure H-10. BOEM 12-km Future Year NOx Emissions Summary in Tons per Year by Source Category 

and State (Alabama, Florida, Louisiana, Mississippi, and Texas).
H-24 Gulf of Mexico Multisale EIS

Figure H-11. BOEM 12-km Future Year VOC Emissions Summary in Tons per Year by Source Category 

and State (Alabama, Florida, Louisiana, Mississippi, and Texas).
Air Quality: Cumulative and Visibility Impacts H-25

Figure H-12. BOEM 12-km Future Year PM2.5 Emissions Summary in Tons per Year by Source Category 

and State (Alabama, Florida, Louisiana, Mississippi, and Texas).
H-26 Gulf of Mexico Multisale EIS

Figure H-13. BOEM 12-km Future Year SO2 Emissions Summary in Tons per Year by Source Category 

and State (Alabama, Florida, Louisiana, Mississippi, and Texas).

Table H-5 summarizes NOx, VOC, SO2, and PM2.5 emissions within the 4-km domain in 

short tons for the 2012 base year and the 2017 future year scenario, and Table H-6 summarizes the 

changes in emissions between the base and future year scenarios by major source category. 

Table H-5. 2012 Base Case and Future Year Emissions Summary by Source Category for BOEM’s 4-km 

Domain.

Sectors 2012 Base Year (TPY) Future Year Scenario (TPY)

NOx PM2.5 SO2 VOC NOx PM2.5 SO2 VOC

Fugitive Dust 0 70,526 0 0 0 78,179 0 0

Agricultural 0 0 0 0 0 0 0 0

Fires 50,781 493,750 34,939 1,112,486 50,781 493,750 34,939 1,112,486

ALM 171,436 5,416 2,039 4,896 278,052 7,752 560 7,520

C3 CMV 68,857 3,650 36,339 2,466 108,654 2,666 25,892 4,769

Biogenic 19,015 0 0 3,140,424 19,015 0 0 3,140,424

Nonpoint 81,918 54,561 7,390 296,267 86,014 58,937 3,165 294,728

Nonroad 76,345 6,994 153 112,683 105,272 9,653 159 157,559

Area Oil and 

Gas 69,331 1,991 530 506,972 148,131 5,535 2,134 1,283,385

Onroad 270,364 8,467 1,731 145,061 183,305 7,124 940 106,904
Air Quality: Cumulative and Visibility Impacts H-27

Sectors 2012 Base Year (TPY) Future Year Scenario (TPY)

NOx PM2.5 SO2 VOC NOx PM2.5 SO2 VOC

Non-U.S. 

Fugitive Dust 0 0 0 0 0 0 0 0 

Non-U.S. 

Area 38,832 4,361 719 15,208 35,625 4,429 502 16,787

BOEM 

Gulfwide 186,636 6,337 26,968 7,310 129,814 4,117 31,839 36,109

Non-U.S. 

Onroad 13,894 438 73 6,217 9,097 447 27 4,041

Non-U.S. 

Point (with 

GOM offshore 

platforms)

106,344 2,663 7,795 57,361 32,045 2,181 4,646 11,337

Point Oil and 

Gas 101,530 4,587 50,861 39,192 95,052 4,961 47,086 42,884

EGU Point 137,932 17,943 306,031 3,545 117,518 21,802 136,784 4,371

Non-EGU 

Point 319,924 105,264 271,961 208,773 344,080 120,826 269,191 240,212

BOEM OCS 

Platform No 

Action

0 0 0 0 84,351 837 3,205 54,449

BOEM OCS 

Platform 

w/Action

0 0 0 0 22,973 223 1,037 7,015

BOEM OCS 

Support

Vessel No 

Action

0 0 0 0 234,796 8,296 23,089 8,093

BOEM OCS 

Support

Vessel 

w/Action

0 0 0 0 106,163 9,749 396 10,238

Table H-6. Changes in Emissions between the 2012 Base Case and Future Year Emissions (short tons 

per year) by Source Category for BOEM’s 4-km Domain.

Sector Future Year - Base Year (TPY) Future Year - Base Year (%)

NOx PM2.5 SO2 VOC NOx PM2.5 SO2 VOC

Fugitive Dust 0 7,653 0 0 -- 11% -- --

Agricultural 0 0 0 0 -- -- -- --

Fires 0 0 0 0 0% 0% 0% 0%

ALM 106,616 2,336 (1,479) 2,624 62% 43% -73% 54%

C3 CMV 39,797 (984) (10,447) 2,303 58% -27% -29% 93%

Biogenic 0 0 0 0 0% -- -- 0%

Nonpoint 4,096 4,376 (4,225) (1,539) 5% 8% -57% -1%

Nonroad 28,927 2,659 6 44,876 38% 38% 4% 40%

Area Oil and Gas 78,800 3,544 1,604 776,413 114% 178% 303% 153%

Onroad (87,059) (1,343) (791) (38,157) -32% -16% -46% -26%
H-28 Gulf of Mexico Multisale EIS

Sector Future Year - Base Year (TPY) Future Year - Base Year (%)

NOx PM2.5 SO2 VOC NOx PM2.5 SO2 VOC

Non-U.S. Fugitive 

Dust 0 0 0 0 -- -- -- --

Non-U.S. Area (3,207) 68 (217) 1,579 -8% 2% -30% 10%

BOEM Gulfwide (56,822) (2,220) 4,871 28,799 -30% -35% 18% 394%

Non-U.S. Onroad (4,797) 9 (46) (2,176) -35% 2% -63% -35%

Non-U.S. Point 

(with GOM 

offshore platforms)

(74,299) (482) (3,149) (46,024) -70% -18% -40% -80%

Point Oil and Gas (6,478) 374 (3,775) 3,692 -6% 8% -7% 9%

EGU Point (20,414) 3,859 (169,247) 826 -15% 22% -55% 23%

Non-EGU Point 24,156 15,562 (2,770) 31,439 8% 15% -1% 15%

Figure H-14 presents spatial plots of future year scenario NOx, VOC, PM2.5, and SO2

emissions in short tons per year within the 4-km domain for BOEM’s BOEM OCS oil and gas 

production platforms under the 2017-2022 GOM Multisale EIS. Note that the deepwater platforms 

have higher annual emissions than the shallow-water platforms. Figure H-15 presents 4-km spatial 

plots for the same pollutants and future year scenario in short tons per year for BOEM’s OCS oil and 

gas support vessels and helicopters under the 2017-2022 GOM Multisale EIS. Figure H-16 shows 

emissions for BOEM’s OCS oil and gas platforms, support vessels, and helicopters under the No 

Action alternative, which are the existing sources. Figure H-17 shows emissions for all other marine 

vessel activity in the Gulf of Mexico. Figure H-18 shows emissions for all other anthropogenic US 

sources. 
Air Quality: Cumulative and Visibility Impacts H-29

Figure H-14. Spatial Distribution of (clockwise starting from top left) NOx, VOC, SO2, and PM2.5

Emissions (tons per year) from New OCS Oil and Gas Production Platforms under the 

Proposed Action.
H-30 Gulf of Mexico Multisale EIS

Figure H-15. Spatial Distribution of Emissions (tons per year) of (clockwise starting from top left) NOx, 

VOC, SO2, and PM2.5 from BOEM’s OCS Additional Oil and Gas Support Vessels and 

Helicopters under the Proposed Action Scenario.
Air Quality: Cumulative and Visibility Impacts H-31

Figure H-16. Spatial Distribution of (clockwise starting from top left) NOx, VOC, SO2, and PM2.5

Emissions (tons per year) from BOEM’s OCS Oil and Gas Platforms, Support Vessels, and 

Helicopters under the No Action Alternative in BOEM’s 4-km Domain.
H-32 Gulf of Mexico Multisale EIS

Figure H-17. Spatial Distribution of (clockwise starting from top left) NOx, VOC, SO2, and PM2.5

Emissions (tons per year) from All Other Marine Vessel Activity in the Gulf of Mexico under 

the Future Year Scenario in BOEM’s 4-km Domain.
Air Quality: Cumulative and Visibility Impacts H-33

Figure H-18. Spatial Distribution of (clockwise starting from top left) NOx, VOC, SO2, and PM2.5

Emissions (tons per year) from Other Anthropogenic U.S. Sources for the Future Year 

Scenario within BOEM’s 4-km Domain.

H.3.10 Source Apportionment Design

Source apportionment, as applied in CAMx, provides a means of assessing the contributions 

of specified sources or categories of sources to predicted ozone and PM concentrations under the 

air quality conditions being simulated. Source contributions can be calculated for ozone and for PM 

using ozone or PM source apportionment routines included in CAMx. Source apportionment 

analyses were applied to the future year scenario in order to analyze the pre- and postlease OCS oil 

and gas impacts to short-term and annual NAAQS, AQRVs, and PSD increments. BOEM selected a 

set of nine source categories for source apportionment as listed in Table H-7.
H-34 Gulf of Mexico Multisale EIS

Table H-7. Source Categories for Source Apportionment Calculations.

Category ID Sources

SC1 Fires (U.S., Canada, and Mexico)

SC2 Biogenic and other natural sources (e.g., lighting NOx and sea salt)

SC3 Additional BOEM OCS oil and gas production platforms associated with the 

2017-2022 GOM Multisale EIS scenario (w/Action)

SC4 Additional BOEM oil and gas production support vessels and helicopters 

associated with the 2017-2022 GOM Multisale EIS scenario (w/Action)

SC5 BOEM’s OCS oil and gas production platforms, support vessels, and 

helicopters under the base case (No Action) alternative

SC6 All other marine vessel activity in the Gulf of Mexico, not associated with OCS 

oil and gas activities

SC7 Other anthropogenic U.S. sources8

SC8 Mexican and Canadian anthropogenic sources9

SC9 Initial Conditions (IC)

SC10 Boundary Conditions (BC)

These source categories aggregate similar sources based on jurisdiction (i.e., sources under 

BOEM’s jurisdiction versus other Federal agencies) and sources beyond direct domestic regulatory 

control (e.g., natural emission sources and foreign sources). Additional OCS oil and gas production 

platforms and additional support vessel and helicopter trips associated with the 2017-2022 GOM 

Multisale EIS are included as a separate source category, thus providing estimates of the impacts of 

these new sources, which are projected to occur under the future year scenario associated with the 

2017-2022 GOM Multisale EIS. Platforms and support vessels and helicopters projected for the 

future year scenario under the base case (No Action) scenario are also included as a separate 

source apportionment category. 

Isolating fires and biogenic emissions shows the component of the air quality concentrations 

that are typically beyond the control of Federal agencies and states. Similarly, the Mexican and 

Canadian anthropogenic emissions are beyond the control of U.S. regulators. 

H.4 BASE CASE PHOTOCHEMICAL GRID MODELING

H.4.1 Overview

The CAMx Photochemical Grid Model (PGM) was applied on a set of nested domains with 

horizontal resolutions of 36, 12 and 4 km centered on the Gulf of Mexico OCS Region (Figure H-5). 

For the 2012 base case analysis, CAMx was run with the 2012 base case emissions described in 

Section H.3. Meteorological fields required by CAMx were obtained from the WRF meteorological 

model results for 2012, which were developed as described in Section H.2. Modeling procedures 

 

8 Includes onshore oil and gas production sources and oil and gas production sources in State waters.

9 Also includes oil and gas production sources.
Air Quality: Cumulative and Visibility Impacts H-35

were based on the USEPA’s current and revised draft modeling guidance procedures (USEPA, 2007

and 2014). Additional features of the modeling approach are listed below.

• Anthropogenic and non-anthropogenic model-ready emissions for the 2012 base 

case were developed as described in the emission inventory TSD.

• Photochemical grid modeling was based on CAMx version 6.20 with the Carbon 

Bond 6 revision 2h (CB6r2h) photochemical mechanism, including active excess 

methane emissions and halogen chemistry. 

• Day-specific boundary conditions (BCs) for the lateral boundaries of the 36-km 

modeling domain were based on 2012 GEOS-Chem global chemistry model 

(GCM) output. 

• A model performance evaluation was conducted for the initial 2012 base case 

simulation using all available aerometric data within the modeling domain. Based 

on these initial results, a number of potential issues with model inputs were 

identified and appropriate modifications tested to confirm that the extent to which 

the modifications resolved the identified issues and resulted in improved model 

performance. These initial results and test results are described in Section H.5. 

Revised inputs were then used in the final model simulations and revised model 

performance metrics based on the final model runs were prepared. Results of 

the final model performance evaluation are also presented in Section H.5. 

H.4.2 Model Grid Configuration

The PGM domain configuration is comprised of a system of nested grids with 36-, 12-, and 

4-km horizontal resolution as shown in Figure H-5. Table H-8 provides the modeling grid definitions 

for the WRF and CAMx simulations. Since a large portion of the eastern GOM is under 

Congressional moratoria (GOMESA), the 4-km PGM domain excluded this area to limit the grid 

dimension to allow for a more manageable size for computation efficiency.

Table H-8. Domain Grid Definitions for the WRF and CAMx/CMAQ Modeling. 

Modeling

Grid

WRF CAMx

Origin1 Coordinates 

(x, y) (km)

Grid Dimension 

(column × row)

Origin1 Coordinates 

(x, y) (km)

Grid Dimension 

(column × row)

36-km grid (-2592, -2304) (164 × 128) (-2736, -2088) (148 × 112)

12-km grid (-1008, -2016) (264 × 186) (-948, -1956) (254 × 176)

4-km grid (-156, -1704) (480 × 210) (-136, -1684) (299 × 200)

1 Southwest corner of each domain grid.

For CAMx, BCs for the 12-km domain were extracted from the 36-km simulation results, and 

the 12-and 4-km grids were modeled using 2-way nesting (allowing interactions between the two 

grids in both directions). Specification of the CAMx vertical domain structure depends on the 

definition of the WRF vertical layers structure. The WRF simulation was run with 33 vertical layer 
H-36 Gulf of Mexico Multisale EIS

interfaces (which is equivalent to 32 vertical layers) from the surface up to 50 mbar (approximately 

20 km above mean sea level [AMSL]). The WRF model employs a terrain following coordinate 

system called eta (η) coordinate, which is defined by relative pressure differences between layers. 

As shown in Table H-9, the WRF levels are more finely stratified near the surface in an attempt to 

improve simulation of the atmospheric boundary layer structure and processes. A layer collapsing 

scheme is adopted for the CAMx simulations whereby multiple WRF layers are combined into single 

CAMx layers to improve the PGM computational efficiency. Table H-9 also shows the layer 

collapsing from the 32 WRF layers to 28 PGM layers. The mixing heights over the study domain are 

typically below 2 km. Therefore, the WRF modeling layers up to the 16th layer (approximately 2 km) 

are directly mapped to the PGM layers (no layer-collapsing) to better simulate the stable thermal 

stratification of the boundary layer and avoid errors potentially introduced by layer collapsing. Above 

the 20th WRF layer, two WRF layers were combined into a single PGM layer up to the 50 hPa region 

top.

Table H-9. Vertical Layer Interface Definition for WRF Simulations (left-most columns) and the 

Layer-collapsing Scheme for the CAMx/CMAQ Layers (right columns). 

WRF CAMx/CMAQ

Layer 

Interface Eta (η) Pressure (mbar)

Height 

(m)

Thickness 

(m) Layer Layer Top Height (m)

Thickness 

(m)

33 0.0 50 19,594.2 2,090.8 24 19,594.2 3,972.6

32 0.027 76 17,503.4 1,881.8

31 0.06 107 15,621.6 1,754.7 23 15,621.6 3,484.9

30 0.1 145 13,866.9 1,730.1

29 0.15 193 12,136.7 1,412.6 22 12,136.7 2,614.2

28 0.2 240 10,724.1 1,201.6

27 0.25 288 9,522.5 1,050.2 21 9,522.5 1,986.1

26 0.3 335 8,472.3 935.8

25 0.35 383 7,536.4 846 20 7,536.4 1,693.2

24 0.4 430 6,690.5 847.3

23 0.455 482 5,843.2 910.3 19 5,843.2 1,679.1

22 0.52 544 4,932.9 768.8

21 0.58 601 4,164.1 711.8 18 4,164.1 1,375.4

20 0.64 658 3,452.2 663.5

19 0.7 715 2,788.7 418.9 17 2,788.7 821.1

18 0.74 753 2,369.8 402.1

17 0.78 791 1,967.6 386.8 16 1,967.6 386.8

16 0.82 829 1,580.8 280.8 15 1,580.8 280.7

15 0.85 858 1,300.1 273.3 14 1,300.1 273.4

14 0.88 886 1,026.7 178.3 13 1,026.7 178.2

13 0.9 905 848.5 131.7 12 848.5 131.8

12 0.915 919 716.7 130.1 11 716.7 130.1

11 0.93 934 586.6 85.8 10 586.6 85.8

10 0.94 943 500.8 85.1 9 500.8 85.1

9 0.95 953 415.7 84.5 8 415.7 84.5

8 0.96 962 331.2 83.8 7 331.2 83.8
Air Quality: Cumulative and Visibility Impacts H-37

WRF CAMx/CMAQ

Layer 

Interface Eta (η) Pressure (mbar)

Height 

(m)

Thickness 

(m) Layer Layer Top Height (m)

Thickness 

(m)

7 0.97 972 247.4 83.1 6 247.4 83.1

6 0.98 981 164.3 57.8 5 164.3 57.8

5 0.987 988 106.5 41.1 4 106.5 41.1

4 0.992 992 65.4 24.6 3 65.4 24.6

3 0.995 995 40.8 20.4 2 40.8 20.4

2 0.9975 998 20.4 20.4 1 20.4 20.4

1 1.0 1,000 0 -- -- -- --

H.4.3 Meteorology

Given the objectives of the air quality analysis and the availability of full annual WRF 

simulations for 2009 through 2013, the CAMx model was exercised for a full calendar year. The 

decision to model for an entire calendar year rather than just a single season is consistent with the 

need to address ozone, PM2.5, visibility and annual deposition. Given the extremely hot, dry, and 

smoky conditions during 2011, the 2012 calendar year was selected for the base year, base case 

modeling. 

Meteorological inputs for CAMx were generated by processing the WRF outputs using 

appropriate meteorological input preprocessors. The WRFCAMx Version 4.3 was used to translate 

WRF output meteorological fields to daily CAMx meteorological inputs. For a single day, 25 hours of 

meteorology must be present (midnight through midnight, inclusive) as these fields represent hourly 

instantaneous conditions and CAMx internally time-interpolates these fields to each model time step. 

Precipitation fields are not time-interpolated but rather time-accumulated, so cloud/precipitation files 

contain one less hour than other meteorological files (e.g., 24 hours of clouds/precipitation vs. 

25 hours for other meteorology fields). 

Several methodologies are available in WRFCAMx to derive vertical diffusivity (Kv) fields 

from WRF output. For this modeling, a method consistent with the Yonsei University (YSU) bulk 

boundary layer scheme (Hong and Noh, 2006; this is the default option in WRF) was used to 

generate the Kv profile. The lower bound Kv value is set based on the land-use type for each grid 

cell. Another issue is deep cumulus convection, which is difficult to simulate in a grid model because 

of the small horizontal spatial scale of the cumulus tower. Inadequate characterization of this 

convective mixing can cause ozone and precursor species to be overestimated in the boundary

layer. To address this issue, a patch was developed that increases transport of air from the 

planetary boundary layer into the free troposphere and up to the cloud top within cloudy grid cells 

(ENVIRON, 2012). This patch was shown to improve surface layer ozone in a recent modeling 

study in Texas (Kemball-Cook et al., 2015), and thus was also employed in this modeling study. 

WRFCAMx provides an option to process sub-grid cloud data from WRF fields. Selecting 

the “DIAG” sub-grid cloud method diagnoses sub-grid cloud fields from WRF gridded thermodynamic 

fields. The DIAG option is generally selected for the 36- and 12-km WRF output extraction but not 
H-38 Gulf of Mexico Multisale EIS

for grid spacing less than about 10 km. However, a recent modeling study showed that, without the

sub-grid cloud, the 4-km grid produced too much ozone over the Houston area due to enhanced 

photochemistry (Nopmongcol et al., 2014). Therefore, the DIAG option was used for the 4-km grid 

as well as the 36- and 12-km grids. 

H.4.4 Configuration of Model Input Parameters

Configuration of the CAMx model is summarized in Table H-10. Additional key configuration 

selections include the following: 

Chemical Mechanism: Gas phase chemistry using the Carbon Bond 6 revision 2h (CB6r2h) 

photochemical mechanism including active local excess methane emissions and halogen chemistry. 

For particles, CAMx was configured to use the Coarse-Fine (CF) aerosol scheme in which primary 

species are modeled using two static modes (coarse and fine), while all secondary species are 

modeled as fine particles only. 

Photolysis Rates: The CAMx requires a lookup table of photolysis rates as well as gridded 

albedo/haze/ozone/snow as input. Day-specific ozone column data are based on the Total Ozone 

Mapping Spectrometer (TOMS) data measured using the satellite-based Ozone Monitoring 

Instrument (OMI). Albedo is based on land use data, which includes enhanced albedo values when 

snow cover is present. For CAMx, there is an ancillary snow cover input that is based on WRF 

output that overrides the land use-based albedo input to use an enhanced snow cover albedo value. 

The Tropospheric Ultraviolet and Visible (TUV) Radiation Model photolysis rate processor was used. 

The CAMx is configured to use the in-line TUV to adjust for cloud cover and account for the effects 

aerosol loadings have on photolysis rates; this latter effect on photolysis may be especially important 

in adjusting the photolysis rates due to the occurrence of PM concentrations associated with 

emissions from fires. Note that the same photolysis rates are used in the 2012 base case and future 

year scenario model runs. 

Landuse: Landuse fields were generated based on U.S. Geological Survey (USGS) 

Geographic Information Retrieval and Analysis System (GIRAS) data10. The WRF 

estimated snow cover data is used to override the USGS land cover categories when 

snow cover is present.

Meteorological Inputs: The WRF-derived meteorological fields were processed to 

generate CAMx meteorological inputs for the using the WRFCAMx processor. 

Plume in Grid: The subgrid-scale Plum-in-Grid module was not used to avoid 

unacceptably long model run times and given the fact that most sources in the OCS 

are far upwind of the receptor sites of interest. 

 

10 http://pubs.usgs.gov/ds/2006/240/
Air Quality: Cumulative and Visibility Impacts H-39

Boundary Conditions: Boundary conditions (BCs) for the 36-km domain were 

derived from a GEOS-Chem global chemistry model run for 2012 as described bove. 

The BCs for the 12/4-km model runs were based on BCs extracted from the 36-km 

simulations. 

Advection/Diffusion Methods: The piecewise parabolic method (PPM) advection 

solver was used for horizontal transport (Colella and Woodward, 1984), along with 

the spatially varying (Smagorinsky) horizontal diffusion approach. The CAMx used 

K-theory for vertical diffusion, using the CMAQ-like vertical diffusivities from 

WRFCAMx. 

Initial Conditions: The 36-km simulation used default initial conditions (ICs) that 

represent clean remote conditions. A 10-day spin-up period was then used to 

eliminate any significant influence of the ICs. The ICs and BCs for the nested 

(12/4-km) grid simulations were extracted from the parent grid simulation outputs 

with a shorter (3 day) spin-up period.

Boundary Conditions: The lateral boundary conditions (BCs) for the 36-km grid were 

based on results from a GEOS-Chem GCM simulation for year 2012. The 

GEOS2CAMx processor was used to interpolate from the GEOS-Chem horizontal 

and vertical coordinate system to the CAMx coordinate system and to map the 

GEOS-Chem chemical species to the chemical mechanisms being used by CAMx. 

The use of an alternative global model (MOZART-4/GEOS5; available at 

http://www.acd.ucar.edu/wrf-chem/mozart.shtml) as a source for the BCs was 

explored via a test simulation on the 36-km domain with BCs derived from MOZART 

and subsequent comparison of model predictions with observations at rural 

monitoring sites. Results of this comparison indicated slightly worse model 

performance for ozone when using the MOZART BCs as compared to GEOS-Chem 

with mixed results for PM depending on species and monitoring network used for 

evaluation. Based on these results and the fact that, in contrast to GEOS-Chem, 

MOZART does not use day-specific values for dust emissions, resulted in the 

selection of BCs based on the GEOS-Chem model. 

Table H-10. CAMx Model Configuration.

Science Options Configuration Notes

Model Codes CAMx V6.20

Horizontal Grid 36/12/4 km Refer to Section H.2

36-km grid 148 x 112 cells

12-km grid 254 x 176 cells

4-km grid 299 x 200 cells

Vertical Grid

19 vertical layers (layercollapsed from 23 WRF 

layers)
H-40 Gulf of Mexico Multisale EIS

Science Options Configuration Notes

Grid Interaction 36/12 km one-way nesting 

12/4 km two-way nesting

Initial Conditions Clean initial conditions Use 10-day spin-up for the 36-km grid; 3-day 

spin-up for the nested (12/4 km) grids

Boundary 

Conditions 36 km from GCM simulation GEOS-Chem GCM 2012 output data

Land-use Data Land-use fields based on 

USGS GIRAS data

Photolysis Rate 

Preprocessor TUV V4.8 Clear-sky photolysis rates based on day-specific Total Ozone Mapping Spectrometer (TOMS) data

Chemistry

Gas-phase CB6r2h

Updated isoprene chemistry; heterogeneous 

hydrolysis of organic nitrates; active methane 

chemistry and ECH4 tracer species (Hildebrandt 

Ruiz and Yarwood, 2013); halogen chemistry 

(Yarwood et al., 2014)

Aerosol-phase CF Coarse and fine mode aerosols

Meteorological 

Input 

Preprocessor

WRFCAMx V4.3 Compatible with CAMx V6.20

Diffusion Scheme

Horizontal-grid Explicit horizontal diffusion Spatially varying horizontal diffusivities determined 

based on the methods of Smagorinsky (1963)

Vertical-grid K-theory 1st-order closure

WRFCAMx-derived vertical diffusivities based on 

the Yonsei University (YSU) planetary boundary 

layer (PBL) scheme (Hong and Noh, 2006); landuse dependent minimum diffusivity (minimum Kv = 

0.1 to 1.0 m2

/s) with a cloud Kv patch recently 

developed to address deep convective mixing 

(ENVIRON, 2012)

Deposition Scheme

Dry deposition ZHANG03 Dry deposition scheme by Zhang et al. (2001; 2003)

Wet deposition CAMx-specific formulation Scavenging model for gases and aerosols (Seinfeld 

and Pandis, 1998)

Numerical Solvers

Gas-phase 

chemistry

Euler Backward Iterative 

(EBI) solver Hertel et al., 1993

Horizontal 

advection

Piecewise Parabolic 

Method (PPM) Colella and Woodward, 1984

Vertical 

advection

Implicit scheme w/ vertical 

velocity update 

H.5 MODEL PERFORMANCE EVALUATION

Results from the CAMx base case model runs were compared with available air quality 

observations within the 12/4-km domain to evaluate the ability of the model to accurately reproduce 

observed conditions. Evaluation of CAMx model performance focused on ozone and PM species as 

these predictions play the primary role in the air quality impact analysis. Evaluation of the CAMx 

2012 base case simulation followed USEPA’s current (USEPA, 2007) and new draft (USEPA, 2014) 
Air Quality: Cumulative and Visibility Impacts H-41

PGM modeling guidance. The model performance evaluation (MPE) used the Atmospheric Model 

Evaluation Tool (AMET11), which is the evaluation tool discussed in USEPA’s latest PGM guidance 

(USEPA, 2014). Note that AMET requires that a monitoring site have at least 75% valid data 

capture in order to be used in the MPE, which eliminated observed data from some sites for use in 

the MPE.

H.5.1 Implications of WRF Model Performance on PGM Simulations

The WRF model performance evaluation results are presented in Appendix F. The effects 

of the meteorological model performance on PGM modeled concentrations, visibility and deposition 

is difficult to predict given the multiple effects the meteorological model can have. As described in 

Appendix F, overall WRF model performance was found to be good and significant impediments to 

PGM model performance due to errors in meteorology are not anticipated. 

H.5.2 Ambient Data Used In the Model Performance Evaluation

Ozone model performance was evaluated using observed hourly and daily maximum 8-hour 

(DMAX8) ozone concentrations from the USEPA’s Air Qu ality System (AQS12) and the Clean Air 

Status and Trends Network (CASTNet13). Figure H-19 displays the locations of the AQS and 

CASTNet ozone monitoring sites used in the ozone model performance evaluation. Historically, 

CASTNet ozone monitoring sites operated by the U.S. Dept. of the Interior’s National Park Service 

(NPS) were included as part of AQS (i.e., ozone compliance monitors), while those operated by the 

USEPA were not. This has recently been changed and now all CASTNet ozone data are also 

reported in AQS. Thus, CASTNet ozone monitoring sites operated by the NPS are included in both 

the AQS and CASTNet monitoring databases. Apart from this overlap, most AQS monitoring sites 

tend to be more urban-oriented, while CASTNet sites tend to be more rural. Ramboll Environ 

therefore provides separate performance results for the AQS and CASTNet monitoring sites in order 

to provide insight into ozone performance at urban vs. rural sites. 

 

11 https://www.cmascenter.org/help/documentation.cfm?MODEL=amet&VERSION=1.1

12 http://www.epa.gov/ttn/airs/airsaqs/aqsweb/

13 http://java.epa.gov/castnet/
H-42 Gulf of Mexico Multisale EIS

CASTNET

AQS

Figure H-19. Ozone Monitoring Sites Used in the Model Performance 

Evaluation: CASTNet Sites in the Southeastern U.S. (top) and 

AQS Sites within the 4-km Modeling Domain (bottom) (color 

coding of AQS monitor locations is arbitrary). 

45-

A

I

S
Air Quality: Cumulative and Visibility Impacts H-43

The PM2.5 model performance was evaluated using observed speciated PM data from CSN, 

IMPROVE, and SEARCH monitoring sites in the southeastern U.S. as shown in Figure H-20. This 

was augmented by 24-hour integrated total PM2.5 mass measurements using Federal Reference 

Method (FRM) or equivalent method monitoring sites reporting to the AQS. Most of these FRM sites 

collect samples on a 1-in-3 day schedule, although some collect data every day. The CSN data 

consist of 24-hour integrated particulate samples analyzed for SO4, NO3, NH4, EC, OC, and 

elements using a 1:3 or 1:6 day sampling frequency. The Interagency Monitoring of Protected 

Visual Environments (IMPROVE14) network collects 24-hour average PM2.5 and PM10 mass and 

speciated PM2.5 concentrations (with the exception of ammonium) using a 1:3 day sampling 

frequency. The SEARCH network data consist of hourly and 24-hour PM2.5 mass and speciated 

PM2.5 data (including ammonia). The FRM and CSN monitoring sites tend to be more urban, 

whereas the IMPROVE sites are mostly located at national parks and wilderness areas and so are 

more rural. 

There are additional monitoring sites within the modeling domain that collect hourly PM2.5

and PM10 total mass. However, automated hourly PM measurements are in some cases subject to 

additional measurement artifacts and uncertainties relative to data collected on filters and do not 

include speciated PM measurements. Although MPE results were generated using hourly PM data, 

they are not shown here to maintain consistency with the 24-hour PM NAAQS and the speciated PM 

results, as well as for the sake of brevity. Some hourly PM data, including speciated PM data, are 

available at SEARCH network sites. Comparison of MPE results for model bias and error did not 

show large overall differences between the hourly and daily SEARCH network comparisons. 

 

14 http://vista.cira.colostate.edu/IMPROVE/
H-44 Gulf of Mexico Multisale EIS

CSN

IMPROVE

SEARCH (source: EPRI, 2011) 

Figure H-20. Speciated PM Monitoring Sites Used in the Model Performance Evaluation: CSN Network 

(top), IMPROVE Network (bottom left), and SEARCH Network (bottom right).

482030002

220330009

220150008 481130069

482011039

120111002

280670002 13215001

130210007

130690002

120730012

121030026

120573002

CHAS

EVER1

OKEF1

SAMA1

ROMA1
Air Quality: Cumulative and Visibility Impacts H-45

H.5.3 Model Performance Statistics

Statistical performance measures applicable to air quality model evaluation are defined in 

Table H-11. 

Table H-11. Definitions of Model Performance Evaluation Statistical Metrics. 

Statistical Measure Mathematical 

Expression Notes

Ap: Accuracy of paired 

peak

Comparison of the peak observed value (Opeak) 

with the predicted value at same time and location

NME: Normalized Mean 

Error Reported as %

RMSE: Root Mean 

Square Error Reported as %

FE: Fractional Gross 

Error Reported as % and bounded by 0% to 200%

MAGE: Mean Absolute 

Gross Error Reported as concentration (e.g., μg/m3

) 

MNGE: Mean 

Normalized Gross Error Reported as %

MB: Mean Bias Reported as concentration (e.g., μg/m3) 

MNB: Mean Normalized 

Bias Reported as %

FB: Mean 

Fractionalized Bias Reported as %, bounded by -200% to +200%

NMB: Normalized Mean 

Bias Reported as %

For over two decades, ozone model performance for bias and error has been compared 

against the USEPA’s 1991 ozone modeling guidance model performance goals as follows (USEPA, 

1991):

• Mean Normalized Bias (MNB) ≤ ±15%

• Mean Normalized Gross Error (MNGE) ≤ 35%

peak

peak

O

− OP

∑

∑

=

=

−

N

i

i

N

i

ii

O

OP

1

1

( ) 2

1

1

1 2





 



 ∑ − =

N

i

OP ii N

∑= +

− N

i ii

ii

OP

OP

N 1

2

∑=

−

N

i

OP ii N 1

1

∑=

− N

i i

ii

O

OP

N 1

1

∑( ) =

−

N

i

OP ii N 1

1

( ) ∑=

− N

i i

ii

O

OP

N 1

1

∑= 















+

− N

i ii

ii

OP

OP

N 1

2

∑

∑

=

=

−

N

i

i

N

i

ii

O

OP

1

1

)(
H-46 Gulf of Mexico Multisale EIS

In the USEPA’s 1991 ozone modeling guidance, these performance metrics were for hourly 

ozone concentrations that were consistent with the form of the ozone NAAQS in those days. The 

MNB performance statistic uses hourly predicted and observed ozone concentrations paired by time 

and location and is defined as the difference between the predicted and the observed hourly ozone 

divided by the observed hourly ozone concentrations averaged over all predicted/observed pairs 

within a given region and for a given time period (e.g., by day, month or modeling period). The 

MNGE is defined similarly only it uses the absolute value of the difference between the predicted 

and observed hourly ozone concentrations, so it is an unsigned metric. Note that, because the MNB 

and MNGE performance metrics divide by the observed ozone concentrations, they weigh 

performance for low ozone concentrations highly and can become unstable as the observed ozone 

approaches zero. Consequently, they are no longer recommended. Instead, the Fractional Bias 

and Error (FB/FE) and Normalized Mean Bias and Error (NMB/NME) are the preferred bias and error 

statistical performance measures.

For PM species, a separate set of model performance statistics and performance goals and 

criteria have been developed as part of the regional haze modeling performed by several Regional 

Planning Organizations (RPOs). The USEPA’s modeling guidance notes that PM models might not 

be able to achieve the same level of model performance as ozone models. Indeed, PM2.5 species 

definitions are defined by the measurement technology used to measure them, and different 

measurement technologies can produce very different PM2.5 concentrations. Given this, several 

researchers have developed PM model performance goals and criteria that are less stringent than 

the ozone goals that are shown in Table H-12 (Boylan, 2004; Boylan and Russell, 2006; Morris 

et al., 2009a and 2009b). However, unlike the 1991 ozone model performance goals that use the 

MNB and MNGE performance metrics, the Fractional Bias (FB) and Fractional Error (FE) are 

typically used for PM species with no observed concentration threshold screening. The FB/FE 

differs from the MNB/MNGE in that the difference in the predicted and observed concentrations are 

divided by the average of the predicted and observed values, rather than just the observed value as 

in the MNB/MNGE. This results in the FB being bounded by -200% to +200%, and the FE being 

bounded by 0% to +200%. There are additional statistical performance metrics that evaluate 

correlation, scatter, and normalized mean bias and error (NMB/NME), as shown in Table H-12. 

Table H-12. Ozone and PM Model Performance Goals and Criteria. 

Bias 

(FB/NMB)

Error 

(FE/NME) Comment

≤±15% ≤35% Ozone model performance goal that would be considered very good 

model performance for PM species

≤±30% ≤50% PM model performance Goal, considered good PM performance

≤±60% ≤75% PM model performance Criteria, considered average PM performance. 

More recently, the USEPA compiled and interpreted the model performance from 69 PGM 

modeling studies in the peer-reviewed literature between 2006 and March 2012 and developed 

recommendations on what should be reported in a model performance evaluation (Simon et al., 
Air Quality: Cumulative and Visibility Impacts H-47

2012). Although these recommendations are not official USEPA guidance, their recommendations 

were integrated in this CAMx MPE.

• The PGM MPE studies should, at a minimum, report the Mean Bias (MB) and 

Error (ME or RMSE), and Normalized Mean Bias (NMB) and Error (NME) and/or 

Fractional Bias (FB) and Error (FE). Both the MNB and FB are symmetric 

around zero with the FB bounded by -200% to +200%.

• Use of the Mean Normalized Bias (MNB) and Gross Error (MNGE) is not 

encouraged because they are skewed toward low observed concentrations and 

can be misinterpreted due to the lack of symmetry around zero.

• The model evaluation statistics should be calculated for the highest resolution 

temporal resolution available (e.g., hourly ozone) and for important regulatory 

averaging times (e.g., daily maximum 8-hour ozone). 

• It is important to report processing steps in the model evaluation and how the 

predicted and observed data were paired and whether data are 

spatially/temporally averaged before the statistics are calculated.

• Predicted values should be taken from the grid cell that contains the monitoring 

site, although bilinear interpolation to the monitoring site point can be used for 

higher resolution modeling (<12 km).

• The PM2.5 should also be evaluated separately for each major component 

species (e.g., SO4, NO3, NH4, EC, OA, and remainder other PM2.5 [OPM2.5]).

• Evaluation should be performed for subsets of the data, including high observed 

concentrations (e.g., ozone >60 ppb) by subregion and by season or month.

• Spatial displays should be used in the model evaluation to evaluate model 

predictions away from the monitoring sites. Time series of predicted and 

observed concentrations at a monitoring site should also be used.

• It is necessary to understand measurement artifacts in order to make meaningful 

interpretation of the model performance evaluation.

H.5.4 Approach

The PGM evaluation focused on ozone, both hourly and daily maximum 8-hour (DMAX8) 

ozone concentrations; total PM2.5 mass and speciated PM2.5 concentrations; gaseous NO2, SO2, and 

CO concentrations; and visibility. The evaluation was performed across all monitoring sites within 

either the southeastern U.S. as shown in the top panel of Figure H-20 (in order to capture the 

regional CSN and IMPROVE network sites) or the 4-km modeling domain (Figure H-5), as well as at 

each individual site on an annual, seasonal (quarterly), and monthly basis. In addition to generating 

numerous statistical performance metrics (refer to Table H-11), graphical representation of model 

performance used three main types of displays. 
H-48 Gulf of Mexico Multisale EIS

• Soccer Plots of monthly bias and error that are compared against the ozone 

performance goals and the PM performance goals and criteria (refer to Table

H-11). Monthly soccer plots allow the easy identification of when performance 

goals/criteria are achieved and an evaluation of performance across seasons.

• Spatial statistical performance maps that display bias/error on a map at the 

locations of the monitoring sites in order to better understand spatial attributes of 

model performance, along with tabular summaries of statistical performance 

metrics. 

• Time series plots that compare predicted and observed concentrations at a 

monitoring site as a function of days.

• Scatter plots of predicted and observed concentrations.

All performance statistics and displays are performed matching the predicted and observed 

concentrations by time and location using the modeled prediction in the 12/4-km grid cell containing 

the monitoring site. 

The CAMx model performance for PM was evaluated using total PM2.5 mass and speciated 

PM2.5 measurements compared against the PM performance goals and criteria given in Table H-12. 

Note that the PM goals and criteria are not as stringent as those for ozone because the 

measurements themselves, as well as the PM emissions, are much more uncertain and there are 

more processes involved in PM (e.g., dispersion, transformation and deposition of primary PM and 

formation of secondary PM from gaseous precursors). Each PM measurement technique has its 

own artifacts; different measurement technology could produce different observed PM2.5 values that 

differ by as much as 30 percent. The USEPA’s latest PGM modeling guidance includes a section on 

PM measurement artifacts for the monitoring technologies used in routine networks in the U.S. 

(USEPA, 2014). Thus, the PM model performance needs to recognize these measurement 

uncertainties and artifacts and take them into account in the interpretation of model performance, as 

even a “perfect” model may not achieve the PM performance goals and criteria.

The PM10 consists of particles with a mean aerodynamic diameter of 10 microns or less and 

consists of fine (PM2.5, i.e. particles with a diameter of 2.5 microns or less) and coarse (PMC, i.e., 

particles with a diameter between 2.5 and 10 microns) modes. The PM2.5 is composed of the 

following component species:

• sulfate (SO4) that is typically in the form of ammonium sulfate;

• nitrate (NO3) that is typically in the form of ammonium nitrate;

• ammonium (NH4) that is associated with SO4 and NO3; 

• elemental carbon (EC) that is also called black carbon (BC) and light-absorbing 

carbon (LAC);
Air Quality: Cumulative and Visibility Impacts H-49

• organic aerosol (OA) that includes primary (POA) and secondary organic aerosol 

(SOA) and is composed or organic carbon (OC) and other atoms (e.g., oxygen) 

that are adhered to the OC; and

• other PM2.5 (OPM2.5) that is primarily crustal in nature (SOIL) but can also include 

other compounds as well as measurement artifacts.

Model performance statistics were calculated for total PM mass using observations from the 

FRM, CSN, SEARCH, and IMPROVE networks and then evaluated for PM10 and PM2.5 component 

species using data from the CSN, SEARCH, and IMPROVE sites. 

H.5.5 Initial Model Performance Results

Results of initial CAMx runs for the 36- and 12-km domains configured as described in 

Section H.4 were evaluated in terms of the MPE statistics described above to determine if any 

corrections or adjustments to model inputs were needed. In some cases, results from CAMx were 

compared with results from CMAQ to determine potential underlying causes of poor model 

performance. Results of these analyses indicated ozone and PM2.5 over prediction biases, which 

were especially pronounced along the Gulf Coast. Evaluation of results for individual PM 

components showed that much of the PM2.5 over prediction in coastal areas was associated with 

over prediction of sea salt emissions as evidenced by over prediction of sodium (Na) and 

consequently over prediction of nitrate PM as a result of nitrate substitution of chloride ions. This 

was confirmed by sensitivity tests in which sea salt emissions were reduced by a factor of five as 

suggested by regressions of predicted vs. observe Na at IMPROVE and CSN monitoring sites. 

Consistent with results of other modeling studies in the southeastern U.S., the ozone over 

prediction bias was judged to likely be associated at least in part with known over prediction biases 

of ozone over the Gulf of Mexico in many different global models, including GEOS-Chem resulting in 

over estimates of boundary condition ozone and over prediction of isoprene by the MEGAN biogenic 

model (Johnson et al., 2015). A series of sensitivity tests based on CAMx performance over the 

36-km domain with reduced ozone and ozone precursor BCs and reduced sea salt emissions 

confirmed that these modifications resulted in generally improved model performance. To this were 

added two additional modifications: the application of a commonly used adjustment to vertical 

diffusivity coefficients (Kv patch), which has been shown to improve model performance overnight 

and in urban areas (ibid); and a reduction in residential wood combustion (RWC) emissions following 

results of Adelman et al. (2014). A set of final 36-km and 12/4-km model runs were then completed 

with these modifications in place. 

H.5.6 Final Model Performance Results

After making the model input and configuration revisions described in the previous section, 

CAMx was rerun on the 36-km grid and boundary conditions extracted for the 12/4-km, two-way 

nested grid run. Results of the MPE for the 12/4-km grid run are presented in this section. 
H-50 Gulf of Mexico Multisale EIS

H.5.6.1 Ozone

Model performance results for ozone are summarized in terms of monthly NMB and NME in 

soccer plots for AQS and CASTNet network monitors within the 4-km and 12-km domains in Figure

H-21. Model performance for nearly all months is within the ±15% NMB and <35% NME ozone 

performance goals listed in Table H-12 (which corresponds to the innermost “goal” box shown in the 

figure), with the principal exceptions being performance during July and August for sites in the 

4-km domain (note only one CASTNet site – site ALC188, Alabama-Coushatta – is located within the 

4-km domain). 

Figure H-21. Monthly Normalized Mean Bias and Normalized Mean Error for Daily Maximum 8-hour 

Average Ozone at AQS (left) and CASTNet (right) Monitoring Sites Located within the 

4-km Modeling Domain (top) and the 12-km Domain (bottom).

As illustrated by the threshold exceedance counts in Figure H-22, the ozone season in the 

far South generally follows a bimodal distribution with a pronounced ozone peak in spring and a 

secondary peak in late summer to early fall. There is a noticeable lack of high ozone events during 

July. This seasonal pattern is reproduced in the model results as shown in Figure H-23. Model 

performance statistics generated using the AMET tool are summarized by calendar quarter. We 
Air Quality: Cumulative and Visibility Impacts H-51

therefore focus further attention on ozone model performance results for Q2 (April-June) and Q3 

(July-September), as these roughly coincide with the seasonal ozone peaks.

Figure H-22. Fraction of Site-days during Each Month of 2012 with Observed Daily Maximum 

8-hour Ozone Exceeding 60 (top), 65 (middle), or 70 (bottom) ppb Over All Monitoring Sites 

in the 4-km Domain.
H-52 Gulf of Mexico Multisale EIS

Figure H-23. Observed (blue) and Predicted (red) Monthly Mean Daily Maximum 8-hour Average Ozone 

Over All Sites in the 4-km Modeling Domain.

Ozone model performance for Q2 (April-May) and Q3 (July-September) over sites in the 

4-km domain is illustrated by the scatter plots in Figure H-24. Standard scatter plots are shown in 

the left-hand column and corresponding scatter density plots are shown in the right-hand column. 

Colors in the scatter density plot indicate the fraction of data in each 2 ppb bin, thus revealing the 

data density variations that are otherwise obscured in regions with numerous overlapping points in 

the standard scatter plots. Model performance in Q2 is better than in Q3 primarily due to a lower 

bias (NMB of 5.2% in Q2 as compared to 20.1% in Q3). The scatter density plots show that the Q3 

bias is primarily associated with over prediction of mid- and low-range values with less bias for 

values exceeding 60 ppb. Summaries of ozone performance statistics with a 60 ppb observed 

ozone cutoff applied are further discussed below. 
Air Quality: Cumulative and Visibility Impacts H-53

Figure H-24. Scatter (left) and Scatter Density (right) Plots for Observed vs. Predicted Daily Maximum 

8-hour Ozone in Q2 (top) and Q3 (bottom) for All AQS Monitoring Sites in the 4-km Modeling 

Domain.

The spatial distribution of NMB over the full 12-km domain is shown in Figure H-25. Note 

that these results are based on the 12-km gridded model resolution for all sites shown. The NMB is 

within ±15% at most sites during Q2 but exceeds +15% at most sites along the Gulf Coast and 

throughout the southern tier and southeast Atlantic States in Q3. 
H-54 Gulf of Mexico Multisale EIS

Figure H-25. Normalized Mean Bias (NMB) for Daily Maximum 8-hour Ozone for Q2 (top) and Q3 

(bottom).

The USEPA recommends that ozone model performance statistics be calculated using a 

60-ppb observed ozone concentration cut-off value (Simon et al., 2012; USEPA, 2014). That is, the 

model performance statistics are calculated for all predicted and observed ozone pairs matched by 

time and location for which the observed value is 60 ppb or higher. Table H-13 lists model 

performance summary statistics derived from the 4-km resolution model output for hourly and 8-hour 

daily maximum ozone with no concentration cut-off applied and with cut-offs of 40 or 60 ppb applied 
Air Quality: Cumulative and Visibility Impacts H-55

for Q2 and Q3. Values of NMB and NME exceeding USEPA’s performance goals as listed in Table

H-12 are highlighted. Biases trend from positive to slightly negative as the threshold concentration 

increases but are always within the Performance Goal for Q2 and also under application of the 

40- and 60-ppb thresholds in Q3. The NME is always within the USEPA Performance Goal except 

for hourly values in Q3 when no cut-off is applied. 

Table H-13. Model Performance Statistics at Different Observed Ozone Concentration Screening 

Thresholds Based on All Monitoring Sites in the 4-km Domain (shaded cells indicate values 

exceeding USEPA performance goals).

Monitor Site Q2 (April – June) Q3 (July – September)

N NMB (%) NME (%) NMB (%) NME (%)

USEPA Performance Goal ≤±15% ≤35% ≤±15% ≤35%

Ozone Cut-Off Concentrations DMAX8 Ozone

0 6399 5.2 14.1 6217 20.1 25.6

40 4326 2.1 11.6 3218 7.9 15.9

60 1246 -5.7 9.9 375 -9.2 12.6

Ozone Cut-Off Concentrations Hourly Ozone

0 152327 10.9 30.5 149676 30.6 46.7

40 53213 -3.5 16.7 22751 1.5 19.6

60 11229 -10.6 14.7 3498 -13.9 17.8

Time series of observed and predicted daily maximum 8-hour ozone are plotted in Figure

H-26 for the monitoring site in each county in the Houston-Galveston-Brazoria ozone nonattainment 

area with the highest ozone design values during the 2010-2014 design value periods (2010-2012, 

2011-2013, 2012-2014): Northwest Harris County site (AQS ID 48-201-0029)15, Manvel Croix Park 

– Brazoria County (AQS ID 48-039-1004), and Galveston 99th St. – Galveston County (AQS ID 

48-167-1034). 

Time series of observed and predicted daily maximum 8-hour ozone are plotted in Figure

H-27 for two monitoring sites in the Baton Rouge ozone nonattainment area: LSU (AQS ID 22-033-

0003) and Carville (AQS ID 22-047-0012). These sites typically had the highest ozone design 

values in the Baton Rouge area during the 2010-2014 design value periods. 

The time series for the ALC188 (Alabama-Coushatta, Texas) CASTNet site (the only 

CASTNet site in the 4-km domain) are shown in Figure H-28. 

Overall model performance as seen in these time series is good, especially in Q2 and 

especially in the Houston-Galveston area. There is a tendency towards over prediction in Q3 at 

 

15 This site recorded either the maximum or was within 1 ppb of the maximum ozone design value of all 

sites in Harris County during this period.
H-56 Gulf of Mexico Multisale EIS

Galveston and more noticeably at the Baton Rouge sites, consistent with the results for all sites 

presented above. 

Figure H-26. Time Series of Daily Maximum 8-hour Ozone at Monitoring Sites with Highest Design 

Values in Harris (top), Brazoria (middle), and Galveston (bottom) Counties, Texas, for Q2 

(left) and Q3 (right).

Figure H-27. Time Series of Daily Maximum 8-hour Ozone at Monitoring Sites in the Baton Rouge 

Nonattainment Area: LSU (top) and Carville (bottom) for Q2 (left) and Q3 (right).
Air Quality: Cumulative and Visibility Impacts H-57

Figure H-28. Time Series of Daily Maximum 8-hour Ozone at the ALC188 (Alabama-Coushatta, Texas) 

CASTNet Monitoring Site for Q2 (top) and Q3 (bottom).

H.5.6.2 Particulate Matter

The CAMx model performance for particulate matter (PM) was evaluated for total PM2.5

mass and speciated PM2.5 measurements. The PM performance was compared against the 

performance goals and criteria given in Table H-12. Note that the PM goals and criteria are not as 

stringent as those for ozone because both PM measurements and PM emissions are subject to 

greater uncertainties and PM formation and transformation processes are more complex and difficult 

to model. Each PM measurement technique has its own artifacts; different measurement 

technologies can produce different observed PM2.5 values that differ by as much as 30 percent. The 

USEPA’s latest PGM modeling guidance includes a section on PM measurement artifacts for the 

monitoring technologies used in routine networks in the U.S. (USEPA, 2014). The PM model 

performance results must be evaluated in light of these measurement uncertainties and artifacts as 

even a “perfect” model may not achieve the PM performance goals and criteria relative to the 

imperfect measurements.
H-58 Gulf of Mexico Multisale EIS

The PM10 consists of particles with a mean aerodynamic diameter of 10 microns or less and 

consists of fine (PM2.5, i.e. particles with a diameter of 2.5 microns or less) and coarse (PMC, i.e., 

particles with diameter between 2.5 and 10 microns) modes. The PM2.5 is composed of the following 

component species:

• sulfate (SO4) that is typically in the form of ammonium sulfate;

• nitrate (NO3) that is typically in the form of ammonium nitrate;

• ammonium (NH4) that is associated with SO4 and NO3; 

• elemental carbon (EC) that is also called black carbon (BC) and light-absorbing 

carbon (LAC);

• organic aerosol (OA) that includes primary (POA) and secondary organic aerosol 

(SOA) and is composed or organic carbon (OC) and other atoms (e.g., oxygen) 

that are adhered to the OC; and

• other PM2.5 (OPM2.5) that is primarily crustal in nature (SOIL) but can also include 

other compounds such as sea salt and may include measurement artifacts as it 

is determined by subtraction of the sum of individual measured species from the 

measured total PM2.5. 

In the following subsections, we first evaluate the CAMx 2012 base case simulation for total 

PM2.5 mass using observations from the FRM, CSN, and IMPROVE monitoring networks and then 

evaluate results for PM10 and PM2.5 component species. There are also numerous hourly PM2.5 and 

PM10 monitoring sites in the region that are also used in the MPE, but results for these are not 

presented here as they may suffer from additional measurement artifacts and uncertainties and are 

not directly comparable to the speciated PM data. 

H.5.6.2.1 Total PM2.5 Mass

Daily total PM2.5 mass is measured at FRM, IMPROVE, and CSN network monitors, and 

hourly PM2.5 is measured at FRM equivalent and non-FRM monitoring sites. Because only three 

CSN sites and no IMPROVE network sites are located within the 4-km CAMx modeling domain, 

some performance statistics are presented here for all monitors within the southeastern U.S. domain 

shown in Figure H-29.

16

 

16 This area corresponds to the high-resolution domain used for the meteorological (WRF) modeling 

described in Section 2. 
Air Quality: Cumulative and Visibility Impacts H-59

Figure H-29. PM Monitoring Sites in the Southeastern U.S. Domain (triangles – AQS hourly, 

square – IMPROVE, diamond – CSN, circles – AQS FRM daily).

Figure H-30 displays soccer plots of total PM2.5 mass model performance across the FRM, 

CSN, and IMPROVE monitoring networks in the southeastern U.S. domain. Note that these results 

are based on 12-km resolution CAMx output. Also shown in the soccer plots are boxes that 

represent the performance goals for ozone (most inner) and PM (middle), and the PM performance 

criteria (most outer). Performance for the late fall and winter months (October-February) is 

characterized by larger positive NMB and higher NME in each network. This bias is somewhat more 

extreme in the FRM data. Performance results are within or nearly within the PM performance goals 

except for January and October-December for all networks and within the PM performance criteria 

for all months at all networks.

As illustrated in Figure H-31, over prediction in Q4 appears to be primarily associated with 

“other PM2.5” (OPM2.5). Measured OPM likely consists mostly of crustal material (dust) in addition to 

sea salt. Modeled OPM2.5 is defined as the sum of unspeciated PM, crustal material, and sea salt. 

Comparisons of particulate OC and EC performance statistics are presented in Figure H-32. 

The NMB and NME are within the PM performance goals with the exception of July and August EC 

predictions at CSN sites; the over prediction bias is smaller at SEARCH sites. Note that both the 

SEARCH and CSN networks use the Thermal Optical Reflectance (TOR) method to determine OC 

and EC.
H-60 Gulf of Mexico Multisale EIS

Figure H-30. Soccer Plots of Total PM2.5 Mass Model Performance Across the IMPROVE (top left), CSN 

(top right), SEARCH (bottom left), and FRM Daily (bottom right) Monitoring Networks for 

Sites in the Southeastern U.S. Domain.
Air Quality: Cumulative and Visibility Impacts H-61

Figure H-31. Comparisons of Predicted with Observed Daily Average PM at CSN Network Sites in the 

Southeastern U.S. for Q2 (left) and Q4 (right) for Total PM2.5 (top), Other PM2.5 (middle), 

and Sodium (bottom).
H-62 Gulf of Mexico Multisale EIS

Figure H-32. Comparisons of Observed vs. Predicted OC (top) and EC (bottom) at SEARCH (left) and 

CSN (right) Network Sites in the Southeastern U.S.

H.5.6.2.2 Nitrogen Species (NO2, NOy, and NO3) 

Soccer plot summaries of NMB and NME for nitrogen species are shown in Figure H-33 and 

Figure H-34 for monitoring sites in the 4-km domain. The NO2, NOy, and particulate NO3 are over 

predicted, especially in the summer months. The NO3 over prediction at coastal sites could be at 

least partially due to over prediction of sea salt emissions as a result of Cl- ion substitution. This is 

consistent with under prediction of particulate Cl at some sites despite over prediction of Na. Nitrate 

deposition biases fall within the performance criteria in all but one month, but errors are large 

indicating a lack of model precision. Measurement uncertainties may also be contributing to the 

large errors. 
Air Quality: Cumulative and Visibility Impacts H-63

N/A

Figure H-33. Monthly Normalized Mean Bias and Normalized Mean Error for Hourly NO2 (top) and Daily 

NOy (bottom) at SEARCH Network Sites (left) and AQS Sites (right) in the 4-km Domain.
H-64 Gulf of Mexico Multisale EIS

Figure H-34. Monthly Normalized Mean Bias and Normalized Mean Error for NO3 at SEARCH Network 

Monitoring Sites (top left) and AQS Sites (top right) and NO3 Deposition at NADP Sites 

(bottom) in the Southeastern U.S. (Note: Additional months for SEARCH NO3 not shown 

as the NMB and NME exceed the upper axis limits.) 
Air Quality: Cumulative and Visibility Impacts H-65

H.5.6.2.3 Sulfur Species (SO2 and SO4) 

Model performance for hourly SO2 within the 4-km domain is summarized in terms of 

monthly NME and NMB in Figure H-35. The AQS network SO2 monitors are typically cited to 

represent the influence of major utility or industrial SO2 sources and thus may measure short-term 

peaks associated with plume impacts from a discrete source. As a result, the timing, location, and 

magnitudes of peak SO2 concentrations are not well represented within the 4-km grid modeling 

results. In addition, monitors near large ports may be influenced by discrete plumes from passing 

marine vessels, which could be sufficient to cause 1-hour peaks in the monitoring data. Since 

marine vessel emission inputs to the model are temporally averaged, these discrete events cannot 

be properly simulated by the model. Given these characteristics of the SO2 monitoring data, we 

would expect large 1-hour SO2 modeling errors as shown in Figure H-35, although we would not 

necessarily expect the positive normalized mean biases that occur in every month. 

Over prediction bias of hourly SO2 at SEARCH network sites seen in the top row of Figure

H-35 is in contrast to lower SO4 bias shown in the next row. Good performance for SO4 is also 

evident at CSN network sites. The SO4 deposition is under predicted in most months. Reasons for 

the overall SO2 over prediction bias at sites in the 4-km domain (top row of Figure H-33) are not 

immediately apparent. Examination of results over all sites in the 12-km domain (Figure H-36) 

shows wide variations in bias from site-to-site, including between sites in the 4-km domain, 

suggesting that the lower bias in the network average performance statistics in Figure H-33 are 

partly the result of over- and under-predictions cancelling each other out. 
H-66 Gulf of Mexico Multisale EIS SO2 SO4 SO4 Deposition

Figure H-35. Monthly Normalized Mean Bias and Normalized Mean Error at Monitoring Sites in the 

4-km Domain for SO2 (top row, AQS sites left panel, SEARCH sites right panel), SO4

(middle row, CSN sites left panel, SEARCH sites right panel), and SO4 Deposition 

Measured at NADP Sites (bottom row).
Air Quality: Cumulative and Visibility Impacts H-67

Figure H-36. Annual Normalized Mean Bias for Hourly SO2 (based on 12-km resolution CAMx 

results).

H.5.6.2.4 Ammonium (NH4) 

Model performance for particulate ammonium at monitors within the 4-km domain is 

summarized in terms of monthly NME and NMB in Figure H-37. Performance at the two SEARCH 

network sites falls within the PM criteria bounds, but positive biases and large errors are seen at the 

three CSN sites. Note that results based on all sites in the southeastern U.S. domain (at 12-km 

resolution) are very similar. The NH4 overestimation bias at the CSN sites is likely due to NO3

over-prediction (Figure H-34), as SO4 is showing biases closer to zero (Figure H-35). Examination 

of individual CSN site results shows acceptable performance at the Houston site (NMB=20%, 

NME=59%), but large positive biases and errors at the Baton Rouge, Louisiana, and Laurel, 

Mississippi, monitors. 
H-68 Gulf of Mexico Multisale EIS

Figure H-37. Monthly Normalized Mean Bias and Normalized Mean Error for Daily Average NH4 at CSN 

(top) and SEARCH (bottom) Network Sites in the 4-km Modeling Domain.
Air Quality: Cumulative and Visibility Impacts H-69

H.5.6.2.5 Carbon Monoxide (CO)

Model performance for hourly CO within the 4-km domain is summarized in terms of monthly 

NME and NMB in Figure H-38. Hourly CO is under predicted on average at AQS sites where the 

influenced of local mobile sources at sub-grid scales is not adequately resolved by the model’s 4-km 

grid resolution; model performance is better at the SEARCH sites, several of which are in rural 

locations. 

Figure H-38. Monthly Normalized Mean Bias and Normalized Mean Error for Hourly CO at SEARCH 

Network Sites (left) and AQS Sites (right).

H.6 AIR RESOURCE ASSESSMENT APPROACH

H.6.1 Future Year Modeling

The CAMx was run with the Future Year scenario emissions inventory, including emissions 

from the 2017-2022 GOM Multisale EIS sources described in Appendix G. Model results were 

post-processed for analysis of air quality impacts with respect to the NAAQS and AQRVs; PSD 

increments were also calculated for information purposes. Source apportionment technology was 

used to provide estimates of source group impacts, including impacts of potential new sources 

associated with the 2017-2022 GOM Multisale EIS. Details of the source apportionment and postprocessing procedures are presented in this section. 

H.6.1.1 Source Apportionment Design

The CAMx Ozone Source Apportionment Technology (OSAT) and Particulate Source 

Apportionment Technology (PSAT) tools were used to obtain the separate air quality, deposition, 

and visibility impacts associated with existing and new (2017-2022 GOM Multisale EIS) OCS oil and 

gas development in the GOM, as well as from other emission sources in the GOM and several other 

source categories as described in Appendix G. The CAMx OSAT and PSAT source apportionment 

tools use reactive tracers that operate in parallel to the host PGM to provide air quality and 

deposition contributions due to user-selected source groups. The CAMx determines the 

contributions of emissions from each source category to the total CAMx model concentrations and 
H-70 Gulf of Mexico Multisale EIS

depositions during the course of the simulation. A detailed description of the CAMx source 

apportionment tools is available in the CAMx user’s guide (ENVIRON, 2014).

The Anthropogenic Precursor Culpability Assessment (APCA) version of the CAMx Ozone 

Source Apportionment Technology (OSAT) was used in the future year scenario modeling. The 

APCA differs from OSAT in that it distinguishes between natural and anthropogenic emissions; when 

ozone is formed due to the interaction of biogenic VOC and anthropogenic NOx under VOC-limited 

conditions, a case OSAT would assign the ozone formed to the biogenic VOC, APCA recognizes 

that biogenic VOC is uncontrollable and re-directs the ozone formed to the anthropogenic NOx. 

Thus, APCA only assigns ozone formed to natural emissions when it is due to natural VOC 

interacting with natural NOx emissions. The APCA requires that the first source category is always 

natural emissions. Like OSAT, APCA uses four reactive tracers to track the ozone contributions of 

each source group: NOx emissions (Ni); VOC emissions (Vi);and ozone formed under VOC-limited 

(O3Vi) and NOx-limited (O3Ni) conditions.

For PM, three families of Particulate Source Apportionment Technology (PSAT) source 

apportionment tracers were used to track contributions of SO4, NO3/NH4, and primary PM that 

require, respectively, 2, 7 and 6 reactive tracers for each family. Thus, combined APCA/PSAT 

source apportionment uses 19 reactive tracers to track the contribution of each source category. 

The Secondary Organic Aerosol (SOA) family of PSAT tracers was not used in the future year 

scenario source apportionment modeling because (1) only a few specific kinds of VOC species form 

SOA (i.e., isoprene, terpenes, sesquiterpenes, and aromatics), and these VOCs are mainly emitted 

by biogenic sources with some aromatic species (e.g., toluene and xylene) emitted by anthropogenic 

sources (e.g., gasoline combustion) (emissions from oil and gas exploration and production has 

negligible aromatic VOC emissions); and (2) the chemistry of SOA is quite complex, involving 

numerous gaseous, semi-volatile, and particulate species so that PSAT requires 21 tracers to track 

the SOA contributions of each source group (Morris et al., 2015). As a result, including SOA would 

more than double the number of reactive tracers, resulting in doubling of the computer time needed 

for the CAMx source apportionment run. 

H.6.1.2 Future Year Source Apportionment Simulation

The CAMx 2017 source apportionment simulation was conducted for 1 January to 

31 December calendar year over the 12-km southeastern U.S. modeling domain shown in Figure

H-5. The boundary conditions (BCs) defining inflow concentrations around the lateral boundaries of 

the 12-km domain were obtained from a future year CAMx simulation of the 36-km continental U.S.

(CONUS) domain shown in Figure H-5. Both the 36-km and 12-km simulations made use of the 

same 2012 WRF meteorology and model configuration used in the base case simulation. 
Air Quality: Cumulative and Visibility Impacts H-71

H.6.2 Post-Processing of Future Year Source Apportionment Modeling Results

H.6.2.1 Overview

The CAMx future year scenario model and ozone and particulate matter source 

apportionment modeling outputs were post-processed for comparison against the NAAQS and PSD 

concentration increments listed in Table H-14 and other thresholds of concern (TOC), as discussed 

below. For analyzing NAAQS and AQRV impacts at Class I and sensitive Class II areas, the 

Thresholds of Concern (TOCs) used were as defined by the Federal Land Manager (FLM) that 

manages each Class I/II area as prescribed in the June 23, 2011, Memorandum of Understanding 

(MOU) for evaluating onshore oil and gas AQ/AQRV impacts.17

The CAMx source apportionment results for individual source categories were used to 

evaluate the incremental impacts of each of a set of hierarchical source groups as defined in Table

H-15. Note that Source Group B represents all new direct emissions associated with the 2017-2022 

GOM Multisale EIS and Source Group C represents these sources in addition to all existing OCS 

platforms and associated support vessel and aircraft activity. Also note that Source Group E 

includes Source Groups A-D, along with all other anthropogenic sources, but excludes fires and 

other natural sources (biogenics, lightning NOx, sea salt) and the contribution of boundary 

conditions. 

Table H-14. NAAQS and PSD Increments. 

Pollutant Pollutant/Averaging 

Time NAAQS PSD Class I Increment1

PSD Class II 

Increment1

CO 1-hour2 35 ppm 40,000 

μg/m3 -- --

CO 8-hour2 9 ppm 10,000 μg/m3 -- --

NO2 1-hour3 100 ppb 188 μg/m3 -- --

NO2 Annual4 53 ppb 100 μg/m3 2.5 μg/m3 25 μg/m3

O3 8-hour5 0.070 ppm 137 

μg/m3 -- --

PM10 24-hour6 150 μg/m3 8 μg/m3 30 μg/m3

PM10 Annual7 -- 4 μg/m3 17 μg/m3

PM2.5 24-hour8 35 μg/m3 2 μg/m3 9 μg/m3

PM2.5 Annual9 12 μg/m3 1 μg/m3 4 μg/m3

SO2 1-hour10 75 ppb 196 μg/m3

SO2 3-hour11 0.5 ppm 1,300 μg/m3 25 μg/m3 512 μg/m3

SO2 24-hour -- 5 μg/m3 91 μg/m3

SO2 Annual4 -- 2 μg/m3 20 μg/m3

 

17 http://www.epa.gov/compliance/resources/policies/nepa/air-quality-analyses-mou-2011.pdf
H-72 Gulf of Mexico Multisale EIS

Pollutant Pollutant/Averaging 

Time NAAQS PSD Class I Increment1

PSD Class II 

Increment1

1 The PSD demonstrations serve information purposes only and do not constitute a regulatory PSD 

increment consumption analysis.

2 No more than one exceedance per calendar year. 3

 98th percentile, averaged over 3 years. 4 Annual mean not to be exceeded. 5 Fourth-highest daily maximum 8-hour ozone concentrations in a year, averaged over 3 years, 

NAAQS promulgated December 28, 2015. 6 Not to be exceeded more than once per calendar year on average over 3 years. 7

 3-year average of the arithmetic means over a calendar year. 8

 98th percentile, averaged over 3 years. 9 Annual mean, averaged over 3 years, NAAQS promulgated December 14, 2012. 10 99th percentile of daily maximum 1-hour concentrations in a year, averaged over 3 years. 11 No more than one exceedance per calendar year (secondary NAAQS). 

Table H-15. Source Group for Incremental Impacts Analysis. 

Source 

Group 

Included Source 

Categoriesa Comment

A SC3 New oil and gas platform sources under the 2017-2022 GOM 

Multisale EIS scenario (w/Action)

B SC3, SC4 Add support vessels and aircraft associated with new platform 

sources (w/Action)

C SC3, SC4, SC5

Add oil and gas platforms and associated support vessels and 

aircraft under the No Action alternative (existing base case 

sources)

D SC3, SC4, SC5, 

SC6

Add all other marine vessel activity in the GOM, not associated 

with OCS oil and gas activities

E SC3, SC4, SC5, 

SC6, SC7, SC8 Add all other U.S. and non-U.S. anthropogenic sources

F SC1, SC2, SC8, 

SC10

Natural and non-U.S. sources (including US sources outside of the 

12-km modeling domain) a Refer to Table H-6.

H.6.2.2 Comparison against NAAQS

The CAMx future year scenario predicted total concentrations from all emission sources 

were post-processed for comparison to the applicable NAAQS, as listed in Table H-14, in two 

different ways. First, the CAMx predictions were compared directly against each NAAQS. This is 

referred to as the “absolute” prediction comparison. These absolute prediction comparisons may be 

misleading in cases in which the model exhibits significant prediction bias. In recognition of this, 

USEPA modeling guidance (USEPA, 2007 and 2014) recommends using the model in a relative 

sense when projecting future year ozone, PM2.5, and regional haze levels; and the USEPA has 

developed the Modeled Attainment Test Software (MATS; Abt. 2014) for making such future year 

projections. This approach uses the ratio of future year to current year modeling results to develop 

Relative Response Factors (RRFs) that are applied to observed current year Design Values 

(abbreviated as either DVC or DVB) to make future year Design Value (DVF) projections (i.e., 

DVF = DVC x RRF). The MATS was applied to the prediction of both ozone and PM2.5 DVFs. The 
Air Quality: Cumulative and Visibility Impacts H-73

MATS was also used for assessing the cumulative visibility impacts at IMPROVE monitoring sites in 

the 12-km domain, as discussed in more detail below.

H.6.2.3 Impacts at Class I and Sensitive Class II Areas

The incremental AQ/AQRV contributions associated with emissions from each source group 

listed in Table H-15 were calculated at the Class I and sensitive Class II areas shown in Figure

H-39. The selected areas include all Class I and sensitive Class II areas within the 4-km modeling 

domain plus additional Class I areas within the 12-km modeling domain. 

Table H-16 lists those areas that are located in Gulf Coast or nearby states and thus are of 

greatest interest to this analysis. Refer to Section Error! Reference source not found. for a 

complete list of all areas shown in Figure H-39, along with the results of the visibility analyses. 

Receptors for each Class I and sensitive Class II area were defined based on the spatial 

extent of the Class I/II area defined using shapefiles obtained from the applicable Federal Land 

Management Agency. A GIS was used to determine the set of grid cells overlapping each area by at 

least 5%. Model results for the identified grid cells were then used to represent predicted ambient 

concentrations and deposition in each area. 

Figure H-39. Class I and Sensitive Class II Areas for Which Incremental AQ/AQRV Impacts 

Were Calculated.
H-74 Gulf of Mexico Multisale EIS

Table H-16. Class I and Sensitive Class II Areas in Gulf Coast and Nearby States.

Type Name Agency1 State Modeling Domain

Class I Breton Wilderness FWS LA 4 km

Class II Breton NWR FWS LA 4 km

Class II Gulf Islands NS NPS MS, FL 4 km

Class II Padre Island NS NPS TX 4 km

Class I Bradwell Bay FS FL 12 km

Class I St. Marks FWS FL 12 km

Class I Chassahowitzka FWS FL 12 km

Class I Everglades NP NPS FL 12 km

Class I Okefenokee FWS GA 12 km

Class I Wolf Island FWS GA 12 km

Class I Cohutta FS GA 12 km

Class I Sipsey FS AL 12 km

Class I Guadalupe Mountains NPS TX 12 km

Class I Big Bend NPS TX 12 km

Class I Wichita Mountains FWS OK 12 km

Class I Caney Creek FS AR 12 km

Class I Upper Buffalo FS AR 12 km

1 FWS = U.S. Dept. of the Interior, Fish and Wildlife Service; FS = U.S. Dept. of Agriculture, 

Forest Service; NPS = U.S. Dept. of the Interior, National Park Service; NS = National 

Seashore; NWR = National Wildlife Refuge.

H.6.2.3.1 Incremental Visibility Impacts

Visibility impacts were calculated for each source group using incremental concentrations as 

quantified by the CAMx PSAT tool. Changes in light extinction from CAMx model concentration 

increments due to emissions from each source group were calculated for each day at grid cells 

representing each Class I and sensitive Class II area. The FLAG (2010) procedures were used in 

the incremental visibility assessment analysis.

The visibility evaluation metric used in this analysis is based on the haze index (HI), which is 

measured in deciview (dv) units and is defined as follows:

HI = 10 × ln[bext/10]

Where bext is the atmospheric light extinction measured in inverse megameters (Mm-1) and is 

calculated primarily from atmospheric concentrations of particulates. 

A more intuitive measure of haze is visual range (VR), which is defined as the distance at 

which a large black object just disappears from view, and is measured in km. Visual range is related 

to bext by the formula VR = 3912/bext. The advantage of using the HI rather than VR is that a given 

change in HI is approximately associated with the same degree of perceived change in visibility 

regardless of the baseline conditions whereas small changes in VR are much more noticeable under 

clean conditions as compared to hazy conditions. 
Air Quality: Cumulative and Visibility Impacts H-75

The incremental concentrations due to each source group were added to natural background 

extinction in the extinction equation (bext) and the difference between the haze index with the source 

group concentrations included and the haze index based solely on natural background 

concentrations is calculated. This quantity is the change in haze index, which is referred to as “delta 

deciview” (Δdv):

Δdv = 10 × ln[bext(SC+background)/10] - 10 × ln[bext(background)/10] 

Δdv = 10 × ln[bext(SC+background)/bext(background)] 

Here bext(SCi+background) refers to atmospheric light extinction due to impacts from the source 

category plus background concentrations, and bext(background) refers to atmospheric light extinction due 

to natural background concentrations only. 

For each source group, the estimated visibility degradation at the Class I areas and sensitive 

Class II areas due to the source group are presented in terms of the number of days that exceed a 

threshold change in deciview (Δdv) relative to background conditions. The number of days with a 

deciview greater than 0.5 and 1.0 are reported. 

IMPROVE Reconstructed Mass Extinction Equations

The FLAG (2010) procedures for evaluating visibility impacts at Class I areas use the revised 

IMPROVE reconstructed mass extinction equation to convert PM species in μg/m3 to light extinction 

(bext) in inverse megameters (Mm-1) as follows:

bext = bSO4 + bNO3 + bEC + bOCM + bSoil + bPMC+ bSeaSalt+ bRayleigh+ bNO2

where

bSO4 = 2.2 × fS(RH) × [Small Sulfate] + 4.8 × fL(RH) × [Large Sulfate]

bNO3 = 2.4 × fS(RH) × [Small Nitrate] + 5.1 × fL(RH) × [Large Nitrate]

bOCM = 2.8 × [Small Organic Mass] + 6.1 × [Large Organic Mass]

bEC = 10 × [Elemental Carbon]

bSoil = 1 × [Fine Soil]

bCM = 0.6 × [Coarse Mass]

bSeaSalt = 1.7 × fSS(RH) × [Sea Salt]

bRayleigh = Rayleigh Scattering (Site-specific)

bNO2 = 0.33 × [NO2 (ppb)] {or as: 0.1755 × [NO2 (μg/m3

)]}.

f(RH) are relative humidity adjustment factors that account for the fact that sulfate, nitrate, 

and sea salt aerosols are hygroscopic and are more effective at scattering solar radiation at higher 
H-76 Gulf of Mexico Multisale EIS

relative humidity. FLAG (2010) recommends using monthly average f(RH) values rather than the 

hourly averages recommended in the previous FLAG (2000) guidance document in order to 

moderate the effects of extreme weather events on the visibility results. 

The revised IMPROVE equation treats “large sulfate” and “small sulfate” separately because 

large and small aerosols affect an incoming beam of light differently. However, the IMPROVE 

measurements do not separately measure large and small sulfate; they measure only the total PM2.5

sulfate. Similarly, CAMx writes out a single concentration of particulate sulfate for each grid cell. 

Part of the definition of the new IMPROVE equation is a procedure for calculating the large and 

small sulfate contributions based on the magnitude of the model output sulfate concentrations; the 

procedure is documented in FLAG (2010).18 The sulfate concentration magnitude is used as a

surrogate for distinguishing between large and small sulfate concentrations. For a given grid cell, 

the large and small sulfate contributions are calculated from the model output sulfate (which is the 

“Total Sulfate” referred to in the FLAG [2010] guidance) as

For Total Sulfate <20 μg/m3

: 

[Large Sulfate] = ([Total Sulfate] / 20 μg/m3

) × [Total Sulfate]

For Total Sulfate ≥20 μg/m3

: 

[Large Sulfate] = [Total Sulfate]

For all values of Total Sulfate:

[Small Sulfate] = [Total Sulfate] – [Large Sulfate]

The procedure is identical for nitrate and organic mass. 

The PSAT source apportionment algorithm does not separately track NO2 concentrations but 

instead tracks total reactive nitrogen (RGN) that consists of NO, NO2, and other reactive nitrogen 

compounds (e.g., N2O5, HONO, etc.). Thus, for each hour and each grid cell representing a 

Class I/II area, a source group’s incremental PSAT RGN contribution is converted to NO2 by 

multiplying by the total (all emissions) CAMx model NO2/RGN concentration ratio. Note that this 

same procedure is also used for contributions to NO2 concentrations.

Although sodium and particulate chloride are treated in the CAMx core model, these species 

are not carried in the CAMx PSAT tool. This does not affect the calculations of visibility impacts from 

individual source groups other than impacts from the natural source category (SC2). 

 

18 http://www.nature.nps.gov/air/Pubs/pdf/flag/FLAG_2010.pdf
Air Quality: Cumulative and Visibility Impacts H-77

Predicted daily average modeled concentrations due to each source group for receptor grid 

cells containing Class I and sensitive Class II areas were processed using the revised IMPROVE 

reconstructed mass extinction equation FLAG (2010) to obtain changes in bext at each sensitive 

receptor area that are converted to deciview and reported.

Annual average natural conditions for each Class I area were obtained from Table 6 in FLAG 

(2010) and monthly relative humidity factors for each Class I area from Tables 7-9 in FLAG (2010). 

The ∆dv was calculated for each grid cell that overlaps a Class I or sensitive Class II area by 5% or 

more for each day of the annual CAMx run. The highest ∆dv across all grid cells overlapping a 

Class I or sensitive Class II area by at least 5% was selected to represent the daily value at that 

Class I/II area. Visibility impacts due to emissions from each source group that exceed the 0.5 and 

1.0 Δdv thresholds are noted. 

Cumulative Visibility Impacts

The cumulative visibility impacts of the 2017-2022 GOM Multisale EIS were assessed 

following the recommendations from the U.S. Dept. of the Interior’s Fish and Wildlife Service (FWS) 

and NPS (USDOI, FWS and USDOI, NPS, official communication, 2012). This approach is based 

on an abbreviated regional haze rule method that estimates the future year visibility at Class I and 

sensitive Class II areas for the average of the Worst 20% (W20%) and Best 20% (B20%) visibility 

days with and without the effects of the source group emissions on visibility impairment. The 

cumulative visibility impacts used CAMx model output from the 2012 Base Year and 2017 Future 

Year emissions scenarios in conjunction with monitoring data to produce cumulative visibility impacts 

at each Class I and sensitive Class II area. The USEPA’s Modeled Attainment Test Software 

(MATS19) was used to make the 2017 visibility projections for the W20% and B20% days. The basic 

steps in the recommended cumulative visibility method are as follows (USDOI, FWS and USDOI, 

NPS, official communication, 2012):

(1) Calculate the observed average 2012 current year cumulative visibility impact 

using the haze index (HI, in deciviews) at each Class I area using 

representative IMPROVE measurement data to determine the 20% of days with 

the worst and 20% of days with the best visibility. The MATS is designed to use 

5 years of monitoring data centered on the base case year, which for 2012 

would include 2010-2014. However, MATS only includes IMPROVE monitoring 

data through 2012, so the 2008-2012 5-year period was used to define the 

visibility baseline conditions in the MATS visibility projections. 

(2) Estimate the relative response factors (RRFs) for each component of PM2.5 and 

for coarse mass (CM) corresponding to the new IMPROVE visibility algorithm 

using the CAMx 2012 and 2017 model output. The RRFs are based on the 

 

19 http://www.epa.gov/ttn/scram/modelingapps_mats.htm
H-78 Gulf of Mexico Multisale EIS

average concentrations across a 3 x 3 array of 4-km grid cells centered on the 

IMPROVE monitoring site location.

(3) Using the RRFs and ambient data, calculate 2017 future year daily 

concentration data for the B20% and W20% days using the CAMx 2012 base 

case and 2017 standard model concentration estimates and PSAT source 

apportionment modeling results two ways: 

(a) 2017 Total Emissions: Use total 2017 CAMx concentration results due to all 

emissions;

(b) 2017 No Cumulative Emissions: Use PSAT source apportionment results to 

eliminate contributions of PM concentrations associated with each source 

group. 

(4) Use the information in Step 3 to calculate the average 2017 visibility for the 20% 

Best and 20% Worst visibility days and the 2017 emissions.

(5) Assess the average differences in cumulative visibility impacts for each source 

group and also compare with the future and current observed Baseline visibility 

conditions.

Because of the need for IMPROVE observations, monitoring data from nearby Class I areas 

were used to represent areas without any IMPROVE monitors. 

H.6.2.3.2 Sulfur and Nitrogen Deposition

The CAMx-predicted wet and dry fluxes of sulfur- and nitrogen-containing species were 

processed to estimate total annual sulfur and nitrogen deposition values at each Class I and 

sensitive Class II area. The maximum annual sulfur and nitrogen deposition values from any grid 

cell that intersects a Class I receptor area was used to represent deposition for that area, in addition 

to the average annual deposition values of all grid cells that represent a Class I receptor area. 

Although the convention in the past has been to report just the maximum deposition in any receptor 

in a Class I/II area, since deposition relates to the total amount deposited across an entire 

watershed, the average metric may be considered a more relevant parameter for evaluating 

potential environmental effects. Maximum and average predicted sulfur and nitrogen deposition 

impacts are reported separately for each source group. 

Nitrogen deposition impacts were calculated by taking the sum of the nitrogen contained in 

the fluxes of all nitrogen species modeled by the CAMx PSAT source apportionment tool. The 

CAMx species used in the nitrogen deposition flux calculation are reactive gaseous nitrate species, 

RGN (NO, NO2, NO3 radical, HONO, N2O5), TPN (PAN, PANX, PNA), organic nitrates (NTR), 

particulate nitrate formed from primary emissions plus secondarily formed particulate nitrate (NO3), 

gaseous nitric acid (HNO3), gaseous ammonia (NH3), and particulate ammonium (NH4). The CAMx 

species used in the sulfur deposition calculation are primarily sulfur dioxide emissions (SO2) and 

particulate sulfate ion from primary emissions plus secondarily formed sulfate (SO4). 
Air Quality: Cumulative and Visibility Impacts H-79

FLAG (2010) recommends that applicable sources assess impacts of nitrogen and sulfur 

deposition at Class I areas. This guidance recognizes the importance of establishing critical 

deposition loading values (“critical loads”) for each specific Class I area as these critical loads are 

completely dependent on local atmospheric, aquatic, and terrestrial conditions and chemistry. 

Critical load thresholds are essentially a level of atmospheric pollutant deposition below which 

negative ecosystem effects are not likely to occur. FLAG (2010) does not include any critical load 

levels for specific Class I areas and refers to site-specific critical load information on FLM websites 

for each area of concern. This guidance does, however recommend the use of deposition analysis 

thresholds (DATs 20) developed by the NPS and FWS. The DATs represent screening level values 

for nitrogen and sulfur deposition for individual projects with deposition impacts below the DATS 

considered negligible. A DAT of 0.005 kilograms per hectare per year (kg/ha/yr) for both nitrogen 

and sulfur deposition has been established for both nitrogen and sulfur deposition in western Class I 

areas. A DAT of 0.01 kg/ha/yr has been established for both nitrogen and sulfur deposition for areas 

in the eastern U.S. As a screening analysis, results for Source Group B (new platforms and 

associated support vessels and aircraft associated with the 2017-2022 GOM Multisale EIS scenario) 

were compared to the DATs. Comparison of deposition impacts from cumulative sources to the DAT 

is not appropriate. 

For the 2012 base case and the combined source groups and total 2012 and future year 

emissions, the annual nitrogen and sulfur deposition were compared against critical load values 

established by the Federal Land Management agencies. Published nitrogen critical load values for 

areas managed by the NPS21 include minimum critical loads of 3 kg/ha/yr at the Gulf Islands 

National Seashore, as well as at Guadalupe Mountains and Big Bend, and 5 kg/ha/yr at Padre Island

National Seashore and Everglades National Park. These values represent the minimum of the 

critical loads for each biological community type (i.e., forests, herbaceous plants, lichen, mycorrhizal 

fungi, and nitrate leaching). Nitrogen and sulfur critical load values for areas managed by the U.S. 

Dept. of Agriculture’s Forest Service (USFS) include 5 kg/ha/yr at Bradwell Bay, Cohutta, Sipsey, 

Caney Creek and Upper Buffalo. The 5 kg/ha/yr critical load value for these areas applies 

separately to nitrogen and to sulfur deposition. As no separate critical load values for sulfur are 

available from the NPS areas, the sulfur critical loads were set equal to the values for nitrogen. No 

published critical load values were found for areas managed by the FWS; critical loads for these 

areas were set by reference to the NPS and USFS critical loads based on proximity and similarity of 

ecoregion types. Using this approach, both nitrogen and sulfur critical loads for the Breton 

Wilderness, Breton National Wildlife Refuge, St. Marks, Chassahowitzka, Okefenoke, and Wolf 

Island were set at 3 kg/ha/yr based on the Gulf Islands National Seashore value for Eastern 

Temperate Forests. The values for Wichita Mountains was set at 5 kg/ha/yr based on the NPS’ 

Chickasaw National Recreation Area Great Plains ecoregion value.

 

20 http://www.nature.nps.gov/air/Pubs/pdf/flag/nsDATGuidance.pdf

21 http://www.nature.nps.gov/air/Studies/criticalloads/Ecoregions/index.cfm
H-80 Gulf of Mexico Multisale EIS

H.6.2.4 PSD Increments

The maximum contribution of new oil and gas emissions in the Gulf of Mexico under the 

2017-2022 GOM Multisale EIS scenario were reported for each Class I and sensitive Class II area 

and were compared against the PSD increments given in Table H-14. Under the Clean Air Act, a 

PSD increment consumption analysis requires major stationary sources subject to PSD review to 

demonstrate that emission increases from the proposed source, in conjunction with all other 

emissions increases or reductions in the impacted area (typically within 50 kilometers), will not cause 

or contribute to concentrations of air pollutants that exceed PSD increments. The PSD increments 

have been established for NOx, SO2, and PM in Class I and Class II areas. Actions to be authorized 

by BOEM under the 2017-2022 GOM Multisale EIS scenario do not typically constitute major 

stationary sources and do not typically trigger PSD permits or review. However, a comparison of 

ambient concentrations from an accumulation of new oil and gas sources within the entire study area 

to PSD increments at specific Class I and Class II areas is included in this analysis for information 

purposes. This information is presented to aid State agencies in tracking the potential minor source 

increment consumption and to aid Federal Land Managers or Tribal governments responsible for 

protecting air resources in Class I areas.

H.7 AIR RESOURCE ASSESSMENT RESULTS

H.7.1 NAAQS Impacts

Future year CAMx modeling results were used to examine future air quality relative to the 

NAAQS and the individual contributions of each source group relative to the NAAQS. For the ozone 

and PM2.5 NAAQS, comparisons are presented both in terms of the “absolute” CAMx results and in 

terms of using the base case and future year CAMx results in a relative sense to scale the observed 

base (“current” or “base”) year design value (DVC or DVB) to obtain the projected future year design 

value (DVF) as recommended by the USEPA’s modeling guideline (USEPA, 2007 and 2014) and as 

described in Section H.6.2.2.

H.7.1.1 Ozone NAAQS Analysis using Relative Model Results

The USEPA’s Model Attainment Test Software (MATS) was used to make future year ozone 

DVF projections using the CAMx 2012 base case and future year scenario modeling results as 

described in Section H.6.2.2. The MATS was used to make DVF projections at the locations of 

ambient air monitoring sites as well as throughout the 4-km modeling domain using the MATS 

Unmonitored Area Analysis (UAA) procedures.

H.7.1.1.1 Monitored Ozone Design Value Projections using MATS

The MATS results for the future year ozone design values (DVFs) at individual ambient air 

monitoring sites in the 4-km domain are listed in Table H-17 andTable H-18. Updated MATS data 
Air Quality: Cumulative and Visibility Impacts H-81

files containing ozone design values up through 2014 were obtained from the USEPA.22 To make 

future year projections, MATS starts with a current year design value (DVC) that is based on an 

average of three ozone design values from the 5-year period centered on the base case modeling 

year, which was 2012 for this analysis. Thus, MATS DVCs are based on ozone design values from 

the 2010-2012, 2011-2013, and 2012-2014 periods. The MATS makes ozone DVF projections using 

the changes in daily maximum 8-hour ozone concentrations near (3 x 3 array of 4-km grid cells) a 

monitor using the ratio of future year to current year modeling results to scale the observed DVCs. 

These modeled derived scaling factors are called Relative Response Factors (RRFs; DVF = DVC x 

RRF). The RRFs are based on the 10 highest modeled ozone days above a threshold ozone 

concentration. A lower bound observed ozone threshold value of 50 ppb was used in MATS.

Of the 74 monitors with valid DVCs as calculated by MATS, 39 have DVCs exceeding the 

NAAQS (70 ppb). The DVFs are less than DVCs at all 74 sites. A total of 22 sites have predicted 

DVFs exceeding the MATS, all of which are among the sites with DVCs above the NAAQS. 

Contributions of each source group to the DVFs were calculated as the difference between 

the DVF calculated from the CAMx results with all sources included and a revised DVF calculated 

after first subtracting out the individual hourly contributions of each source group in the future year 

model run. These source group contributions are tabulated in Table H-18. The maximum 

contribution from Source Group A (new platforms associated with the 2017-2022 GOM Multisale EIS 

scenario) is 0.5 ppb. The maximum contribution from Source Group B (new platforms and support 

vessels and helicopters associated with this Multisale EIS scenario) is 5.1 ppb. 

Five sites in Texas and one in Louisiana were identified where the contribution of the new 

platforms and associated support vessels and aircraft under the 2017-2022 GOM Multisale EIS 

scenario (Source Group B) to the DVF was enough to push the DVF from just below the 70 ppb 

NAAQS (with Source Group B contributions removed) to just above the NAAQS when all sources 

were included (Table H-19). In each case, the “contribution” from Source Group B is less than 

5 ppb. At each of these sites, the DVCs are all also greater than 70 ppb as noted above. At the 

Galveston, Texas, monitor, the 0.3-ppb contribution of Source Group A (new platforms) alone was 

sufficient to bump the future year design value from just below the NAAQS to just above the NAAQS 

(recall comparisons to the 70 ppb NAAQS are made after truncating design values to the nearest 

ppb). 

For the ozone impacts assessment, please note that the states will not designate under the 

2015 ozone standard of 70 ppb until 2017, with the earliest attainment date of March 2021 for 

marginal areas. For this impacts assessment, the non-OCS source emissions were based on the 

USEPA’s 2017 emission projections, with a future modeled year of 2017 and compared to the 

70-ppb standard. This assessment is assuming the standard will be attained way before the actual 

 

22 https://www3.epa.gov/scram001/modelingapps_mats.htm
H-82 Gulf of Mexico Multisale EIS

attainment date, but it wanted to give maximum OCS oil and gas impacts under the new 70ppb 

ozone standard. 

Table H-17. Current Year (DVC) and Future Year (DVF) Ozone Design Values at Ambient Air Monitoring 

Sites within the 4-km Modeling Domain from MATS.

Site ID Site Name State County DVC DVF

10030010 FAIRHOPE HIGH SCHOOL, FAIRHOPE, 

ALABAMA AL Baldwin County 68 66.2

10970003 CHICKASAW, MOBILE CO., ALABAMA AL Mobile County 67.3 64.4

10972005 BAY RD. ,MOBILE AL. AL Mobile County 72 66.5

120330004 ELLYSON INDUSTRIAL PARK-COPTER 

ROAD FL Escambia County 67.7 65.1

120330018 NAS PENSACOLA FL Escambia County 70.7 68.1

120910002 720 Lovejoy Rd FL Okaloosa County 65 62.9

121130015 1500 WOODLAWN WAY FL Santa Rosa County 69.3 67.4

220050004 11153 Kling Road LA Ascension Parish 71.3 67.8

220190002 HIGHWAY 27 AND HIGHWAY 108 LA Calcasieu Parish 70.7 68.9

220190008 2646 John Stine Road LA Calcasieu Parish 66.7 64.7

220190009 2284 Paul Bellow Road LA Calcasieu Parish 70 67.3

220330003 EAST END OF ASTER LANE LA East Baton Rouge 

Parish 75.3 71.3

220330009 1061-A Leesville Ave LA East Baton Rouge 

Parish 72.3 68.3

220330013 11245 Port Hudson-Pride Rd. Zachary, La LA East Baton Rouge 

Parish 69 65.1

220470009 65180 Belleview Road LA Iberville Parish 70.3 64.6

220470012 HIGHWAY 171, CARVILLE LA Iberville Parish 73.3 68.6

220511001 West Temple Pl LA Jefferson Parish 71.3 68.4

220550007 646 Cajundome LA Lafayette Parish 69.7 67.2

220570004 Nicholls University Farm Highway 1 LA Lafourche Parish 71 65.7

220630002 Highway 16, French Settlement LA Livingston Parish 72.3 68.6

220710012 Corner of Florida Ave & Orleans Ave LA Orleans Parish 68.3 66.5

220770001 TED DAVIS RESIDENCE. HIGHWAY 415 LA Pointe Coupee Parish 74 68.2

220870004 4101 Mistrot Dr. Meraux, LA 70075 LA St. Bernard Parish 68 64.4

220890003 1 RIVER PARK DRIVE LA St. Charles Parish 67.7 65.2

220930002 ST. JAMES COURTHOUSE, HWY 44 @ 

CANAPELLA LA St. James Parish 66.3 62.7

220950002 Anthony F. Monica Street LA St. John the Baptist 

Parish 72 69.3

221030002 1421 Hwy 22 W, Madison Ville, LA 70447 LA St. Tammany Parish 72.3 68.7

221210001 1005 Northwest Drive, Port Allen LA West Baton Rouge 

Parish 68 63.8

280450003 400 Baltic St MS Hancock County 66.3 63.4

280470008 47 Maple Street MS Harrison County 70.3 67

280590006 Hospital Road at Co. Health Dept. MS Jackson County 71.3 69.2
Air Quality: Cumulative and Visibility Impacts H-83

Site ID Site Name State County DVC DVF

480271047 1605 Stone Tree Drive TX Bell County 73.7 71

80.3 78

68.7 66.3

480391004 4503 CROIX PKWY TX Brazoria County 85 81.9

480391016 109 B BRAZORIA HWY 332 WEST TX Brazoria County 69.3 66.8

480610006 344 PORTER DRIVE TX Cameron County 60.7 59.2

69.3 66.6

481671034 9511 AVENUE V 1⁄2 TX Galveston County 75.3 71.2

482010024 4510 1/2 ALDINE MAIL RD. TX Harris County 76.7 75.1

482010026 1405 SHELDON ROAD TX Harris County 73 71.2

482010029 16822 KITZMAN TX Harris County 80 76.3

482010046 7330 1/2 NORTH WAYSIDE TX Harris County 73.7 71.6

482010047 4401 1/2 LANG RD. TX Harris County 77 74.8

482010051 13826 1/2 CROQUET TX Harris County 78.7 76.3

482010055 6400 BISSONNET STREET TX Harris County 78.7 77.3

482010062 9726 1/2 MONROE TX Harris County 76.7 74.4

482010066 3333 1/2 HWY 6 SOUTH TX Harris County 77.7 75.2

482010070 5425 POLK AVE., SUITE H TX Harris County 75 73.5

482010416 7421 PARK PLACE BLVD TX Harris County 77.3 74.8

482011015 1001 B LYNCHBURG ROAD TX Harris County 71 68.5

482011034 1262 1/2 MAE DRIVE TX Harris County 78 76.1

482011035 9525 CLINTON DR TX Harris County 74.7 72.5

482011039 4514 1/2 DURANT ST. TX Harris County 78.3 75.5

482011050 4522 PARK RD. TX Harris County 76.3 74

482151048 325 Golf Course Road TX Hidalgo County 60 58.1

482450009 1086 Vermont Avenue TX Jefferson County 71.7 68.3

482450011 800 EL VISTA ROAD & 53RD STREET TX Jefferson County 74 70.5

482450022 12552 SECOND ST. TX Jefferson County 70.3 66.7

482450101 6019 MECHANIC TX Jefferson County 75 72.3

482450102 SETRPC 43 Jefferson Co Airport TX Jefferson County 67 64.4

482450628 UNAVAILABLE TX Jefferson County 69.3 66.4

482451035 Seattle Street TX Jefferson County 69.3 66.9

483091037 4472 MAZANEC RD TX McLennan County 71.7 69.1

483390078 9472 A HWY 1484 TX Montgomery County 78 74.7

483491051 Corsicana Airport TX Navarro County 70 68.2

483550025 CORPUS CHRISTI STATE SCHOOL, 

AIRPORT RD TX Nueces County 69.3 68.2

483550026 9860 LA BRANCH TX Nueces County 68.3 66.2

483611001 2700 AUSTIN AVE TX Orange County 69.3 66.5

483611100 INTERSECTION OF TX HWYS 62 AND 

12 TX Orange County 68 65.4

484530014 3724 NORTH HILLS DR, AUSTIN, TX 

78758 TX Travis County 71.3 67.7

484530020 12200 LIME CREEK RD. TX Travis County 71.7 68.3

484690003 106 MOCKINGBIRD LANE TX Victoria County 66.3 64.2
H-84 Gulf of Mexico Multisale EIS

Table H-18. Ozone Current (DVC) and Future Year (DVF) Design Values and Reduction in DVF with 

Contributions from Individual Source Groups Removed.

Site id State County DVC DVF

Change in DVF with Source Group 

Removed

A B C D E

10030010 AL Baldwin County 68 66.2 0.3 4.7 7.6 10.2 42.6

10970003 AL Mobile County 67.3 64.4 0.1 2.3 4.2 5.4 40.4

10972005 AL Mobile County 72 66.5 0.1 5.1 6.5 7.9 44.7

120330004 FL Escambia County 67.7 65.1 0.3 1.7 5.5 7.4 35.3

120330018 FL Escambia County 70.7 68.1 0.4 2.6 7.8 10.9 37.8

120910002 FL Okaloosa County 65 62.9 0.3 1.9 6.8 9.5 33.6

121130015 FL Santa Rosa County 69.3 67.4 0.5 2.6 9.3 12.7 37.5

220050004 LA Ascension Parish 71.3 67.8 0.1 0.7 2.3 3.1 43.6

220190002 LA Calcasieu Parish 70.7 68.9 0.3 2 5.6 8.3 40.2

220190008 LA Calcasieu Parish 66.7 64.7 0.3 1.7 4.9 7.4 37.6

220190009 LA Calcasieu Parish 70 67.3 0.2 1.5 4.2 6.1 39.7

220330003 LA East Baton Rouge Parish 75.3 71.3 0.1 0.7 2.9 4 45.3

220330009 LA East Baton Rouge Parish 72.3 68.3 0.1 0.7 2.6 3.7 43.3

220330013 LA East Baton Rouge Parish 69 65.1 0.2 1 3.2 4.3 37.7

220470009 LA Iberville Parish 70.3 64.6 0 0.2 0.7 1.1 41.2

220470012 LA Iberville Parish 73.3 68.6 0 0.4 1.5 2.3 45.7

220511001 LA Jefferson Parish 71.3 68.4 0.2 1.1 5.2 6.6 45

220550007 LA Lafayette Parish 69.7 67.2 0.1 1.4 3.9 5.6 41.5

220570004 LA Lafourche Parish 71 65.7 0.1 0.5 1.7 2.4 40.9

220630002 LA Livingston Parish 72.3 68.6 0.2 1.1 4.4 5.9 44.3

220710012 LA Orleans Parish 68.3 66.5 0.3 1.2 5.6 7.2 42

220770001 LA Pointe Coupee Parish 74 68.2 0 0.5 2 3 43.7

220870004 LA St. Bernard Parish 68 64.4 0.3 1.4 5.5 7.2 41.1

220890003 LA St. Charles Parish 67.7 65.2 0.1 0.6 2.5 3.3 44.7

220930002 LA St. James Parish 66.3 62.7 0.1 0.5 2.1 2.8 39.3

220950002 LA St. John the Baptist 

Parish 72 69.3 0.2 0.9 3.5 4.6 45

221030002 LA St. Tammany Parish 72.3 68.7 0.2 1.1 5 6.3 42.9

221210001 LA West Baton Rouge 

Parish 68 63.8 0 0.5 2.1 2.9 40

280450003 MS Hancock County 66.3 63.4 0.3 1.6 5.3 7.1 39.9

280470008 MS Harrison County 70.3 67 0.3 1.7 5.4 7.3 42.8

280590006 MS Jackson County 71.3 69.2 0.4 2.7 6 8.9 44.9

480271047 TX Bell County 73.7 71 0 0.3 0.9 1.2 30.9

80.3 78 0 0.3 0.9 1.3 37.4

68.7 66.3 0.1 0.2 0.4 0.5 33.3

480391004 TX Brazoria County 85 81.9 0.1 0.7 2.2 3.1 49.5

480391016 TX Brazoria County 69.3 66.8 0.2 1.3 3.4 4.8 37.4

480610006 TX Cameron County 60.7 59.2 0.2 1.3 2.4 3.3 29.2

69.3 66.6 0.1 0.2 0.3 0.5 29.9
Air Quality: Cumulative and Visibility Impacts H-85

Site id State County DVC DVF

Change in DVF with Source Group 

Removed

A B C D E

481671034 TX Galveston County 75.3 71.2 0.3 3.6 9.8 16.6 46.6

482010024 TX Harris County 76.7 75.1 0.2 1.5 4 5.8 44.1

482010026 TX Harris County 73 71.2 0.2 1.6 4.1 5.9 42.1

482010029 TX Harris County 80 76.3 0.2 1.1 3.3 4.8 48

482010046 TX Harris County 73.7 71.6 0.2 1.3 3.4 4.9 41.8

482010047 TX Harris County 77 74.8 0.2 1 3 4.4 46

482010051 TX Harris County 78.7 76.3 0.1 0.6 1.8 2.6 47.5

482010055 TX Harris County 78.7 77.3 0.1 0.8 2.4 3.3 46.9

482010062 TX Harris County 76.7 74.4 0.2 1.1 3.1 4.5 45.3

482010066 TX Harris County 77.7 75.2 0.1 0.7 2.2 3.1 46.6

482010070 TX Harris County 75 73.5 0.2 1.3 3.4 5 41.6

482010416 TX Harris County 77.3 74.8 0.1 1.2 3.1 4.6 44.4

482011015 TX Harris County 71 68.5 0.2 1.3 3.7 5.3 39.1

482011034 TX Harris County 78 76.1 0.3 1.7 4.1 5.9 44.3

482011035 TX Harris County 74.7 72.5 0.2 1.3 3.3 5 41.7

482011039 TX Harris County 78.3 75.5 0.2 1.3 3.4 5.1 42.8

482011050 TX Harris County 76.3 74 0.3 2.2 5.8 9.1 43.5

0.1 0.6 1.5 2.2 27.5

482151048 TX Hidalgo County 60 58.1 0.1 0.6 1.4 2 24.3

482450009 TX Jefferson County 71.7 68.3 0.1 0.7 2 2.9 42.2

482450011 TX Jefferson County 74 70.5 0.2 1.9 4.9 7.2 43.9

482450022 TX Jefferson County 70.3 66.7 0.1 0.8 2.4 3.5 40.3

482450101 TX Jefferson County 75 72.3 0.3 3 8.2 12.4 45.9

482450102 TX Jefferson County 67 64.4 0.2 1.3 4.1 6 40

482450628 TX Jefferson County 69.3 66.4 0.2 2 5.3 7.8 41.8

482451035 TX Jefferson County 69.3 66.9 0.2 1.5 4.5 6.7 41.9

483091037 TX McLennan County 71.7 69.1 0 0.2 0.5 0.7 31.3

483390078 TX Montgomery County 78 74.7 0.2 1 3.1 4.5 45.8

483491051 TX Navarro County 70 68.2 0.1 0.2 0.6 0.8 33.5

483550025 TX Nueces County 69.3 68.2 0.3 1.9 5.4 7.4 35

483550026 TX Nueces County 68.3 66.2 0.3 1.3 3.6 4.9 32.7

483611001 TX Orange County 69.3 66.5 0.1 1.4 4.8 6.9 41.3

483611100 TX Orange County 68 65.4 0.1 1.5 4.6 6.9 40

484530014 TX Travis County 71.3 67.7 0 0.2 0.9 1.3 37.5

484530020 TX Travis County 71.7 68.3 0.1 0.3 1 1.4 35.8

484690003 TX Victoria County 66.3 64.2 0.2 1 3 4.2 32.6
H-86 Gulf of Mexico Multisale EIS

Table H-19. MATS Ozone Design Value Results for All Monitoring Sites Where Exclusion of 

Contributions from Source Group A or B is Sufficient to Reduce the Predicted Future Design 

Value (DVF) from Above the NAAQS to Below the NAAQS (all values in ppb).

Site ID Location State DVC1 DVF2 DVF_A3 DVF –

DVF_A DVF_B3 DVF –DVF_B

220330003 East Baton 

Rouge Parish LA 75.3 71.3 71.2 0.1 70.6 0.7

480271047 Bell County TX 73.7 71.0 71.0 0.0 70.7 0.3

481671034 Galveston TX 75.3 71.2 70.9 0.3 69.1 4.9

482010026 Houston TX 73 71.2 71.0 0.2 69.6 1.6

482010046 Houston TX 73.7 71.6 71.4 0.2 70.3 1.3

482450101 Port Arthur TX 75 72.3 72.0 0.3 69.3 3.0

1 The MATS base period ozone design value (ppb) representing combined contributions of all sources.

2 The MATS future year ozone design value (ppb) representing combined contributions of all sources. 3 The MATS future year ozone design value (ppb) calculated after removing source apportionment 

contributions of Source Group A or B. 

Figure H-40 displays the MATS Unmonitored Area Analysis (UAA) results, which were 

generated using the observed ozone data in MATS and the base year and future year scenario 

CAMx results. The MATS UAA spatially interpolates the DVCs obtained from observations across 

the modeling domain and then calculates the DVF for each model grid cell by multiplying the 

interpolated DVC by the RRF value (i.e., the ratio of the modeled future year to base year design 

values) in each grid cell. Future year design values calculated using the MATS UAA procedure are 

lower than base year design values throughout most of the 4-km modeling domain with the 

exception of a maximum 1.6-ppb increase of less than 3 ppb off the Louisiana coast. 
Air Quality: Cumulative and Visibility Impacts H-87

Figure H-40. Base Scenario Ozone Design Values (DVC, top left), Future Year Ozone Design Values 

(DVF, top right) and Their Differences (DVF – DVC; bottom) Calculated Using the MATS 

UAA Tool.

H.7.1.1.2 Ozone MATS Unmonitored Area Analysis

The MATS UAA DVF values calculated after first removing the hourly contributions from 

Source Groups A (new platforms), B (new platforms and associated support vessels and aircraft), 

and D (all Gulf of Mexico sources) are shown in the left column of Figure H-41. The contributions of 

Source Groups A, B, and D calculated as the difference between these DVF values and the DVF 

values from all sources (as shown in the upper right-hand corner of Figure H-40) are shown in the 

right column of Figure H-41. Source Group A contributions are centered in the Gulf of Mexico 

offshore of Louisiana, with a peak impact of 2.2 ppb; maximum impacts from the State seaward 

boundaries inland are in the 1- to 1.2-ppb range along the coast of Cameron Parish. For Source 

Group B, the maximum contribution (10.8 ppb) is in approximately the same location, but the support 

vessel and helicopter activities result in greater impacts landward of the State seaward boundary, 

with maximum contributions in the 6- to 7-ppb range. 
H-88 Gulf of Mexico Multisale EIS

Source 

Group1

DVF with Source Group Contribution 

Removed Source Group Contribution2

A 

B 

D 

1 As defined in Table H-14. 2 Source group contributions are calculated by subtracting the DVF values calculated after removing 

the hourly source group contributions from the DVF values calculated when all sources are 

included. 

Figure H-41. MATS UAA Future Year Ozone Design Values (DFV) Calculated After First Removing the 

Hourly Contributions from a Source Group (left column) and the Corresponding 

Contributions of the Source Group to DVF (right column) Calculated by Subtracting the 

DVFs Shown in the Left-hand Column from the “All Sources” DVF Shown in the Top 

Right-hand Corner of Figure H-40. Top row – source group B; middle row – source 

group D. 
Air Quality: Cumulative and Visibility Impacts H-89

H.7.1.2 Ozone NAAQS Analysis Using Absolute Modeling Results

The CAMx source apportionment absolute modeling results from the future year scenario are 

analyzed and compared with the ozone NAAQS in this section. The ozone NAAQS is defined as the 

3-year average of the 4th highest maximum daily average 8-hour (MDA8) ozone concentration. Since 

only one calendar year of modeling results are available for the base year and future year scenarios, 

the future year 4th highest MDA8 ozone concentration is used as a pseudo-NAAQS comparison 

metric. 

Modeled 4th highest MDA8 values in each model grid cell for the base and future year 

scenarios and the corresponding differences are shown in Figure H-42. Similar to the MATS results 

presented in Figure H-40, the 4th highest MDA8 is lower under the future year scenario throughout 

most of the 4-km domain, with isolated areas of increases of less than 4 ppb located off the coasts of 

Louisiana and Texas and onshore in Cameron Parish, Louisiana. 

Figure H-42. Modeled 4th Highest MDA8 Ozone for the Base Year (upper left) and Future Year (upper 

right) Scenarios and Their Differences (bottom center). 
H-90 Gulf of Mexico Multisale EIS

Contributions of each source group to the all sources future year 4th highest MDA8 values 

shown in the upper right-hand panel of Figure H-42 are shown in Figure H-43 and Figure H-44. 

These contributions are matched in time to the all sources 4th highest MDA8 values; contributions 

may be different during other periods with elevated MDA8 values. As shown in Figure H-43, new 

platform sources under the 2017-2022 GOM Multisale EIS scenario (Source Group A) are estimated 

to contribute as much as 7.4 ppb to design values out over the Gulf of Mexico. Within the states out 

to the State Seaward Boundary (SSB), the contributions range from near zero to approximately 3

ppb, with the maximum contributions occurring along the coast of Cameron Parish, Louisiana. 

Contributions increase by about 10 ppb when contributions from support vessels and helicopters 

associated with the 2017-2022 GOM Multisale EIS scenario are added in (Source Group B). Also, 

adding in all existing platforms and support vessels and helicopters (Source Group C) raises the 

maximum contribution out over the Gulf of Mexico to nearly 38 ppb. Contributions landward of the 

SSB are generally below 15 ppb but with some areas along the Louisiana coast reaching maximum 

contributions up to 35 ppb. Adding in all other marine vessel activity in the Gulf of Mexico (Source 

Group D) only increases the contributions by a few ppb. The addition of land-based and Mexican 

and Canadian anthropogenic sources (Source Group E) results in source contributions that are 

typically about 30 ppb higher than the contributions from Gulf of Mexico sources alone (Source 

Group D). Contributions over the land areas are higher than for Source Group D although the 

highest contributions remain out over the Gulf of Mexico where biogenic emissions have minimal 

influence. In other words, to the extent that elevated ozone levels are predicted over the Gulf of 

Mexico, they are nearly entirely attributable to anthropogenic sources. 

Contributions from natural sources (including biogenics and fires) and non-U.S. emissions, 

including 12-km domain boundary conditions (Source Group F), are shown in the left panel of Figure

H-44; contributions from just the boundary conditions (BCs) are shown in the right panel. These 

results show an area south of Galveston where ozone design values were almost entirely driven by 

U.S. or Mexican anthropogenic BCs; however, over the rest of the Gulf of Mexico, including the near 

coastal areas, contributions are generally between 20 and 30 ppb and are overwhelmingly 

attributable to the BCs. Higher contributions are seen inland where biogenic sources play a larger 

role in ozone formation.
Air Quality: Cumulative and Visibility Impacts H-91

Figure H-43. Contributions of Source Groups A (top left), B (top right), C (middle left), D (middle right), 

and E (bottom) to Future Year All-sources 4th Highest MDA8 (note different color scales in 

each panel).
H-92 Gulf of Mexico Multisale EIS

Figure H-44. Contributions from (left) Source Group F (natural and non-US emission sources 

including boundary conditions) and (right) Boundary Conditions Only, to Future 

Year All-sources 4th Highest MDA8. 

H.7.1.3 PM2.5 NAAQS Analysis using Relative Model Results

There are two PM2.5 NAAQS, one for 24-hour averaging time that is expressed as a 3-year 

average of the annual 98th percentile in a year with a threshold of 35 μg/m3 and an annual average 

over 3 years with a threshold of 12 μg/m3

. With 1 year of complete everyday modeling, the annual 

98th percentile will correspond to the 8th highest 24-hour PM2.5 concentration in a year. 

Predictions of future year 24-hour and annual average PM2.5 design values were made 

based on the use of model results in a relative sense as was done for ozone design values in 

Section H.7.1.1. The MATS software was used to generate predicted future year design values 

(DVFs) from current (base year) design values (DVB or DVC). The MATS was configured to use 

ambient measurements of total PM2.5 for the period 2008-2012 to generate DVCs based on an 

average of three overlapping 3-year average DVs as recommended in the USEPA’s guidance 

(USEPA, 2014) and speciated PM2.5 monitoring data for the period 2010-2012 to generate the 

projected DVFs based on model predicted species RRFs. 

H.7.1.3.1 24-Hour PM2.5

As described for the ozone NAAQS analysis in Section H.7.1.1, the MATS was used to 

calculate DVFs for the 24-hour and annual PM2.5 NAAQS. Observational data for use in the MATS 

were provided by the USEPA23 for use in calculating the DVCs. For total PM2.5, observational data 

covered the period 2008-2012; for the speciated PM2.5 calculations, observational data covered the 

period 2010-2012. 

 

23 https://www3.epa.gov/scram001/modelingapps_mats.htm
Air Quality: Cumulative and Visibility Impacts H-93

Results of the MATS analysis are shown in Table H-20. All current and future year design 

values are below the 35 μg/m3 NAAQS, and the future year design values are projected to be lower 

than the current year design values at all sites. The reductions in the projected DVFs calculated 

after removing source contributions from each Source Group A, B, C, D, and E (i.e., DVF from Table

H-20 minus DVF calculated with hourly source group contributions removed) are listed in Table

H-21. The largest of the Source Group A, B, C, or D contributions calculated in this manner occur at 

the Bay Rd. monitor in Mobile County, Alabama. New platforms and associated support vessels 

and helicopters (Source Group B) are calculated to contribute 1.2 μg/m3 or 6.4% of the 18.9 μg/m3

DVF at this location. 

Table H-20. Current Year (DVC) and Future Year (DVF) 24-Hour PM2.5 Design Values for Monitoring 

Sites in the 4-km Modeling Domain from MATS.

Site ID Site Name State County DVC DVF 

10030010 FAIRHOPE HIGH SCHOOL, FAIRHOPE, 

ALABAMA AL Baldwin County 19.5 17.7

10970003 CHICKASAW, MOBILE CO., ALABAMA AL Mobile County 19.1 17.2

10972005 BAY RD., MOBILE AL. AL Mobile County 20 18.9

120330004 ELLYSON INDUSTRIAL PARK-COPTER 

ROAD FL Escambia County 19.2 17.6

220190009 2284 Paul Bellow Road LA Calcasieu Parish 18.6 17

220190010 Common and East McNeese LA Calcasieu Parish 20.5 18.4

220330009 1061-A Leesville Ave LA East Baton Rouge 

Parish 21 19.2

220331001 Highway 964 LA East Baton Rouge 

Parish 16.7 14.2

220470005 St Gabriel Agricultural Exp. Station LA Iberville Parish 21 19.9

220470009 65180 Belleview Road LA Iberville Parish 18.6 17.5

220511001 West Temple Pl LA Jefferson Parish 18.7 17.1

220512001 Patriot St. and Allo St. LA Jefferson Parish 18.5 16.6

220550006 121 East Point Des Mouton LA Lafayette Parish 18.8 17.5

220550007 646 Cajundome LA Lafayette Parish 20.2 18.1

220790002 8105 Tom Bowman Drive LA Rapides Parish 19.6 17.7

220870007 24 E. CHALMETTE CIRCLE LA St. Bernard Parish 20.2 17.4

221050001 21549 Old Hammond Hwy, Hammond, LA 

70403 LA Tangipahoa Parish 18.8 17.2

221090001 4047 Highway 24 North Gray LA Terrebonne Parish 17.6 16.2

221210001 1005 Northwest Drive, Port Allen LA West Baton Rouge 

Parish 21.7 20.2

280010004 Natchez Municipal Water Works,

Brenham St. MS Adams County 20.3 17.7

280350004 205 Bay Street MS Forrest County 22.4 21

280450003 400 Baltic St. MS Hancock County 20 18.3

280470008 47 Maple Street MS Harrison County 18.3 16

280590006 Hospital Road at Co. Health Dept. MS Jackson County 20.8 19.6

280670002 26 Mason St. MS Jones County 23 21.7
H-94 Gulf of Mexico Multisale EIS

Site ID Site Name State County DVC DVF 

480290059 14620 LAGUNA RD. TX Bexar County 21.4 20.9

480612004 LOT B 69 1⁄2 TX Cameron County 22.7 22.4

482010058 7210 1/2 BAYWAY DRIVE TX Harris County 20.8 20.2

482011035 9525 CLINTON DR TX Harris County 24 22.7

483550032 3810 HUISACHE STREET TX Nueces County 24.3 23.3

484530020 12200 LIME CREEK RD. TX Travis County 20.7 19.1

484530021 2600 B WEBBERVILLE RD. TX Travis County 21.8 20.5

Table H-21. 24-Hour PM2.5 Current (DVC) and Future Year (DVF) Design Values and Reduction in DVF 

with Contributions from Individual Source Groups Removed. 

Site ID State County DVC DVF

Change in DVF with Source Group 

Removed

A B C D E

10030010 AL Baldwin County 19.5 17.7 0.0 0.2 0.3 0.4 8.8

10970003 AL Mobile County 19.1 17.2 0.0 0.1 0.1 0.2 10.2

10972005 AL Mobile County 20 18.9 0.0 1.2 1.2 1.3 12.0

120330004 FL Escambia County 19.2 17.6 0.0 0.0 0.1 0.1 9.2

220190009 LA Calcasieu Parish 18.6 17 0.0 0.1 0.2 0.5 9.9

220190010 LA Calcasieu Parish 20.5 18.4 0.0 0.0 0.1 0.3 12.1

220330009 LA East Baton Rouge 

Parish 21 19.2 0.0 0.1 0.2 0.3 12.3

220331001 LA East Baton Rouge 

Parish 16.7 14.2 0.0 0.1 0.2 0.4 9.1

220470005 LA Iberville Parish 21 19.9 0.0 0.0 0.2 0.4 14.2

220470009 LA Iberville Parish 18.6 17.5 0.0 0.0 0.1 0.3 10.2

220511001 LA Jefferson Parish 18.7 17.1 0.0 0.0 0.2 0.3 12.0

220512001 LA Jefferson Parish 18.5 16.6 0.0 0.1 0.2 0.4 13.1

220550006 LA Lafayette Parish 18.8 17.5 0.1 0.2 0.5 1.0 12.1

220550007 LA Lafayette Parish 20.2 18.1 0.0 0.0 0.2 0.3 12.3

220790002 LA Rapides Parish 19.6 17.7 0.0 0.0 0.2 0.4 8.1

220870007 LA St. Bernard Parish 20.2 17.4 0.0 0.0 0.2 0.4 12.0

221050001 LA Tangipahoa Parish 18.8 17.2 0.1 0.1 0.3 0.5 9.1

221090001 LA Terrebonne Parish 17.6 16.2 0.0 0.1 0.3 0.4 10.8

221210001 LA West Baton Rouge 

Parish 21.7 20.2 0.0 0.0 0.2 0.3 13.8

280010004 MS Adams County 20.3 17.7 0.0 0.1 0.1 0.2 7.8

280350004 MS Forrest County 22.4 21 0.0 0.1 0.1 0.2 11.4

280450003 MS Hancock County 20 18.3 0.0 0.1 0.6 1.1 11.4

280470008 MS Harrison County 18.3 16 0.0 0.0 0.3 0.4 8.8

280590006 MS Jackson County 20.8 19.6 0.1 0.1 0.4 1.1 14.3

280670002 MS Jones County 23 21.7 0.0 0.1 0.1 0.1 11.0

480290059 TX Bexar County 21.4 20.9 0.0 0.0 0.0 0.0 11.8

480612004 TX Cameron County 22.7 22.4 0.0 0.7 0.7 0.8 5.4

482010058 TX Harris County 20.8 20.2 0.0 0.0 0.2 0.5 13.1
Air Quality: Cumulative and Visibility Impacts H-95

Site ID State County DVC DVF

Change in DVF with Source Group 

Removed

A B C D E

482011035 TX Harris County 24 22.7 0.0 0.0 0.1 0.2 14.9

483550032 TX Nueces County 24.3 23.3 0.0 0.1 0.1 0.2 12.3

484530020 TX Travis County 20.7 19.1 0.0 0.0 0.0 0.1 9.4

484530021 TX Travis County 21.8 20.5 0.0 0.0 0.0 0.1 12.1

H.7.1.3.2 Annual Average PM2.5

The MATS projections of DVF for the annual average PM2.5 design values are shown in 

Table H-22. The only design value exceeding the 12 μg/m3 annual average NAAQS is the current 

year design value at the Clinton Dr. monitor in Houston, Texas. The projected future year design 

value at this location is below the NAAQS. Future year design values are projected to be less than 

the current year design values at all monitoring sites except for a 0.3 μg/m3 increase at the Hidalgo 

County monitoring site just west of Brownsville, Texas. 

Reductions in the projected annual average DVFs calculated after removing source 

contributions from each Source Group A, B, C, D, and E (i.e., DVF from Table H-22 minus DVF 

calculated with hourly source group contributions removed) are shown in Table H-23. The largest of 

the Source Group A, B, C, or D contributions calculated in this manner occur at the Bay Rd. monitor 

in Mobile County, Alabama. New platforms and associated support vessels and helicopters (Source 

Group B) are calculated to contribute 0.7 μg/m3 or 7.7% of the 9.1 μg/m3 DVF at this location. 

Source Group B contributions at the Clinton Dr. monitor are calculated to be less than 0.05 μg/m3

. 

Source Group B contributions at the Hidalgo County monitoring site are calculated to be 0.1 μg/m3

. 

Table H-22. Current (DVC) and Projected Future (DVF) Annual Average PM2.5 Design Values for 

Monitoring Sites in the 4-km Modeling Domain (highlighted values exceed the 12 μg/m3

NAAQS). 

Site ID Site Name State DVC DVF 

10030010 FAIRHOPE HIGH SCHOOL, FAIRHOPE, ALABAMA AL 9.8 9.1

10970003 CHICKASAW, MOBILE CO., ALABAMA AL 9.7 8.9

10972005 BAY RD., MOBILE AL. AL 9.2 9.1

120330004 ELLYSON INDUSTRIAL PARK-COPTER ROAD FL 8.9 8.3

220190009 2284 Paul Bellow Road LA 8.6 7.9

220190010 Common and East McNeese LA 9.1 8.5

220330009 1061-A Leesville Ave LA 10.3 9.6

220331001 Highway 964 LA 9.3 8.3

220470005 St Gabriel Agricultural Exp. Station LA 10.2 9.5

220470009 65180 Belleview Road LA 8.9 8.1

220511001 West Temple Pl LA 9 8.2

220512001 Patriot St. and Allo St. LA 9.2 8.3

220550006 121 East Point Des Mouton LA 8.9 8.2

220550007 646 Cajundome LA 9.1 8.4

220790002 8105 Tom Bowman Drive LA 8.8 8
H-96 Gulf of Mexico Multisale EIS

Site ID Site Name State DVC DVF 

220870007 24 E. CHALMETTE CIRCLE LA 10.5 9.7

221050001 21549 Old Hammond Hwy, Hammond, LA 70403 LA 9 8.1

221090001 4047 Highway 24 North Gray LA 8.5 7.8

221210001 1005 Northwest Drive, Port Allen LA 10.8 10.1

280010004 Natchez Municipal Water Works Brenham St MS 10.2 9.3

280350004 205 Bay Street MS 11.7 10.9

280450003 400 Baltic St MS 9.9 9.1

280470008 47 Maple Street MS 9.6 8.7

280590006 Hospital Road at Co. Health Dept. MS 9.5 9

280670002 26 Mason St. MS 11.8 11.3

480290059 14620 LAGUNA RD. TX 9 8.8

480612004 LOT B 69 1⁄2 TX 11 10.9

482010058 7210 1/2 BAYWAY DRIVE TX 11.1 10.9

482011035 9525 CLINTON DR TX 12.4 11.6

482150043 2300 NORTH GLASSCOCK TX 10.4 10.7

483550032 3810 HUISACHE STREET TX 10.3 10

484530020 12200 LIME CREEK RD. TX 8.4 7.9

484530021 2600 B WEBBERVILLE RD. TX 10.2 9.8

Table H-23. Annual Average PM2.5 Future Year Design Values (DVF) and Change in DVF with 

Contributions from Individual Source Groups Removed (highlighted values exceed the 

12 μg/m3 NAAQS). 

Site ID State County DVC DVF 

Change in DVF with Source Group 

Removed

A B C D E

10030010 AL Baldwin County 9.8 9.1 0.0 0.1 0.2 0.3 5.5

10970003 AL Mobile County 9.7 8.9 0.0 0.1 0.1 0.2 6.2

10972005 AL Mobile County 9.2 9.1 0.0 0.7 0.8 0.9 6.1

120330004 FL Escambia County 8.9 8.3 0.0 0.1 0.1 0.2 5.2

220190009 LA Calcasieu Parish 8.6 7.9 0.0 0.1 0.2 0.4 5.0

220190010 LA Calcasieu Parish 9.1 8.5 0.0 0.0 0.2 0.4 6.3

220330009 LA East Baton Rouge 

Parish 10.3 9.6 0.0 0.1 0.2 0.3 7.2

220331001 LA East Baton Rouge 

Parish 9.3 8.3 0.0 0.0 0.1 0.2 6.0

220470005 LA Iberville Parish 10.2 9.5 0.0 0.0 0.1 0.2 7.4

220470009 LA Iberville Parish 8.9 8.1 0.0 0.0 0.1 0.3 5.5

220511001 LA Jefferson Parish 9 8.2 0.0 0.1 0.2 0.3 6.0

220512001 LA Jefferson Parish 9.2 8.3 0.0 0.0 0.1 0.2 6.6

220550006 LA Lafayette Parish 8.9 8.2 0.0 0.0 0.2 0.4 5.9

220550007 LA Lafayette Parish 9.1 8.4 0.0 0.1 0.2 0.4 6.1

220790002 LA Rapides Parish 8.8 8 0.0 0.0 0.1 0.2 4.7

220870007 LA St. Bernard Parish 10.5 9.7 0.0 0.1 0.2 0.3 7.3

221050001 LA Tangipahoa Parish 9 8.1 0.0 0.1 0.2 0.3 5.0

221090001 LA Terrebonne Parish 8.5 7.8 0.0 0.0 0.2 0.4 5.5
Air Quality: Cumulative and Visibility Impacts H-97

Site ID State County DVC DVF 

Change in DVF with Source Group 

Removed

A B C D E

221210001 LA West Baton Rouge 

Parish 10.8 10.1 0.0 0.0 0.1 0.2 7.9

280010004 MS Adams County 10.2 9.3 0.0 0.0 0.1 0.2 5.4

280350004 MS Forrest County 11.7 10.9 0.0 0.0 0.1 0.2 7.2

280450003 MS Hancock County 9.9 9.1 0.0 0.0 0.2 0.4 6.1

280470008 MS Harrison County 9.6 8.7 0.0 0.0 0.2 0.3 5.6

280590006 MS Jackson County 9.5 9 0.0 0.1 0.2 0.3 6.9

280670002 MS Jones County 11.8 11.3 0.0 0.0 0.1 0.1 7.4

480290059 TX Bexar County 9 8.8 0.0 0.0 0.1 0.1 5.0

480612004 TX Cameron County 11 10.9 0.0 0.3 0.4 0.5 4.9

482010058 TX Harris County 11.1 10.9 0.0 0.0 0.1 0.3 8.0

482011035 TX Harris County 12.4 11.6 0.0 0.0 0.0 0.2 8.8

482150043 TX Hidalgo County 10.4 10.7 0.0 0.1 0.1 0.1 6.4

483550032 TX Nueces County 10.3 10 0.0 0.0 0.1 0.1 6.0

484530020 TX Travis County 8.4 7.9 0.0 0.0 0.0 0.1 4.4

484530021 TX Travis County 10.2 9.8 0.0 0.0 0.0 0.1 6.1

Figure H-43 displays the MATS UAA results for the annual average PM2.5 DVC, DVF, and 

the difference, DVF - DVC.24 Reductions in annual average PM2.5 design values associated with 

emission reductions from all sources combined are projected throughout nearly the entire domain, 

with the exception of increases near the Freshwater Bayou Canal in Vermilion Parish, Louisiana,

and Brownsville, Texas, in addition to a few additional areas in Texas and southern Louisiana. 

Some of the isolated areas of increases may represent artifacts of the MATS UAA spatial 

interpolation procedure and are not necessarily physically meaningful. Increases in the coastal ports 

are associated with new platforms and support vessel and helicopter traffic (Source Group B), as 

shown by the unmonitored area source group contributions in Figure H-46. Source Group B 

contributes as much as 1.8 μg/m3 in these areas. 

 

24 The UAA analysis could only be performed for the annual average PM2.5 NAAQS as the MATS 

software cannot calculate UAA results for the 24-hour average PM2.5 NAAQS.
H-98 Gulf of Mexico Multisale EIS

Figure H-45. Current Year (DVC) and Future Year (DVF) Annual Average PM2.5 Design Values from 

the MATS Unmonitored Area Analysis (top left and top right, respectively) and the 

Difference, DVF – DVC (bottom).
Air Quality: Cumulative and Visibility Impacts H-99

Figure H-46. Contributions of Source Groups A (top left), B (top right), C (middle left), D (middle right), 

and E (bottom) to the Future Year All-sources Annual Average PM2.5 Concentration Based 

on the MATS Unmonitored Area Analysis (note different color scales used in each panel). 

H.7.1.4 PM2.5 NAAQS Analysis using Absolute Model Predictions

The CAMx source apportionment absolute modeling results from the future year scenario are 

analyzed and compared with the PM2.5 24-hour and annual NAAQS in this section. 
H-100 Gulf of Mexico Multisale EIS

H.7.1.4.1 24-Hour PM2.5

The 24-hour PM2.5 NAAQS is defined as the three-year average of the annual 98th percentile 

daily average which corresponds to the 8th highest daily average in each year assuming complete 

data. Since only one calendar year of modeling results are available for the base year and future 

year scenarios, the future year 8th highest daily average PM2.5 concentration is selected for 

comparison with the NAAQS. 

Modeled 8th highest daily PM2.5 concentrations in each model grid cell for the base and future 

year scenarios and the corresponding differences are shown in Figure H-47. Areas of high 

predicted PM2.5 occur along the Alabama, Louisiana and east Texas Gulf coasts in both the base 

and future year scenarios. Although predicted 8th highest daily PM2.5 concentrations in these areas 

exceed the 35 μg/m3 NAAQS, both base-year monitored design values (DVCs) and projected future 

year design values (DVFs) are below the NAAQS at monitoring sites in these areas as noted in 

Section H.7.1.3.1 above. A tendency towards over prediction of daily PM2.5 noted in the model 

performance evaluation results presented in Section H.5. The difference plot at the bottom of 

Figure H-47 shows PM2.5 reductions in the majority of the domain with some areas of increases in 

PM2.5 along portions of the immediate shoreline and offshore in the western Gulf where additional 

activities are anticipated under the 2017-2022 GOM Multisale EIS scenario. Where PM2.5 increases 

are predicted, they are limited to less than 15 μg/m3 for nearly all grid cells. 

Source group contributions to the annual 8th highest daily average PM2.5 concentrations 

under the future year scenario are shown in Figure H-48. These contributions are matched in time 

to the all sources 8th highest daily average PM2.5 concentrations; contributions may be different 

during other periods with elevated daily average PM2.5 values. Impacts of the new sources 

associated with the 2017-2022 GOM Multisale EIS scenario (Source Groups A and B) are largely 

focused on the area offshore of western Louisiana. Impacts from new platforms associated with the 

2017-2022 GOM Multisale EIS scenario (Source Group A) are less than 1 μg/m3

; adding in support 

vessels and helicopters (Source Group B) increases the near-shore impacts up to a maximum of 

7 μg/m3 as compared to a combined maximum impact of all Gulf of Mexico sources (Source 

Group D) of 44 μg/m3

. 

Contributions from Source Group E, which includes Source Group D plus all other U.S. and 

non-U.S. anthropogenic sources, shows the influence of inland urban areas on PM2.5 levels, 

especially in Baton Rouge and Lake Charles, Louisiana.

Contributions from Source Group F (natural and non-U.S. emission sources including 

boundary conditions) shown in the left panel of Figure H-49 are dominated by fire emissions near 

Beaumont, Texas, and in Vermilion and Lafourche Parishes, Louisiana. Boundary condition 

contributions are less than 4 μg/m3 in the coastal areas as shown in the right panel of Figure H-49. 
Air Quality: Cumulative and Visibility Impacts H-101

Figure H-47. Modeled 8th Highest Daily Average PM2.5 Concentrations for the Base Year (top left), 

Future Year (top right), and the Future – Base Difference (bottom). 
H-102 Gulf of Mexico Multisale EIS

Figure H-48. Contributions of Source Groups A (top left), B (top right), C (middle left), D (middle right), 

and E (bottom) to the Future Year All-sources 8th Highest Daily Average PM2.5

Concentration (note different color scales used in each panel). 
Air Quality: Cumulative and Visibility Impacts H-103

Figure H-49. Contributions from (left) Source Group F (natural and non-U.S. emission sources including 

boundary conditions) and (right) Boundary Conditions Only to Future Year All-sources 

8th Highest 24-hour PM2.5 (note use of different color scale in each panel).

7.1.4.2 Annual Average PM2.5

Modeled annual average PM2.5 for the base year, future year, and the future – base 

differences are shown in Figure H-50. Average PM2.5 concentrations decrease on most locations 

between the base and future year scenarios with changes over the western GOM between ± 

0.5 μg/m3

. Increases of up to 2.5 μg/m3 are calculated to occur in coastal Vermilion Parish, 

Louisiana. 

Source group contributions to the annual average PM2.5 concentrations under the future year 

scenario are shown in Figure H-51. Impacts of the new sources associated with the 2017-2022 

GOM Multisale EIS scenario (Source Group B) are largely focused on the area offshore of western 

Louisiana with a maximum impact of 2.2 μg/m3 as compared to a combined maximum impact of all 

GOM sources (Source Group D) of 9.3 μg/m3

. Source Group F contributions (natural and non-U.S.

emission sources including boundary conditions) shown in the left panel of Figure H-52 are 

dominated by fire emissions near Beaumont, Texas, and in Vermilion and Lafourche Parishes, 

Louisiana. Boundary condition contributions are less than 2 μg/m3 in the coastal areas as shown in 

the right panel of Figure H-52. 
H-104 Gulf of Mexico Multisale EIS

Figure H-50. Modeled Annual Average PM2.5 Concentrations for the Base Year (top left), Future Year 

(top right), and the Future – Base Difference (bottom). 
Air Quality: Cumulative and Visibility Impacts H-105

Figure H-51. Contributions of Source Group A (top left), B (top right), C (middle left), D (middle right), 

and E (bottom) to the Future Year All-sources Annual Average PM2.5 Concentration (note 

use of different color scales in each panel).
H-106 Gulf of Mexico Multisale EIS

Figure H-52. Contributions from (left) Source Group F (natural and non-U.S. emission sources including 

boundary conditions) and (right) Boundary Conditions Only to Future Year All-sources 

Annual Average PM2.5 (note use of different color scale in each panel).

H.7.1.5 NAAQS Analysis for other Criteria Air Pollutants

H.7.1.5.1 PM10

Figure H-53 displays modeled 2nd highest daily average PM10 concentrations than can be 

compared with the 24-hour average PM10 NAAQS (150 μg/m3

) for the base and future scenarios and 

the base-future differences. Areas of elevated PM10 are evident in urban and port areas and in fire 

zones along the Gulf Coasts of Texas and Louisiana (impacts of fires on PM10 can be discerned 

from the left panel of Figure H-55 described below). The PM10 decreases are modeled along the 

Louisiana coast with increases of between 2 and 5 μg/m3 in waters farther offshore associated with 

new emissions from the 2017-2022 GOM Multisale EIS scenario sources. 

Source group contributions to the 2nd highest daily average PM10 concentrations are shown 

in Figure H-54. The maximum contribution of the new platforms and associated support vessels 

and aircraft under the 2017-2022 GOM Multisale EIS scenario (Source Group B) is predicted to be 

10.7 μg/m3 or 7% of the NAAQS. The maximum contribution of all oil and gas platforms and support 

vessels and helicopters (Source Group C) is 41 μg/m3 (28% of the NAAQS). Fires dominate 

contributions from natural and non-U.S. sources (Figure H-55).
Air Quality: Cumulative and Visibility Impacts H-107

Figure H-53. Modeled 2nd Highest 24-hour Average PM10 Concentrations for the Base Year (top left), 

Future Year (top right), and the Future – Base Difference (bottom). 
H-108 Gulf of Mexico Multisale EIS

Figure H-54. Contributions of Source Groups A (top left), B (top right), C (middle left), D (middle right), 

and E (bottom) to the Future Year All-sources 2nd Highest Daily Average PM10

Concentration (note use of different color scales in each panel).
Air Quality: Cumulative and Visibility Impacts H-109

Figure H-55. Contributions from (left) Source Group F (natural and non-U.S. emission sources including 

boundary conditions) and (right) Boundary Conditions Only to Future Year All-sources 

2nd Highest Daily Average PM10 Concentration (note use of different color scale in each 

panel).

H.7.1.5.2 NO2

Results are presented here for both the 1-hour average NO2 NAAQS (100 ppb) and the 

annual average NO2 NAAQS (53 ppb). Figure H-56 and Figure H-57 display modeled 1-hour 

average NO2 design values (based on the 8th highest daily average) for the base and future year 

scenarios along with source group contributions to the future year design values. All modeled 

1-hour NO2 concentrations are below the NAAQS (100 ppb); concentrations in the immediate vicinity 

of the Louisiana Offshore Oil Port (LOOP) peak at 98.5 ppb. Concentrations decrease between the 

base and future year scenarios at most locations except for of as much as a 32-ppb increase in 

coastal Vermilion Parish, Louisiana. Increases are also projected offshore of Texas and Alabama 

and in some interior portions of Texas. 

Source Group contributions to the 8th highest daily average NO2 concentrations are shown in 

Figure H-57. Contributions from new platforms and support vessels and helicopters associated with 

the 2017-2022 GOM Multisale EIS scenario (Source Group B) are dominated by vessel and possibly 

helicopter traffic in the port areas, most notably in Vermilion Parish, Louisiana, where the maximum 

contribution is 55.6 ppb. Combined contributions from new and existing platforms and support 

vessels and helicopters (Source Group C) are dominant in the area of the LOOP. Contributions from 

natural and foreign sources are less than 10 ppb (not shown).
H-110 Gulf of Mexico Multisale EIS

Figure H-56. Modeled 8th Highest 1-hour NO2 Concentrations for the Base Year (top left), Future Year 

(top right), and the Future – Base Difference (bottom). 
Air Quality: Cumulative and Visibility Impacts H-111

Figure H-57. Contributions of Source Group A (top left), B (top right), C (middle left), D (middle right), 

and E (bottom) to the Future Year All-sources 8th Highest Daily Average NO2

Concentrations (note use of different color scales in each panel).
H-112 Gulf of Mexico Multisale EIS

Figure H-58 and Figure H-59 display modeled annual average NO2 concentrations for the 

base case and future year scenarios, along with source group contributions to the future year annual 

averages. All modeled concentrations are below the NAAQS. Increases between the base case 

and future year scenarios of as much as 8 ppb are modeled to occur near the entrance to the 

Freshwater Bayou Canal in Vermilion Parish, Louisiana. Somewhat larger increases are modeled in 

the Permian Basin of west Texas. 

Contributions of Source Groups to the annual average NO2 concentrations are shown in 

Figure H-59. These results are similar to those for 1-hour NO2 shown above. Maximum impacts 

from new platforms and support vessels and helicopters associated with the 2017-2022 GOM 

Multisale EIS scenario are as much as 8.6 ppb (16% of the NAAQS). 

Figure H-58. Modeled Annual Average NO2 Concentrations for the Base Year (top left), Future Year (top 

right), and the Future – Base Difference (bottom). 
Air Quality: Cumulative and Visibility Impacts H-113

Figure H-59. Contributions of Source Groups A (top left), B (top right), C (middle left), D (middle right), 

and E (bottom) to the Future Year All-sources Annual Average NO2 Concentrations.
H-114 Gulf of Mexico Multisale EIS

H.7.1.5.3 SO2

Results are presented here for both the 1-hour average primary SO2 NAAQS (75 ppb) and 

the 3-hour average secondary SO2 NAAQS (0.5 ppm). 

Figure H-60 displays modeled 1-hour SO2 design values (based on the 4th highest daily 

maximum 1-hour average SO2 concentration) for the base, future, and future-base scenarios. 

Modeled values for the base year are generally below the NAAQS except in the immediate vicinity of 

some major point sources. Sources in areas with deepwater platforms are evident with maximum 

values up to 50 ppb. Concentrations decrease in most locations in the future year scenario as 

sources are retired or apply control equipment with projected maximum impacts all below the 

NAAQS. No increases in excess of 5 ppb are modeled along the Gulf Coast or over the open 

ocean.

Contributions of source groups to the modeled 1-hour SO2 concentrations are shown in 

Figure H-61. New sources associated with the 2017-2022 GOM Multisale EIS scenario (Source 

Group B) are modeled to contribute less than 1 ppb. 

Figure H-62 displays modeled 3-hour SO2 design values (based on the annual 2nd highest 

block, 3-hour average SO2 concentration) for the base, future, and future-base scenarios. All 

modeled values are below the NAAQS (500 ppb). These results are similar to those for the 1-hour 

SO2 described above.

Contributions of source groups to the modeled 3-hour SO2 concentrations are shown in 

Figure H-63. Results are similar to those for the 1-hour SO2 concentrations described above.
Air Quality: Cumulative and Visibility Impacts H-115

Figure H-60. Modeled 4th Highest Daily Maximum 1-hour SO2 Concentrations for the Base Year (top 

left), Future Year (top right), and the Future – Base Difference (bottom). 
H-116 Gulf of Mexico Multisale EIS

Figure H-61. Contributions of Source Group A (top left), B (top right), C (middle left), D (middle right), and 

E (bottom) to the Future Year All-sources 4th Highest Daily Maximum 1-hour SO2

Concentration (note different color scales used in each panel).
Air Quality: Cumulative and Visibility Impacts H-117

Figure H-62. Modeled Annual 2nd Highest Block 3-hour SO2 Concentrations for the Base Year (top left), 

Future Year (top right), and the Future – Base Difference (bottom).
H-118 Gulf of Mexico Multisale EIS

Figure H-63. Contributions of Source Group A (top left), B (top right), C (middle left), D (middle right), 

and E (bottom) to the Future Year All-sources 2nd Highest 3-hour Block Average SO2

Concentration (note different color scales used in each panel). 
Air Quality: Cumulative and Visibility Impacts H-119

H.7.1.5.4 CO

Results are presented here for both the 8-hour average (9 ppm) and 1-hour average 

(35 ppm) CO NAAQS. 

Figure H-64 displays modeled 8-hour CO design values (based on the annual 2nd highest 

nonoverlapping running 8-hour average) for the base, future, and future-base scenarios. Similarly, 

Figure H-65 displays modeled 1-hour CO design values (based on the annual 2nd highest daily 

maximum 1-hour average) for the base, future, and future-base scenarios. All values are below the 

NAAQS. The maximum predicted 8-hour design value in the future year is predicted to be 8.3 ppb at 

the entrance to the Freshwater Bayou Canal in Vermilion Parish, Louisiana. Differences between 

the base and future year scenarios are less than 3 ppm. 

Individual source group contributions to CO design values were not calculated as the CAMx 

source apportionment methods do not include tracers for CO. 

Figure H-64. Modeled Annual 2nd Highest Non-overlapping Running 8-hour Average CO 

Concentrations for the Base Year (top left), Future Year (top right), and the 

Future – Base Difference (bottom).
H-120 Gulf of Mexico Multisale EIS

Figure H-65. Modeled Annual 2nd Highest 1-hour Average CO Concentrations for the Base Year (top 

left), Future Year (top right), and the Future – Base Difference (bottom).

H.7.2 PSD Increments

Incremental impacts of each source group at Class I and sensitive Class II areas were 

calculated for all pollutants for which PSD increments have been set (NO2, SO2, PM10, PM2.5). 

Increment consumption is based on the source group contribution calculated from the CAMx source 

contribution results. Increment consumption for 24-hour averages and the 3-hour average SO2 are 

based on the annual second highest values. Comparisons of impacts from the 2017-2022 GOM 

Multisale EIS scenario with maximum allowed PSD increments are presented here as an evaluation 

of a “threshold of concern” for potentially significant adverse impacts, but they do not represent a 

regulatory PSD increment consumption analysis. 

Results of the PSD increments analysis are summarized in Table H-24 in terms of the 

maximum increment consumption over all Class I/II areas within the 4-km modeling domain. 

Maximum impacts occur at the Breton Wilderness Class I area for all PSD pollutants and averaging 

times. Concentration increments from Source Groups A and B are less than the maximum allowed 
Air Quality: Cumulative and Visibility Impacts H-121

PSD increments for all pollutants and averaging times except for the 24-hour PM2.5 increment from 

Source Group B at the Breton Wilderness Class I area where the maximum impact (2.19 μg/m3

) 

exceeds the Class I PSD increment (2 μg/m3

) by just under 10%. The maximum Source Group A 

24-hour average PM2.5 increment is 0.53 μg/m3

, indicating that support vessels or helicopter traffic 

associated with new offshore platforms, rather than emissions from the platforms themselves, are 

largely responsible for pushing the maximum impact above the Class I PSD increment at Breton 

Wilderness. The 24-hour PM2.5 impact from Source Group B averaged over all grid cells covering 

the Breton Wilderness Class I area is 1.79 μg/m3

. Maximum impacts from Source Group C exceed 

the annual and 24-hour PM2.5, the 24-hour PM10, and the annual NO2 Class I PSD increments at 

Breton Wilderness. A summary of impacts from Source Groups A, B, and C for all Class I/II areas is 

provided in Table H-25. 

Table H-24. Maximum Source Group Contributions for PSD Pollutants at Class I and Sensitive Class II 

Areas in the 4-km Modeling Domain. 

Group Max @ Any 

Class I Area 

Percent of PSD 

Class I 

Increment

Class I Area 

Where Max 

Occurred

Max @ Any 

Class II Area

Percent of 

PSD Class II 

Increment

Class II Area 

Where Max 

Occurred

PM10 Annual (Increment = 4 μg/m3, 17 μg/m3)

A 0.04449 1.1% Breton Wilderness 0.04196 0.2% Gulf Islands NS

B 0.29475 7.4% Breton Wilderness 0.35482 2.1% Gulf Islands NS

C 1.44391 36.1% Breton Wilderness 1.24095 7.3% Gulf Islands NS

PM10 24-Hour (Class I, II Increment = 8 μg/m3, 30 μg/m3)

A 0.53529 6.7% Breton Wilderness 0.61362 2.0% Gulf Islands NS

B 2.19999 27.5% Breton Wilderness 2.45061 8.2% Gulf Islands NS

C 14.4191 180.2% Breton Wilderness 13.9928 46.6% Gulf Islands NS

PM2.5 Annual (Class I, II Increment = 1 μg/m3, 4 μg/m3)

A 0.04449 4.4% Breton Wilderness 0.04196 1.0% Gulf Islands NS

B 0.29152 29.2% Breton Wilderness 0.34969 8.7% Gulf Islands NS

C 1.43641 143.6% Breton Wilderness 1.23711 30.9% Gulf Islands NS

PM2.5 24-Hour (Class I, II Increment = 2 μg/m3, 9 μg/m3)

A 0.53527 26.8% Breton Wilderness 0.6136 6.8% Gulf Islands NS

B 2.19194 109.6% Breton Wilderness 2.44002 27.1% Gulf Islands NS

C 14.3964 719.8% Breton Wilderness 13.9795 155.3% Gulf Islands NS

NO2 Annual (Class I, II Increment = 2.5 μg/m3, 25 μg/m3)

A 0.12789 5.1% Breton Wilderness 0.14467 0.6% Gulf Islands NS

B 0.65768 26.3% Breton Wilderness 0.93535 3.7% Gulf Islands NS

C 2.61628 104.7% Breton Wilderness 1.95517 7.8% Breton NWR

SO2 Annual (Class I, II Increment = 2 μg/m3, 20 μg/m3)

A 0.00113 0.1% Breton Wilderness 0.00121 0.0% Gulf Islands NS

B 0.00271 0.1% Breton Wilderness 0.00178 0.0% Gulf Islands NS

C 0.0684 3.4% Breton Wilderness 0.05601 0.3% Breton NWR

SO2 24-Hour (Class I, II Increment = 5 μg/m3, 91 μg/m3)

A 0.01009 0.2% Breton Wilderness 0.01104 0.0% Breton NWR

B 0.01891 0.4% Breton Wilderness 0.0156 0.0% Breton NWR

C 0.53913 10.8% Breton Wilderness 0.41742 0.5% Breton NWR
H-122 Gulf of Mexico Multisale EIS

Group Max @ Any 

Class I Area 

Percent of PSD 

Class I 

Increment

Class I Area 

Where Max 

Occurred

Max @ Any 

Class II Area

Percent of 

PSD Class II 

Increment

Class II Area 

Where Max 

Occurred

SO2 3-Hour (Class I, II Increment = 25 μg/m3, 512 μg/m3)

A 0.02228 0.1% Breton Wilderness 0.01655 0.0% Breton NWR

B 0.03451 0.1% Breton Wilderness 0.02296 0.0% Breton NWR

C 1.17783 4.7% Breton Wilderness 1.03688 0.2% Breton NWR

NS = National Seashore; NWR = National Wildlife Refuge.

H.7.3 AQRV Impacts

H.7.3.1 Visibility

Incremental visibility impacts were calculated for each source group as well as the 

cumulative impact of all sources combined. The approach used the incremental concentrations as 

quantified by the CAMx PSAT source apportionment tool simulation for each source group. 

Changes in light extinction from CAMx model concentration increments due to emissions from each 

source group were calculated for each day at grid cells that intersect Class I and sensitive Class II 

areas within the 12-km modeling domain. 

Calculation of incremental visibility impacts followed procedures recommended by the 

Federal Land Managers (FLAG, 2010) as described in Section H.6.2.3.1. 

For each individual source group, the estimated visibility degradation at each Class I and 

sensitive Class II area in the 12-km modeling domain due to emissions from the source group are 

presented in terms of the number of days that exceed a threshold change in deciview (∆dv) relative 

to background conditions. The number of days with a ∆dv greater than 0.5 and 1.0 are reported.

Results of the FLAG (2010) incremental visibility impact assessment for Source Groups A 

and B are presented in Table H-26 and

Table H-27, respectively. For Source Group A, the annual 8th highest ∆dv exceed the 1.0

threshold at Breton Wilderness, Breton National Wildlife Refuge, and Gulf Islands National 

Seashore. Incremental impacts for Source Group B are larger and include days with the 8th highest 

∆dv greater than 1.0 at Padre Island National Seashore in addition to the areas mentioned above, as 

well as values greater than 0.5 at Chassahowitzka Wilderness and St. Marks National Wildlife 

Refuge. 
Air Quality: Cumulative and Visibility Impacts

H-123

Table H-25. Source Group Contributions for PSD Pollutants at All Class I and Sensitive Class II Areas in the 4-km Modeling Domain.

Source Group A

Pollutant NO2 (μg/m3) PM10 (μg/m3) PM25 (μg/m3) SO2 (μg/m3)

Averaging Time Annual3 24-hour2 Annual3 24-hour4 Annual3 3-hour2 24-hour2 Annual3

Class I State Owner PSD Class I Increment1

2.5 8 4 2 1 25 5 2

Breton Wilderness LA FWS 0.128 0.535 0.044 0.535 0.044 0.022 0.010 0.001

Class II State Owner PSD Class II Increment1

25 30 17 9 4 512 91 20

Breton NWR LA FWS 0.063 0.436 0.036 0.436 0.036 0.017 0.011 0.001

Gulf Islands NS FL,MS NPS 0.145 0.614 0.042 0.614 0.042 0.014 0.007 0.001

Padre Island NS TX NPS 0.014 0.169 0.014 0.169 0.014 0.006 0.002 0.000

Source Group B

Pollutant NO2 (μg/m3) PM10 (μg/m3) PM25 (μg/m3) SO2 (μg/m3)

Averaging Time Annual3 24-hour2 Annual3 24-hour4 Annual3 3-hour2 24-hour2 Annual3

Class I State Owner PSD Class I Increment1

2.5 8 4 2 1 25 5 2

Breton Wilderness LA FWS 0.658 2.200 0.295 2.192 0.292 0.035 0.019 0.003

Class II State Owner PSD Class II Increment1

25 30 17 9 4 512 91 20

Breton NWR LA FWS 0.321 1.752 0.182 1.748 0.181 0.023 0.016 0.002

Gulf Islands NS FL,MS NPS 0.935 2.451 0.355 2.440 0.350 0.017 0.008 0.002

Padre Island NS TX NPS 0.181 1.013 0.166 1.012 0.165 0.006 0.003 0.001

Source Group C

Pollutant NO2 (μg/m3) PM10 (μg/m3) PM25 (μg/m3) SO2 (μg/m3)

Averaging Time Annual3 24-hour2 Annual3 24-hour4 Annual3 3-hour2 24-hour2 Annual3

Class I State Owner PSD Class I Increment1

2.5 8 4 2 1 25 5 2

Breton Wilderness LA FWS 2.616 14.419 1.444 14.396 1.436 1.178 0.539 0.068

Class II State Owner PSD Class II Increment1

25 30 17 9 4 512 91 20

Breton NWR LA FWS 1.955 12.577 1.127 12.559 1.122 1.037 0.417 0.056

Gulf Islands NS FL,MS NPS 1.521 13.993 1.241 13.979 1.237 0.410 0.196 0.016

Padre Island NS TX NPS 0.198 2.031 0.225 2.030 0.224 0.044 0.022 0.002

NS = National Seashore; NWR = National Wildlife Refuge.

1 The PSD demonstrations serve information purposes only and do not constitute a regulatory PSD increment consumption analysis.

2 Based on 2nd highest 24-hour average. 3 Annual arithmetic mean.

4 Based on 2nd highest 24-hour average.
H-124 Gulf of Mexico Multisale EIS

Table H-26. Incremental Visibility Impacts Relative to Natural Background Conditions from Source 

Group A.

Area Max ∆dv 8th High ∆dv

No. of Days

>1.0 >0.5

Class I Areas

Bandelier National Monument 0.00067 0.00016 0 0

Black Canyon of the Gunnison National Park 0.00002 0.00000 0 0

Bosque del Apache National Wildlife Refuge 0.00050 0.00018 0 0

Bosque del Apache (Chupadera Unit) Wilderness 0.00036 0.00013 0 0

Bosque del Apache (Indian Well Unit) Wilderness 0.00036 0.00014 0 0

Bosque del Apache (Little San Pascual Unit) Wilderness 0.00072 0.00023 0 0

Big Bend National Park 0.00746 0.00286 0 0

Bradwell Bay Wilderness 0.08487 0.05269 0 0

Breton Wilderness 2.65806 1.54415 22 57

Caney Creek Wilderness 0.21478 0.07569 0 0

Cape Romain Wilderness 0.08319 0.01800 0 0

Carlsbad Caverns National Park 0.00337 0.00163 0 0

Chassahowitzka Wilderness 0.26500 0.11299 0 0

Cohutta Wilderness 0.07214 0.02483 0 0

Dolly Sods Wilderness 0.01130 0.00424 0 0

Eagles Nest Wilderness 0.00009 0.00001 0 0

Everglades National Park 0.13374 0.04721 0 0

Flat Tops Wilderness 0.00002 0.00000 0 0

Great Sand Dunes National Monument 0.00020 0.00006 0 0

Great Smoky Mountains National Park 0.02866 0.01263 0 0

Guadalupe Mountains National Park 0.00283 0.00094 0 0

Hercules-Glades Wilderness 0.05899 0.02394 0 0

James River Face Wilderness 0.00768 0.00391 0 0

Joyce-Kilmer-Slickrock Wilderness 0.02655 0.00881 0 0

La Garita Wilderness 0.00013 0.00001 0 0

Linville Gorge Wilderness 0.01892 0.00436 0 0

Mammoth Cave National Park 0.04330 0.01815 0 0

Maroon Bells-Snowmass Wilderness 0.00007 0.00001 0 0

Mingo National Wildlife Refuge 0.07764 0.04615 0 0

Mount_Zirkel Wilderness 0.00002 0.00000 0 0

Okefenokee National Wildlife Refuge 0.06476 0.03510 0 0

Otter Creek Wilderness 0.01108 0.00356 0 0

Pecos Wilderness 0.00091 0.00023 0 0

Rawah Wilderness 0.00005 0.00001 0 0

Rocky Mountain National Park 0.00023 0.00003 0 0

Saint Marks National Wildlife Refuge 0.24139 0.19294 0 0

Salt Creek Wilderness 0.00278 0.00149 0 0

San Pedro Parks Wilderness 0.00038 0.00010 0 0

Shenandoah National Park 0.02361 0.00945 0 0

Shining Rock Wilderness 0.02231 0.01030 0 0

Sipsey Wilderness 0.09946 0.02484 0 0
Air Quality: Cumulative and Visibility Impacts H-125

Area Max ∆dv 8th High ∆dv No. of Days

>1.0 >0.5

Swanquarter National Wildlife Refuge 0.01852 0.00864 0 0

Upper Buffalo Wilderness 0.05460 0.02255 0 0

Weminuche Wilderness 0.00018 0.00002 0 0

West Elk Wilderness 0.00006 0.00001 0 0

Wheeler Peak Wilderness 0.00037 0.00012 0 0

White Mountain Wilderness 0.00085 0.00042 0 0

Wichita Mountains National Wildlife Refuge 0.02963 0.01625 0 0

Wichita Mountains (Charons Garden Unit) Wilderness 0.02932 0.01390 0 0

Wichita Mountains (North Mountain Unit) Wilderness 0.02983 0.01408 0 0

Wolf Island Wilderness 0.10444 0.02825 0 0

Class II Areas

Breton National Wildlife Refuge 2.51391 1.44000 13 41

Gulf Islands National Seashore 3.59820 1.79194 26 64

Padre Island National Seashore 1.28497 0.44893 2 5

Table H-27. Incremental Visibility Impacts Relative to Natural Background Conditions from Source 

Group B.

Area Max ∆dv 8th High ∆dv No. of Days

>1.0 >0.5

Class I Areas

Bandelier NM 0.00588 0.00225 0 0

Black Canyon of the Gunnison National Park 0.00027 0.00003 0 0

Bosque del Apache National Wildlife Refuge 0.00927 0.00254 0 0

Bosque del Apache (Chupadera Unit) Wilderness 0.00674 0.00173 0 0

Bosque del Apache (Indian Well Unit) Wilderness 0.00692 0.00183 0 0

Bosque del Apache (Little San Pascual Unit) Wilderness 0.01274 0.00311 0 0

Big Bend National Park 0.06000 0.03458 0 0

Bradwell Bay Wilderness 0.43077 0.29328 0 0

Breton Wilderness 7.77098 6.27094 155 256

Caney Creek Wilderness 1.37302 0.48258 1 7

Cape Romain Wilderness 0.31147 0.08130 0 0

Carlsbad Caverns National Park 0.03024 0.01639 0 0

Chassahowitzka Wilderness 1.35442 0.55791 3 9

Cohutta Wilderness 0.37888 0.12203 0 0

Dolly Sods Wilderness 0.06063 0.03063 0 0

Eagles Nest Wilderness 0.00128 0.00016 0 0

Everglades National Park 0.72032 0.18655 0 2

Flat Tops Wilderness 0.00022 0.00003 0 0

Great Sand Dunes National Monument 0.00329 0.00067 0 0

Great Smoky Mountains National Park 0.15002 0.07991 0 0

Guadalupe Mountains National Park 0.02529 0.01502 0 0

Hercules-Glades Wilderness 0.41027 0.16105 0 0

James River Face Wilderness 0.05739 0.02478 0 0
H-126 Gulf of Mexico Multisale EIS

Joyce-Kilmer-Slickrock Wilderness 0.15156 0.07538 0 0

La Garita Wilderness 0.00252 0.00019 0 0

Linville Gorge Wilderness 0.10346 0.03554 0 0

Mammoth Cave National Park 0.23624 0.09683 0 0

Maroon Bells-Snowmass Wilderness 0.00103 0.00006 0 0

Mingo National Wildlife Refuge 0.44782 0.25368 0 0

Mount_Zirkel Wilderness 0.00019 0.00003 0 0

Okefenokee National Wildlife Refuge 0.40346 0.21507 0 0

Otter Creek Wilderness 0.06577 0.02996 0 0

Pecos Wilderness 0.00863 0.00303 0 0

Rawah Wilderness 0.00062 0.00016 0 0

Rocky Mountain National Park 0.00128 0.00028 0 0

Saint Marks National Wildlife Refuge 1.04546 0.79486 2 23

Salt Creek Wilderness 0.03543 0.01558 0 0

San Pedro Parks Wilderness 0.00562 0.00171 0 0

Shenandoah National Park 0.13636 0.05190 0 0

Shining Rock Wilderness 0.12422 0.06132 0 0

Sipsey Wilderness 0.47703 0.15148 0 0

Swanquarter National Wildlife Refuge 0.09369 0.04563 0 0

Upper Buffalo Wilderness 0.42865 0.16699 0 0

Weminuche Wilderness 0.00268 0.00031 0 0

West Elk Wilderness 0.00100 0.00006 0 0

Wheeler Peak Wilderness 0.00491 0.00148 0 0

White Mountain Wilderness 0.01424 0.00635 0 0

Wichita Mountains National Wildlife Refuge 0.19286 0.10693 0 0

Wichita Mountains (Charons Garden Unit) Wilderness 0.18960 0.08842 0 0

Wichita Mountains (North Mountain Unit) Wilderness 0.19390 0.09435 0 0

Wolf Island Wilderness 0.39934 0.13342 0 0

Class II Areas

Breton National Wildlife Refuge 7.10912 4.34015 104 193

Gulf Islands National Seashore 10.54646 6.33562 198 311

Padre Island National Seashore 5.10452 3.05326 115 204

H.7.3.1.2 Cumulative Visibility Analysis

For the cumulative visibility impacts analysis, the MATS software was applied with observed 

PM species concentrations and monthly average relative humidity from IMPROVE monitoring sites 

to calculate daily visibility impairment at Class I areas from which the W20% and B20% visibility 

days metrics are determined as described in Section H.7.2.3.1. Since not all Class I areas have a 

co-located IMPROVE monitoring site, IMPROVE observations were mapped to nearby Class I areas 

that did not include an IMPROVE monitor. In Table H-28, the Class I area of interest is shown in the 

first column and the IMPROVE site used to represent observed visibility at the Class I area is shown 

in the third column. For example, the IMPROVE data from Dolly Sods Wilderness was used to 

represent observed visibility for both Dolly Sods Wilderness and Otter Creek Wilderness. The MATS 

includes mappings of IMPROVE site to Class I areas. However, MATS does not include a mapping 
Air Quality: Cumulative and Visibility Impacts H-127

for the Breton Wilderness or Bradwell Bay Class I areas and, therefore, cumulative visibility results 

for these areas are not included in this analysis.

Table H-28 and Table H-29 present results for the W20% visibility days, and Table H-30

and Table H-31 present results for the B20% visibility days. Visibility improvement between the 

base and future year scenarios (i.e., positive BY-FY results in Table H-29 and Table H-31) are seen 

at most Class I areas, with eight areas experiencing reductions in visibility on the W20% days. All of 

these areas are in New Mexico and Colorado, and Gulf of Mexico sources (Source Group D) 

contribute less than 0.02 dv to visibility impairment in these areas. The maximum contribution from 

new platforms and support vessels and helicopters associated with the 2017-2022 GOM Multisale 

EIS scenario (Source Group B) to any area on the W20% days is 0.04 dv at Caney Creek, Arkansas. 

Contributions from all Gulf of Mexico sources (Source Group D) are the greatest (0.34 dv) at St. 

Marks National Wildlife Refuge, Florida. 

For the B20% visibility days, 11 areas experience reductions in visibility. All but one of these 

areas are located in New Mexico and Colorado; the lone exception is Big Bend National Park in 

Texas. Contributions from Gulf of Mexico sources to these 11 areas are all less than 0.01 dv. The 

maximum contribution from new platforms and support vessels and helicopters associated with the 

2017-2022 GOM Multisale EIS (Source Group B) to any area on the B20% days is 0.01 dv, which 

occurs at several sites. Contributions from all Gulf of Mexico sources (Source Group D) are the 

greatest (0.08 dv) at St. Marks Wilderness in Florida. 
 H-128 Gulf of Mexico Multisale EIS

Table H-28. Cumulative Visibility Results for 20% Worst Visibility Days (W20%) at Class I Areas for Base (2012) Year (BY) and Future Year 

(FY) Scenarios with All Sources Included and with Contributions from Each Source Group Removed.

FY DV without Source Group

Class I Name State IMPROVE Site BY DV FY DV A B C D E

Bandelier NM NM BAND1 11.79 11.93 11.93 11.93 11.93 11.93 7.56

Big Bend NP TX BIBE1 16.40 16.11 16.11 16.11 16.10 16.09 11.13

Black Canyon of the Gunnison NM CO WEMI1 10.11 10.05 10.05 10.05 10.05 10.05 9.34

Bosque del Apache NM BOAP1 13.65 13.90 13.90 13.90 13.90 13.90 10.69

Caney Creek Wilderness AR CACR1 22.66 20.59 20.58 20.55 20.45 20.36 13.36

Carlsbad Caverns NP TX GUMO1 15.17 15.14 15.14 15.14 15.14 15.14 9.33

Chassahowitzka FL CHAS1 21.77 20.43 20.43 20.41 20.35 20.18 11.45

Cohutta Wilderness GA COHU1 23.94 21.11 21.11 21.11 21.09 21.06 12.89

Dolly Sods Wilderness WV DOSO1 23.45 19.52 19.52 19.52 19.52 19.51 14.64

Eagles Nest Wilderness CO WHRI1 8.81 8.72 8.72 8.72 8.72 8.72 7.84

Everglades NP FL EVER1 18.33 17.63 17.63 17.63 17.63 17.51 15.00

Flat Tops Wilderness CO WHRI1 8.81 8.72 8.72 8.72 8.72 8.72 7.84

Great Sand Dunes NM CO GRSA1 11.52 11.62 11.62 11.62 11.62 11.62 8.94

Great Smoky Mountains NP TN GRSM1 23.75 20.30 20.30 20.29 20.29 20.28 13.84

Guadalupe Mountains NP TX GUMO1 15.17 15.14 15.14 15.14 15.14 15.14 9.33

Hercules-Glades Wilderness MO HEGL1 23.50 21.48 21.47 21.46 21.42 21.37 13.21

James River Face Wilderness VA JARI1 23.50 20.75 20.75 20.74 20.74 20.73 16.07

Joyce-Kilmer-Slickrock Wilderness TN GRSM1 23.75 20.30 20.30 20.29 20.29 20.28 13.84

La Garita Wilderness CO WEMI1 10.11 10.05 10.05 10.05 10.05 10.05 9.34

Linville Gorge Wilderness NC LIGO1 22.61 19.38 19.38 19.37 19.37 19.36 13.29

Maroon Bells-Snowmass Wilderness CO WHRI1 8.81 8.72 8.72 8.72 8.72 8.72 7.84

Mammoth Cave NP KY MACA1 26.11 22.68 22.68 22.68 22.67 22.66 14.97

Mount Zirkel Wilderness CO MOZI1 9.33 9.20 9.20 9.20 9.20 9.20 7.25

Okefenokee GA OKEF1 23.31 21.99 21.99 21.98 21.93 21.87 12.62

Otter Creek Wilderness WV DOSO1 23.45 19.52 19.52 19.52 19.52 19.51 14.64

Pecos Wilderness NM WHPE1 10.04 10.10 10.10 10.10 10.10 10.10 6.73

Rawah Wilderness CO MOZI1 9.33 9.20 9.20 9.20 9.20 9.20 7.25

Cape Romain SC ROMA1 23.40 21.77 21.77 21.77 21.73 21.68 13.12

Rocky Mountain NP CO ROMO1 12.02 11.86 11.86 11.86 11.86 11.86 9.19
Table H-28. Cumulative Visibility Results for 20% Worst Visibility Days (W20%) at Class I Areas for Base (2012) Year (BY) and Future Year 

(FY) Scenarios with All Sources Included and with Contributions from Each Source Group Removed. (continued) 

Air Quality: Cumulative and Visibility Impacts

H-129

FY DV without Source Group

Class I Name State IMPROVE Site BY DV FY DV A B C D E

Salt Creek NM SACR1 17.22 17.79 17.79 17.79 17.79 17.78 7.30

St. Marks FL SAMA1 23.01 21.18 21.18 21.16 21.06 20.84 13.43

San Pedro Parks Wilderness NM SAPE1 9.94 9.98 9.98 9.98 9.98 9.98 7.15

Shenandoah NP VA SHEN1 22.95 19.42 19.42 19.42 19.41 19.39 14.90

Shining Rock Wilderness NC SHRO1 21.90 18.78 18.78 18.77 18.77 18.76 12.25

Sipsey Wilderness AL SIPS1 23.98 21.48 21.48 21.47 21.46 21.44 13.01

Swanquarter NC SWAN1 22.29 20.39 20.39 20.39 20.38 20.37 13.42

Upper Buffalo Wilderness AR UPBU1 22.93 20.90 20.89 20.87 20.79 20.71 12.97

West Elk Wilderness CO WHRI1 8.81 8.72 8.72 8.72 8.72 8.72 7.84

Weminuche Wilderness CO WEMI1 10.11 10.05 10.05 10.05 10.05 10.05 9.34

White Mountain Wilderness NM WHIT1 14.24 14.60 14.60 14.60 14.59 14.59 8.15

Wheeler Peak Wilderness NM WHPE1 10.04 10.10 10.10 10.10 10.10 10.10 6.73

Wichita Mountains OK WIMO1 21.55 20.33 20.33 20.32 20.31 20.30 10.33

Wolf Island GA OKEF1 23.31 21.99 21.99 21.98 21.93 21.87 12.62

NM = National Monument; NP = National Park.
 H-130 Gulf of Mexico Multisale EIS

Table H-29. Differences in Cumulative Visibility Results for 20% Worst Visibility Days (W20%) at Class I Areas Between the Future Year (FY) 

and Base Year (BY) Scenarios and Contributions of Each Source Group to the Future Year Scenario Visibility. 

FY DV without Source Group

Class I Name State IMPROVE Site BYFY DV A B C D E

Bandelier NM NM BAND1 -0.14 0.00 0.00 0.00 0.00 4.37

Big Bend NP TX BIBE1 0.29 0.00 0.00 0.01 0.02 4.98

Black Canyon of the Gunnison NM CO WEMI1 0.06 0.00 0.00 0.00 0.00 0.71

Bosque del Apache NM BOAP1 -0.25 0.00 0.00 0.00 0.00 3.21

Caney Creek Wilderness AR CACR1 2.07 0.01 0.04 0.14 0.23 7.23

Carlsbad Caverns NP TX GUMO1 0.03 0.00 0.00 0.00 0.00 5.81

Chassahowitzka FL CHAS1 1.34 0.00 0.02 0.08 0.25 8.98

Cohutta Wilderness GA COHU1 2.83 0.00 0.00 0.02 0.05 8.22

Dolly Sods Wilderness WV DOSO1 3.93 0.00 0.00 0.00 0.01 4.88

Eagles Nest Wilderness CO WHRI1 0.09 0.00 0.00 0.00 0.00 0.88

Everglades NP FL EVER1 0.70 0.00 0.00 0.00 0.12 2.63

Flat Tops Wilderness CO WHRI1 0.09 0.00 0.00 0.00 0.00 0.88

Great Sand Dunes NM CO GRSA1 -0.10 0.00 0.00 0.00 0.00 2.68

Great Smoky Mountains NP TN GRSM1 3.45 0.00 0.01 0.01 0.02 6.46

Guadalupe Mountains NP TX GUMO1 0.03 0.00 0.00 0.00 0.00 5.81

Hercules-Glades Wilderness MO HEGL1 2.02 0.01 0.02 0.06 0.11 8.27

James River Face Wilderness VA JARI1 2.75 0.00 0.01 0.01 0.02 4.68

Joyce-Kilmer-Slickrock Wilderness TN GRSM1 3.45 0.00 0.01 0.01 0.02 6.46

La Garita Wilderness CO WEMI1 0.06 0.00 0.00 0.00 0.00 0.71

Linville Gorge Wilderness NC LIGO1 3.23 0.00 0.01 0.01 0.02 6.09

Maroon Bells-Snowmass Wilderness CO WHRI1 0.09 0.00 0.00 0.00 0.00 0.88

Mammoth Cave NP KY MACA1 3.43 0.00 0.00 0.01 0.02 7.71

Mount Zirkel Wilderness CO MOZI1 0.13 0.00 0.00 0.00 0.00 1.95

Okefenokee GA OKEF1 1.32 0.00 0.01 0.06 0.12 9.37

Otter Creek Wilderness WV DOSO1 3.93 0.00 0.00 0.00 0.01 4.88

Pecos Wilderness NM WHPE1 -0.06 0.00 0.00 0.00 0.00 3.37

Rawah Wilderness CO MOZI1 0.13 0.00 0.00 0.00 0.00 1.95

Cape Romain SC ROMA1 1.63 0.00 0.00 0.04 0.09 8.65

Rocky Mountain NP CO ROMO1 0.16 0.00 0.00 0.00 0.00 2.67
Table H-29. Differences in Cumulative Visibility Results for 20% Worst Visibility Days (W20%) at Class I Areas Between the Future Year (FY) 

and Base Year (BY) Scenarios and Contributions of Each Source Group to the Future Year Scenario Visibility (continued) 

Air Quality: Cumulative and Visibility Impacts

H-131

FY DV without Source Group

Class I Name State IMPROVE Site BYFY DV A B C D E

Salt Creek NM SACR1 -0.57 0.00 0.00 0.00 0.01 10.49

St. Marks FL SAMA1 1.83 0.00 0.02 0.12 0.34 7.75

San Pedro Parks Wilderness NM SAPE1 -0.04 0.00 0.00 0.00 0.00 2.83

Shenandoah NP VA SHEN1 3.53 0.00 0.00 0.01 0.03 4.52

Shining Rock Wilderness NC SHRO1 3.12 0.00 0.01 0.01 0.02 6.53

Sipsey Wilderness AL SIPS1 2.50 0.00 0.01 0.02 0.04 8.47

Swanquarter NC SWAN1 1.90 0.00 0.00 0.01 0.02 6.97

Upper Buffalo Wilderness AR UPBU1 2.03 0.01 0.03 0.11 0.19 7.93

West Elk Wilderness CO WHRI1 0.09 0.00 0.00 0.00 0.00 0.88

Weminuche Wilderness CO WEMI1 0.06 0.00 0.00 0.00 0.00 0.71

White Mountain Wilderness NM WHIT1 -0.36 0.00 0.00 0.01 0.01 6.45

Wheeler Peak Wilderness NM WHPE1 -0.06 0.00 0.00 0.00 0.00 3.37

Wichita Mountains OK WIMO1 1.22 0.00 0.01 0.02 0.03 10.00

Wolf Island GA OKEF1 1.32 0.00 0.01 0.06 0.12 9.37

NM = National Monument; NP = National Park.
H-132 Gulf of Mexico Multisale EIS

Table H-30. Cumulative Visibility Results for 20% Best Visibility Days (B20%) at Class I Areas for Base 

(2012) Year (BY) and Future Year (FY) Scenarios with All Sources Included and with 

Contributions from Each Source Group Removed. 

FY DV without Source Group

Class I Name State IMPROVE 

Site

BY 

DV

FY 

DV A B C D E 

Bandelier NM NM BAND1 3.81 3.96 3.96 3.96 3.96 3.96 1.51

Big Bend NP TX BIBE1 5.76 5.86 5.86 5.86 5.86 5.86 3.50

Black Canyon of the 

Gunnison NM CO WEMI1 2.04 2.18 2.18 2.18 2.18 2.18 1.55

Bosque del Apache NM BOAP1 5.57 5.60 5.60 5.60 5.60 5.60 3.60

Caney Creek 

Wilderness AR CACR1 9.82 9.25 9.25 9.24 9.22 9.20 5.15

Carlsbad Caverns NP TX GUMO1 5.08 5.03 5.03 5.03 5.03 5.03 2.39

Chassahowitzka FL CHAS1 14.05 13.55 13.55 13.54 13.52 13.34 8.22

Cohutta Wilderness GA COHU1 11.47 10.59 10.59 10.59 10.59 10.58 4.62

Dolly Sods Wilderness WV DOSO1 9.18 8.38 8.38 8.38 8.38 8.37 5.63

Eagles Nest Wilderness CO WHRI1 0.48 0.39 0.39 0.39 0.39 0.39 0.00

Everglades NP FL EVER1 11.29 11.08 11.08 11.07 11.06 10.99 8.01

Flat Tops Wilderness CO WHRI1 0.48 0.39 0.39 0.39 0.39 0.39 0.00

Great Sand Dunes NM CO GRSA1 3.57 3.56 3.56 3.56 3.56 3.56 2.20

Great Smoky Mountains 

NP TN GRSM1 11.10 9.78 9.78 9.78 9.78 9.77 4.22

Guadalupe Mountains 

NP TX GUMO1 5.08 5.03 5.03 5.03 5.03 5.03 2.39

Hercules-Glades 

Wilderness MO HEGL1 11.29 10.84 10.84 10.84 10.83 10.82 5.94

James River Face 

Wilderness VA JARI1 12.36 11.26 11.26 11.26 11.25 11.25 7.13

Joyce-Kilmer-Slickrock 

Wilderness TN GRSM1 11.10 9.78 9.78 9.78 9.78 9.77 4.22

La Garita Wilderness CO WEMI1 2.04 2.18 2.18 2.18 2.18 2.18 1.55

Linville Gorge 

Wilderness NC LIGO1 9.96 9.21 9.21 9.21 9.20 9.19 4.85

Maroon BellsSnowmass Wilderness CO WHRI1 0.48 0.39 0.39 0.39 0.39 0.39 0.00

Mammoth Cave NP KY MACA1 14.20 13.04 13.04 13.04 13.03 13.02 7.41

Mount Zirkel Wilderness CO MOZI1 0.89 0.79 0.79 0.79 0.79 0.79 0.00

Okefenokee GA OKEF1 13.40 12.89 12.89 12.89 12.88 12.85 7.58

Otter Creek Wilderness WV DOSO1 9.18 8.38 8.38 8.38 8.38 8.37 5.63

Pecos Wilderness NM WHPE1 1.09 1.24 1.24 1.24 1.24 1.24 0.00

Rawah Wilderness CO MOZI1 0.89 0.79 0.79 0.79 0.79 0.79 0.00

Cape Romain SC ROMA1 13.79 13.09 13.09 13.09 13.09 13.08 8.48

Rocky Mountain NP CO ROMO1 1.64 1.62 1.62 1.62 1.62 1.62 0.53

Salt Creek NM SACR1 7.11 7.42 7.42 7.42 7.42 7.42 2.89

St. Marks FL SAMA1 13.73 13.00 12.99 12.99 12.92 12.75 8.31

San Pedro Parks 

Wilderness NM SAPE1 1.30 1.37 1.37 1.37 1.37 1.37 0.61
Air Quality: Cumulative and Visibility Impacts H-133

FY DV without Source Group

Class I Name State IMPROVE 

Site

BY 

DV

FY 

DV A B C D E 

Shenandoah NP VA SHEN1 8.68 7.66 7.66 7.66 7.65 7.65 4.56

Shining Rock 

Wilderness NC SHRO1 6.58 5.81 5.80 5.80 5.79 5.79 2.03

Sipsey Wilderness AL SIPS1 13.10 12.20 12.20 12.19 12.16 12.13 6.79

Swanquarter NC SWAN1 11.76 11.09 11.09 11.08 11.08 11.08 7.45

Upper Buffalo 

Wilderness AR UPBU1 10.35 9.80 9.80 9.79 9.77 9.76 5.03

West Elk Wilderness CO WHRI1 0.48 0.39 0.39 0.39 0.39 0.39 0.00

Weminuche Wilderness CO WEMI1 2.04 2.18 2.18 2.18 2.18 2.18 1.55

White Mountain 

Wilderness NM WHIT1 3.24 3.45 3.45 3.45 3.45 3.45 1.41

Wheeler Peak 

Wilderness NM WHPE1 1.09 1.24 1.24 1.24 1.24 1.24 0.00

Wichita Mountains OK WIMO1 9.53 9.24 9.24 9.24 9.24 9.24 5.36

Wolf Island GA OKEF1 13.40 12.89 12.89 12.89 12.88 12.85 7.58

NM = National Monument; NP = National Park.

Table H-31. Differences in Cumulative Visibility Results for 20% Best Visibility Days (B20%) at Class I 

Areas Between the Future Year (FY) and Base Year (BY) Scenarios and Contributions of 

Each Source Group to the Future Year Scenario Visibility. 

Source Group Contribution to FY 

DV

Class I Name State IMPROVE 

Site

BY - FY 

DV A B C D E 

Bandelier NM NM BAND1 -0.15 0.00 0.00 0.00 0.00 2.45

Big Bend NP TX BIBE1 -0.10 0.00 0.00 0.00 0.00 2.36

Black Canyon of the Gunnison 

NM CO WEMI1 -0.14 0.00 0.00 0.00 0.00 0.63

Bosque del Apache NM BOAP1 -0.03 0.00 0.00 0.00 0.00 2.00

Caney Creek Wilderness AR CACR1 0.57 0.00 0.01 0.03 0.05 4.10

Carlsbad Caverns NP TX GUMO1 0.05 0.00 0.00 0.00 0.00 2.64

Chassahowitzka FL CHAS1 0.50 0.00 0.01 0.03 0.21 5.33

Cohutta Wilderness GA COHU1 0.88 0.00 0.00 0.00 0.01 5.97

Dolly Sods Wilderness WV DOSO1 0.80 0.00 0.00 0.00 0.01 2.75

Eagles Nest Wilderness CO WHRI1 0.09 0.00 0.00 0.00 0.00 0.39

Everglades NP FL EVER1 0.21 0.00 0.01 0.02 0.09 3.07

Flat Tops Wilderness CO WHRI1 0.09 0.00 0.00 0.00 0.00 0.39

Great Sand Dunes NM CO GRSA1 0.01 0.00 0.00 0.00 0.00 1.36

Great Smoky Mountains NP TN GRSM1 1.32 0.00 0.00 0.00 0.01 5.56

Guadalupe Mountains NP TX GUMO1 0.05 0.00 0.00 0.00 0.00 2.64

Hercules-Glades Wilderness MO HEGL1 0.45 0.00 0.00 0.01 0.02 4.90

James River Face Wilderness VA JARI1 1.10 0.00 0.00 0.01 0.01 4.13

Joyce-Kilmer-Slickrock 

Wilderness TN GRSM1 1.32 0.00 0.00 0.00 0.01 5.56
H-134 Gulf of Mexico Multisale EIS

Source Group Contribution to FY 

DV

Class I Name State IMPROVE 

Site

BY - FY 

DV A B C D E 

La Garita Wilderness CO WEMI1 -0.14 0.00 0.00 0.00 0.00 0.63

Linville Gorge Wilderness NC LIGO1 0.75 0.00 0.00 0.01 0.02 4.36

Maroon Bells-Snowmass 

Wilderness CO WHRI1 0.09 0.00 0.00 0.00 0.00 0.39

Mammoth Cave NP KY MACA1 1.16 0.00 0.00 0.01 0.02 5.63

Mount Zirkel Wilderness CO MOZI1 0.10 0.00 0.00 0.00 0.00 0.79

Okefenokee GA OKEF1 0.51 0.00 0.00 0.01 0.04 5.31

Otter Creek Wilderness WV DOSO1 0.80 0.00 0.00 0.00 0.01 2.75

Pecos Wilderness NM WHPE1 -0.15 0.00 0.00 0.00 0.00 1.24

Rawah Wilderness CO MOZI1 0.10 0.00 0.00 0.00 0.00 0.79

Cape Romain SC ROMA1 0.70 0.00 0.00 0.00 0.01 4.61

Rocky Mountain NP CO ROMO1 0.02 0.00 0.00 0.00 0.00 1.09

Salt Creek NM SACR1 -0.31 0.00 0.00 0.00 0.00 4.53

St. Marks FL SAMA1 0.73 0.01 0.01 0.08 0.25 4.69

San Pedro Parks Wilderness NM SAPE1 -0.07 0.00 0.00 0.00 0.00 0.76

Shenandoah NP VA SHEN1 1.02 0.00 0.00 0.01 0.01 3.10

Shining Rock Wilderness NC SHRO1 0.77 0.01 0.01 0.02 0.02 3.78

Sipsey Wilderness AL SIPS1 0.90 0.00 0.01 0.04 0.07 5.41

Swanquarter NC SWAN1 0.67 0.00 0.01 0.01 0.01 3.64

Upper Buffalo Wilderness AR UPBU1 0.55 0.00 0.01 0.03 0.04 4.77

West Elk Wilderness CO WHRI1 0.09 0.00 0.00 0.00 0.00 0.39

Weminuche Wilderness CO WEMI1 -0.14 0.00 0.00 0.00 0.00 0.63

White Mountain Wilderness NM WHIT1 -0.21 0.00 0.00 0.00 0.00 2.04

Wheeler Peak Wilderness NM WHPE1 -0.15 0.00 0.00 0.00 0.00 1.24

Wichita Mountains OK WIMO1 0.29 0.00 0.00 0.00 0.00 3.88

Wolf Island GA OKEF1 0.51 0.00 0.00 0.01 0.04 5.31

NM = National Monument; NP = National Park.

H.7.3.2 Acid Deposition

The CAMx-predicted wet and dry fluxes of sulfur- and nitrogen-containing species were 

processed to estimate total annual sulfur and nitrogen deposition values at each Class I and 

sensitive Class II area in the 12/4-km modeling domain. As described in Section H.6.2.3.2, the 

maximum annual sulfur and nitrogen deposition values from any grid cell that intersects a Class I or 

sensitive Class II receptor area was used to represent deposition for that area, in addition to the 

average annual deposition values of all grid cells that intersect a Class I or sensitive Class II 

receptor area. Maximum and average predicted sulfur and nitrogen deposition impacts were 

estimated separately for each source group and together across all source groups. 

As a screening analysis, incremental deposition values in Class I/II areas for combined 

Source Groups A (new platforms associated with the 2017-2022 GOM Multisale EIS scenario) and B 

(new platforms and associated support vessels and helicopters associated with the 2017-2022 GOM 
Air Quality: Cumulative and Visibility Impacts H-135

Multisale EIS scenario) were compared to the eastern and western U.S. Deposition Analysis 

Thresholds (DATs) listed in Table H-32. These DATs are specified in the FLAG guidance25 and are 

further described in Section H.6.2.3.2 above. Results of the incremental deposition analysis are 

summarized in Table H-33 for Class I/II areas in the 4-km modeling domain. Deposition results 

were also obtained for all other sensitive areas throughout the 12 km-modeling domain, but the 

highest deposition values all occurred within the 4-km domain. The dividing line between the 

eastern and western DATs specified in the FLAG guidance is the Mississippi River, which makes 

sense for most locations in the U.S. but it is not necessarily clear which DAT would be most 

appropriate for coastal locations along the Gulf of Mexico so results are compared here against both 

DATs. Note that comparisons of deposition impacts from cumulative sources as represented by 

Source Groups C, D, E, and F to the DAT are not appropriate. Incremental nitrogen deposition 

exceeds the western and eastern DATs at all three locations. Incremental sulfur deposition is below 

the DATs in all cases except the sulfur deposition from Source Group B at Breton Wilderness and 

Gulf Islands National Seashore, which exceeds the western DAT but not the eastern DAT. 

Table H-32. Deposition Analysis Threshold Values (kg/ha/yr) as 

Defined in the Federal Land Manager Guidance 

(FLAG, 2010).

Nitrogen Sulfur

East 0.010 0.010

West 0.005 0.005

Table H-33. Incremental Deposition Impacts from Source Groups A and B at Class I and Sensitive 

Class II Areas in the 4-km Domain.

Area

Source Group A Source Group B

Nitrogen Sulfur Nitrogen Sulfur

Max Avg Max Avg Max Avg Max Avg

Breton 

Wilderness

Annual 

Deposition 0.0589 0.0501 0.0045 0.0039 0.3496 0.2701 0.0079 0.0061

Exceeds 

Eastern DAT? Yes Yes No No Yes Yes No No

Exceeds 

Western DAT? Yes Yes No No Yes Yes Yes Yes

Gulf Islands 

National 

Seashore

Annual 

Deposition 0.0909 0.0383 0.0046 0.0025 0.4560 0.2151 0.0064 0.0039

Exceeds 

Eastern DAT? Yes Yes No No Yes Yes No No

Exceeds 

Western 

DAT?

Yes Yes No No Yes Yes Yes No

 

25 Guidance on Nitrogen and Sulfur Deposition Analysis Thresholds (http://www.nature.nps.gov/air/Pubs/

pdf/flag/nsDATGuidance.pdf).
H-136 Gulf of Mexico Multisale EIS

Area

Source Group A Source Group B

Nitrogen Sulfur Nitrogen Sulfur

Max Avg Max Avg Max Avg Max Avg

Padre 

Island 

National 

Seashore

Annual 

Deposition 0.0458 0.0190 0.0012 0.0010 0.2410 0.1044 0.0019 0.0015

Exceeds 

Eastern DAT? Yes Yes No No Yes Yes No No

Exceeds 

Western DAT? Yes Yes No No Yes Yes No No

Cumulative deposition from all sources combined for the base case and future year 

scenarios were compared against applicable critical load levels in each Class I/II area for which 

critical loads were identified as described in Section H.6.2.3.2. Results are summarized in Table

H-34. Cumulative nitrogen deposition is projected to decrease in all areas between the 2012 base 

case and the 2017 future year, consistent with an overall reduction in NOx emissions. Nevertheless, 

maximum nitrogen deposition is modeled to continue exceeding the critical load thresholds under the 

future year scenario for all areas except the Padre Island National Seashore. Sulfur deposition 

values are lower, and larger sulfur emission reductions help to reduce sulfur deposition from above 

the critical load to below the critical load at Breton Wilderness, Breton National Wildlife Refuge, and 

Cohutta Wilderness (based on maximum grid cell values). Nevertheless, the maximum grid cell 

sulfur deposition still exceeds the critical load at the Gulf Islands National Seashore by a small 

margin. 

Table H-34. Cumulative Nitrogen (N) and Sulfur (S) Deposition Impacts (kg/ha/yr) under the Base and 

Future Year Scenarios (shading indicates values exceeding the Critical Load threshold).

Class I/II Area Critical Load 

Threshold

2012 Base Case 2017 Future Year

NMaxNAvgSMaxSAvgNMaxNAvgSMaxSAvg

Big Bend National Park 3 3.6 2.5 2.3 1.1 3.6 2.5 2.2 1.0

Breton Wilderness 3 7.8 7.1 4.1 3.6 7.7 6.9 2.8 2.5

Breton National Wildlife 

Refuge 3 7.2 6.9 3.7 3.5 7.0 6.7 2.6 2.4

Gulf Islands National 

Seashore 3 13.8 7.0 5.3 4.4 13.0 6.7 3.6 2.9

Padre Island National 

Seashore 5 4.5 2.2 1.5 1.2 4.6 2.2 1.1 0.9

Bradwell Bay Wilderness 5 6.5 6.2 2.5 2.3 6.0 5.8 1.8 1.7

Saint Marks National 

Wildlife Refuge 3 6.8 5.2 2.5 2.0 6.2 4.7 1.8 1.5

Saint Marks Wilderness 3 6.1 4.9 2.0 1.9 5.6 4.5 1.5 1.4

Chassahowitzka 

Wilderness 3 6.8 6.1 2.5 2.5 6.0 5.4 1.9 1.9

Everglades National Park 5 7.5 4.7 3.9 2.2 6.9 4.5 2.4 1.7

Okefenokee National 

Wildlife Refuge 3 6.0 5.7 2.3 2.1 5.6 5.3 1.8 1.7

Okefenokee Wilderness 3 6.5 5.5 2.6 2.1 6.1 5.1 2.1 1.7

Wolf Island Wilderness 3 3.3 3.1 2.1 2.0 3.0 2.8 1.5 1.4
Air Quality: Cumulative and Visibility Impacts H-137

Class I/II Area Critical Load 

Threshold

2012 Base Case 2017 Future Year

NMaxNAvgSMaxSAvgNMaxNAvgSMaxSAvg

Cohutta Wilderness 5 11.5 10.2 5.4 4.3 10.6 9.3 3.6 2.9

Sipsey Wilderness 5 9.4 9.0 3.2 3.2 9.1 8.6 2.1 2.1

Guadalupe Mountains 

National Park 3 3.3 2.6 1.1 0.7 3.2 2.5 0.9 0.6

Wichita Mountains 

(Charons Garden Unit) 

Wilderness

5 5.6 5.6 1.7 1.7 5.4 5.4 1.5 1.5

Wichita Mountains (North 

Mountain Unit) Wilderness 5 6.3 6.3 1.8 1.8 6.1 6.1 1.5 1.5

Wichita Mountains National 

Wildlife Refuge 5 6.5 6.0 1.8 1.7 6.2 5.8 1.5 1.5

Caney Creek Wilderness 5 9.3 9.2 3.7 3.6 9.1 9.0 2.3 2.3

Upper Buffalo Wilderness 5 7.4 7.4 2.5 2.5 7.1 7.1 1.7 1.7

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APPENDIX I 

 

SPECIES NOT CONSIDERED FURTHER

Species Not Considered Further I-3 

I SPECIES NOT CONSIDERED FURTHER

Common Name Scientific Name

Mammals

Bats

Florida bonneted bat Eumops floridanus

Gray bat Myotis grisescens

Indiana bat Myotis sodalis

Rodents

Anastasia Island beach mouse Peromyscus polionotus phasma

Florida salt marsh vole Microtus pennsylvanicus dukecampbelli

Key Largo cotton mouse Peromyscus gossypinus allapaticola

Key Largo woodrat Neotoma floridana smalli

Rice rat Oryzomys palustris natator

Santa Rosa beach mouse Peromyscus polionotus leucocephalus

Southeastern beach mouse Peromyscus polionotus niveiventris

Other Mammals

Florida panther Puma concolor coryi

Gulf Coast jaguarundi Herpailurus yagouaroundi cacomitli

Key deer Odocoileus virginianus clavium

Louisiana black bear Ursus americanus luteolus

Lower Keys marsh rabbit Sylvilagus palustris hefneri

Ocelot Leopardus pardalis

Puma Puma concolor (all subspecies except coryi)

Birds

Attwater's greater prairie-chicken Tympanuchus cupido attwateri

Audubon's crested caracara Polyborus plancus audubonii

Bachman's warbler Vermivora bachmanii

Ivory-billed woodpecker Campephilus principalis

Everglade snail kite Rostrhamus sociabilis plumbeus

Florida grasshopper sparrow Ammodramus savannarum floridanus

Florida scrub-jay Aphelocoma coerulescens

Kirtland's warbler Setophaga kirtlandii

Least tern Sterna antillarum

Northern aplomado falcon Falco femoralis septentrionalis

Red-cockaded woodpecker Picoides borealis

Red crowned parrot Amazona viridigenalis

Sprague's pipit Anthus spragueii
I-4 Gulf of Mexico Multisale EIS

Common Name Scientific Name

Reptiles

Alabama red-belly turtle Pseudemys alabamensis

American alligator Alligator mississippiensis

American crocodile Crocodylus acutus

Atlantic salt marsh snake Nerodia clarkii taeniata

Black pine snake Pituophis melanoleucus lodingi

Eastern indigo snake Drymarchon corais couperi

Gopher tortoise Gopherus polyphemus

Ringed map turtle Graptemys oculifera

Sand skink Neoseps reynoldsi

Yellow-blotched map turtle Graptemys flavimaculata

Amphibians

Dusky gopher frog Rana sevosa

Frosted flatwoods salamander Ambystoma cingulatum

Reticulated flatwoods salamander Ambystoma bishopi

Striped newt Notophthalmus perstriatus

Fishes

Alabama shad Alosa alabamae

Alabama sturgeon Scaphirhynchus suttkusi

Atlantic sturgeon Acipenser oxyrinchus oxyrinchus

Caribbean electric ray Narcine bancroftii

Dusky shark Carcharhinus obscurus

Gulf sturgeon Acipenser oxyrinchus desotoi

Key silverside Menidia conchorum

Largetooth sawfish Pristis pristis

Nassau grouper Epinephelus striatus

Okaloosa darter Etheostoma okaloosae

Opossum pipefish Microphis brachyurus lineatus

Pallid sturgeon Scaphirhynchus albus

Pearl darter Percina aurora

Sand tiger shark Charcharias taurus

Shortnose sturgeon Acipenser brevirostrum

Smalltooth sawfish Pristis pectinata

Speckled hind (grouper) Epinephelus drummondhayi

Warsaw grouper Epinephelus nigritus
I-5 Gulf of Mexico Multisale EIS

Common Name Scientific Name

Invertebrates

Coral

Ivory tree coral Oculina varicosa 

Pillar coral Dendrogyra cylindrus

Rough cactus coral Mycetophyllia ferox

Clams

Alabama heelsplitter Potamilus inflatus

Chipola slabshell Elliptio chipolaensis

Choctaw bean Villosa choctawensis

Fat threeridge Amblema neislerii

Fuzzy pigtoe Pleurobema strodeanum

Golden orb Quadrula aurea

Gulf moccasinshell Medionidus penicillatus

Narrow pigtoe Fusconaia escambia

Ochlockonee moccasinshell Medionidus simpsonianus

Oval pigtoe Pleurobema pyriforme

Purple bankclimber Elliptoideus sloatianus

Round ebonyshell Fusconaia rotulata

Shinyrayed pocketbook Lampsilis subangulata

Smooth pimpleback Quadrula houstonensis

Southern kidneyshell Ptychobranchus jonesi

Southern sandshell Hamiota australis

Tapered pigtoe Fusconaia burkei

Texas fawnsfoot Truncilla macrodon

Texas pimpleback Quadrula petrina

Snails

Stock Island tree snail Orthalicus reses

Insects

Bartram's hairstreak butterfly Strymon acis bartrami

Florida leafwing butterfly Anaea troglodyta floridalis

Miami blue butterfly Cyclargus thomasi bethunebakeri

Schaus swallowtail butterfly Heraclides aristodemus ponceanus

Fungi

Florida perforate cladonia Cladonia perforata
I-6 Gulf of Mexico Multisale EIS

Common Name Scientific Name

Plants

Ferns and Allies

Florida bristle fern Trichomanes punctatum ssp. floridanum

Louisiana quillwort Isoetes louisianensis

Conifers and Cycads

Florida torreya Torreya taxifolia

Flowering Plants

Aboriginal prickly-apple Harrisia aboriginum

American chaffseed Schwalbea americana

Apalachicola rosemary Conradina glabra

Beach jacquemontia Jacquemontia reclinata

Beautiful pawpaw Deeringothamnus pulchellus

Big pine partridge pea Chamaecrista lineata keyensis

Black lace cactus Echinocereus reichenbachii var. albertii

Blodgett's silverbush Argythamnia blodgettii

Britton's beargrass Nolina brittoniana

Brooksville bellflower Campanula robinsiae

Cape Sable thoroughwort Chromolaena frustrata

Carter's small-flowered flax Linum carteri carteri

Carter's mustard Warea carteri

Chapman rhododendron Rhododendron chapmanii

Cooley's meadowrue Thalictrum cooleyi

Cooley's water-willow Justicia cooleyi

Crenulate lead-plant Amorpha crenulata

Deltoid spurge Chamaesyce deltoidea ssp. Deltoidea

Etonia rosemary Conradina etonia

Everglades bully Sideroxylon reclinatum ssp. austrofloridense

Florida golden aster Chrysopsis floridana

Florida pineland crabgrass Digitaria pauciflora

Florida semaphore cactus Consolea corallicola

Florida bonamia Bonamia grandiflora

Florida brickell-bush Brickellia mosieri

Florida prairie-clover Dalea carthagenensis floridana

Florida skullcap Scutellaria floridana

Four-petal pawpaw Asimina tetramera

Fragrant prickly-apple Cereus eriophorus var. fragrans

Garber's spurge Chamaesyce garberi
I-7 Gulf of Mexico Multisale EIS

Common Name Scientific Name

Flowering Plants (continued)

Gentian pinkroot Spigelia gentianoides

Godfrey's butterwort Pinguicula ionantha

Harper's beauty Harperocallis flava

Johnson's seagrass Halophila johnsonii

Key tree cactus Pilosocereus robinii

Lakela's mint Dicerandra immaculata

Lewton's polygala Polygala lewtonii

Longspurred mint Dicerandra cornutissima

Miccosukee gooseberry Ribes echinellum

Okeechobee gourd Cucurbita okeechobeensis ssp. okeechobeensis

Papery whitlow-wort Paronychia chartacea

pigeon wings Clitoria fragrans

pineland sandmat Chamaesyce deltoidea pinetorum

Pygmy fringe-tree Chionanthus pygmaeus

Rugel's pawpaw Deeringothamnus rugelii

Sand flax Linum arenicola

Scrub buckwheat Eriogonum longifolium var. gnaphalifolium

Scrub plum Prunus geniculata

Slender rush-pea Hoffmannseggia tenella

Small's milkpea Galactia smallii

South Texas ambrosia Ambrosia cheiranthifolia

Telephus spurge Euphorbia telephioides

Texas prairie dawn-flower Hymenoxys texana

Texas ayenia Ayenia limitaris

Tiny polygala Polygala smallii

Wedge spurge Chamaesyce deltoidea serpyllum

White birds-in-a-nest Macbridea alba

Wide-leaf warea Warea amplexifolia

APPENDIX J 

 

STATE COASTAL MANAGEMENT PROGRAMS

State Coastal Management Programs J-3 

J STATE COASTAL MANAGEMENT PROGRAMS

Each State’s Coastal Management Program (CMP), federally approved by the National 

Oceanic and Atmospheric Administration (NOAA), is a comprehensive statement setting forth 

objectives, enforceable policies or guidelines, and standards for public and private use of land and 

water resources and uses in that State’s coastal zone. The program provides for direct State land 

and water use planning and regulations. The plan also includes a definition of what constitutes 

permissible land uses and water uses. Federal consistency is the Coastal Zone Management Act 

(CZMA) requirement where Federal agency activities that have reasonably foreseeable effects on 

any land or water use or natural resource of the coastal zone must be consistent to the maximum 

extent practicable with the enforceable policies or guidelines of a coastal state’s federally approved 

coastal management program. The latest Federal consistency regulations concerning State coastal 

zone management (CZM) programs are found in the Federal Register (2000 and 2006).

Each Gulf States’ official coastal boundary can be identified from NOAA’s website at 

https://coast.noaa.gov/czm/media/StateCZBoundaries.pdf. Once a State’s CMP is federally 

approved, Federal agencies must ensure that their actions are consistent to the maximum extent 

practicable with the enforceable polices of the approved program. Federal agencies provide 

feedback to the States through each Section 312 evaluation conducted by NOAA.

To ensure conformance with State CMP policies or guidelines and local land use plans, the 

Bureau of Ocean Management (BOEM) prepares a Federal consistency determination for each 

proposed Outer Continental Shelf (OCS) lease sale. Through the designated State CZM agency, 

local land use entities are provided numerous opportunities to comment on the OCS Program. Local 

land-use agencies also have the opportunity to comment directly to BOEM at any time, as well as 

during formal public comment periods related to the announcement of the Five-Year Program, Call

for Information/Notice of Intent, environmental impact statement (EIS) scoping, public hearings on 

the Draft EIS, and the Proposed Notice of Sale.

A State’s approved CMP may also provide for the State’s review of OCS plans, permits, and 

license activities to determine whether they will be conducted in a manner consistent with the State’s 

CMP. This review authority is applicable to activities conducted in any area that has been leased 

under the OCS Lands Act (OCSLA) and that affect any land or water use or natural resource within 

the State’s coastal zone (16 U.S.C. § 1456(c)(3)(B)).

State of Texas Coastal Management Program

The Texas Coastal Management Program (TCMP) Final EIS was published in August 1996. 

On December 23, 1996, NOAA approved the TCMP, and the requirements therein were made 

operational as of January 10, 1997. The TCMP is based primarily on the Coastal Coordination Act 

(CCA) of 1991 (33 Tex. Nat. Res. Code Ann. Ch. 201 et seq.), as amended by House Bill 3226 

(1995), which calls for the development of a comprehensive coastal program based on existing 

statutes and regulations. The CCA established the geographic scope of the program by identifying 

the program’s inland, interstate, and seaward boundaries. The program’s seaward boundary is the 
J-4 Gulf of Mexico Multisale EIS

State’s territorial seaward limit (3 leagues or 10.36 miles or 16.67 kilometers). The State’s inland 

boundary is based on the State’s Coastal Facilities Designation Line (CFDL). The CFDL was 

developed in response to the Oil Pollution Act of 1990 and basically delineates those areas within 

which oil spills could affect coastal waters or resources. For the purposes of the TCMP, the CFDL 

has been modified to capture wetlands in upper reaches of tidal waters. The geographic scope also 

extends upstream 200 miles (322 kilometers) from the mouths of rivers draining into coastal bays 

and estuaries in order to manage water appropriations on those rivers. The program’s boundaries 

encompass all or portions of 18 coastal counties (including Cameron, Willacy, Kenedy, Kleberg, 

Nueces, San Patricio, Aransas, Refugio, Calhoun, Victoria, Jackson, Matagorda, Brazoria, 

Galveston, Harris, Chambers, Jefferson, and Orange Counties), roughly 8.9 million acres (3.6 million 

hectares) of land and water.

Within this coastal zone boundary, the scope of the TCMP’s regulatory program is focused 

on the direct management of 16 generic “Areas of Particular Concern,” called coastal natural 

resource areas (CNRAs). These CNRAs are associated with valuable coastal resources or 

vulnerable or unique coastal areas and include the following: waters of the open Gulf of Mexico 

(GOM); waters under tidal influence; submerged lands; coastal wetlands; seagrasses; tidal sand and 

mud flats; oyster reefs; hard substrate reefs; coastal barriers; coastal shore areas; GOM beaches; 

critical dune areas; special hazard areas; critical erosion areas; coastal historic areas; and coastal 

preserves.

The State has designated the Western Planning Area (WPA) as the geographical area in 

which Federal consistency shall apply outside of the coastal boundary. The TCMP also identifies 

Federal lands excluded from the State’s coastal zone, such as U.S. Department of Defense facilities 

and wildlife refuges.

Land and water uses subject to the program generally include the siting, construction, and 

maintenance of electric generating and transmission facilities; oil and gas exploration and 

production; and the siting, construction, and maintenance of residential, commercial, and industrial 

development on beaches, critical dune areas, shorelines, and within or adjacent to critical areas and 

other CNRAs. Associated activities also subject to the program include canal dredging; filling; 

placement of structures for shoreline access and shoreline protection; on-site sewage disposal, 

storm-water control, and waste management for local governments and municipalities; the siting, 

construction, and maintenance of public buildings and public works such as dams, reservoirs, and 

flood control projects and associated activities; the siting, construction, and maintenance of roads, 

highways, bridges, causeways, airports, railroads, and nonenergy transmission lines and associated 

activities; certain agricultural and silvicultural activities; water impoundments and diversions; and the 

siting, construction, and maintenance of marinas, State-owned fishing cabins, artificial reefs, public 

recreational facilities, structures for shoreline access and shoreline protection, boat ramps, and 

fishery management measures in the GOM. 

The TCMP is a networked program that is implemented primarily through 8 State agencies, 

18 local governments, and the Coastal Coordination Advisory Committee (Committee). The 
State Coastal Management Programs J-5 

program relies primarily on direct State control of land and water uses, although local governments 

will implement State guidelines related to beach and dune management. Implementation and 

enforcement of the coastal policies is primarily the responsibility of the networked agencies and local 

governments through their existing statutes, regulatory programs, or other authorizations. 

Networked agencies include the General Land Office/School Land Board, Texas Commission on 

Environmental Quality, Railroad Commission of Texas, Texas Parks and Wildlife Commission, Texas 

Department of Transportation, Texas Water Development Board, Texas State Soil and Water 

Conservation Board, and the Texas Sea Grant College Program at Texas A&M University. Other 

members on the Council include four gubernatorial appointees: (1) a coastal business 

representative; (2) an agriculture representative; (3) a local elected official; and (4) a coastal citizen. 

Similarly, 18 county and municipal governments, in those counties with barrier islands, are also 

networked entities with responsibilities for program implementation vis-a-vis beaches and dunes.

Regulations, programs, and expertise of State, Federal, and local government entities are 

linked to the management of Texas CNRAs in the TCMP. Local governments are notified of relevant 

TCMP decisions, including those that may conflict with local land-use plans or zoning ordinances. 

The Committee includes a local government representative as a full-voting member. An additional 

local government representative can be added to the Committee as a non-voting member for special 

local matters under review. The Committee established a permanent advisory committee to ensure 

effective communication for local governments with land-use authority.

In 1994, this Agency entered into a Memorandum of Understanding (MOU) with the Texas 

General Land Office to address similar mineral resource management responsibilities between the 

two entities and to encourage cooperative efforts and promote consistent regulatory practices. This 

MOU, which encompasses a broad range of issues and processes, outlines the responsibilities and 

cooperative efforts, including leasing and CZMA review processes, agreed to by the respective 

agencies. Effective January 10, 1997, all operators were required to submit to BOEM certificates of 

consistency with the TCMP for proposed operations in the WPA.

This Agency developed coordination procedures with the State for submittal of offshore lease 

sale consistency determinations and plans of operation. The WPA Lease Sale 168 was this 

Agency’s first Federal action subject to State consistency review. This Agency and the State of 

Texas revised CZM consistency information for OCS plans, permits, and licenses to conform to the 

revised CZM regulations that were effective January 8, 2001, and updated on January 5, 2006, and 

have also incorporated streamlining improvements into the latest Notices to Lessees and Operators 

(NTLs) (NTLs 2008-G04, 2009-G27, and 2015-BOEM-N01). The State of Texas requires an 

adequate description, objective, and schedule for the project; site-specific information on the 

onshore support base, support vessels, shallow hazards, oil-spill response, wastes and discharges, 

transportation activities, and air emissions; and a Federal consistency certification, assessment, and 

findings. The State’s requirements for Federal consistency review are based specifically on U.S. 

Department of the Interior’s (DOI’s) regulations at 30 CFR parts 250, 254, 256, and 550, and 

NOAA’s Federal consistency regulations at 15 CFR part 930. This Agency will be continuing a 

dialogue with the State of Texas on reasonably foreseeable coastal effects for pipelines and other 
J-6 Gulf of Mexico Multisale EIS

permits, and the result of these discussions will be incorporated into future updates of this Agency’s 

NTLs and/permitting procedures.

State of Louisiana, Office of Coastal Management

The statutory authority for Louisiana's coastal zone management program, the Louisiana 

Office of Coastal Management (LOCM), is the State and Local Coastal Resources Management Act 

of 1978 et seq. (Louisiana Administrative Code, Volume 17, Title 43, Chapter 7, Coastal 

Management, June 1990 revised). The State statute puts into effect a set of State coastal policies 

and coastal use guidelines that apply to coastal land and water use decisionmaking. A number of 

existing State regulations are also incorporated into the program, including those concerning oil and 

gas and other mineral operations; leasing of State lands for mineral operations and other purposes; 

hazardous waste and radioactive materials; management of wildlife, fish, other aquatic life, and 

oyster beds; endangered species; air and water quality; and the Louisiana Superport.

The State statute also authorized establishment of Special Management Areas. Included as 

Special Management Areas are the Louisiana Offshore Oil Port (LOOP) and the Marsh Island

Wildlife Refuge. For purposes of the CZMA, only that portion of LOOP within Louisiana’s coastal 

zone is part of the Special Management Area. In April 1989, the Louisiana Legislature created the 

Wetlands Conservation and Restoration Authority and established a Wetlands Conservation and 

Restoration Trust Fund to underwrite restoration projects. The Legislature also reorganized part of 

the Louisiana Department of Natural Resources (LDNR) by creating the Office of Coastal 

Restoration and Management.

Local governments (parishes) may assume management of uses of local concern by 

developing a local coastal program consistent with the State CMP. The State of Louisiana has 

10 approved local coastal management programs (Calcasieu, Cameron, Jefferson, Lafourche, 

Orleans, St. Bernard, St. James, Plaquemines, Terrebonne, and St. Tammany Parishes). In 

addition, two additional parishes, St. John the Baptist and St. Charles, have worked towards 

developing local coastal management programs. Eight other programs (Assumption, Iberia, 

Livingston, St. Charles, St. Martin, St. Mary, Tangipahoa, and Vermilion Parishes) have not been 

formally approved by NOAA. The parish planning and/or permits offices often serve as the 

permitting agency for projects limited to local concern. Parish-level programs, in addition to issuing 

permits for uses of local concern, also function as a commenting agency to Louisiana’s CZM 

agency, the LOCM, regarding permitting of uses of State concern.

Appendix C2 of the LOCM outlines the rules and procedures for the State’s local CMP. 

Under the LOCM, parishes are authorized, though not required, to develop local CMPs. Approval of 

these programs gives parishes greater authority in regulating coastal development projects that 

entail uses of local concern. Priorities, objectives, and policies or guidelines of local land use plans 

must be consistent with the policies and objectives of Act 361, the LOCM, and the State guidelines, 

except for a variance adopted in Section IV.D of Appendix C2 of the LOCM. The Secretaries of 

LDNR and Wildlife and Fisheries may jointly rule on an inconsistent local program based on local 
State Coastal Management Programs J-7 

environmental conditions or user practices. State and Federal agencies review parish programs 

before they are adopted.

The coastal use guidelines are based on seven general policies or guidelines. State 

concerns that could be relevant to an OCS lease sale and its possible direct effects or associated 

facilities and nonassociated facilities are (a) any dredge and fill activity that intersects more than one 

waterbody, (b) projects involving the use of State-owned lands or water bottoms, (c) national interest 

projects, (d) pipelines, and (e) energy facility siting and development. Some coastal activities of 

concern that could be relevant to a lease sale include wetland loss due to channel erosion from OCS 

traffic; activities near reefs and topographic highs; activities that might affect endangered, 

threatened, or commercially valuable wildlife; and potential socioeconomic impacts due to offshore 

development. Secondary and cumulative impacts to coastal resources such as onshore facility 

development, cumulative impacts from infrastructure development, salt intrusion along navigation 

channels, etc. are also of particular concern.

Effective August 1993, the LOCM required that any entity applying for permits to conduct 

activities along the coast must notify the landowner of the proposed activity. An affidavit must also 

accompany any permit application. Through this regulation, the State strives to minimize coastal 

zone conflicts.

This Agency and the State of Louisiana revised CZM consistency information for OCS plans, 

permits, and licenses to conform to the revised CZM regulations that were effective January 8, 2001, 

and updated on January 5, 2006, and have also incorporated streamlining improvements into the 

latest NTLs (NTLs 2008-G04, 2009-G27, and 2015-BOEM-N01). Federal consistency for 

right-of-way (ROW) pipelines is addressed in NTL 2007-G20. The State of Louisiana requires an 

adequate description, objective, and schedule for the project. Also, the State requires site-specific 

information on the onshore support base, support vessels, shallow hazards, oil-spill response, 

wastes and discharges (including any disposal of wastes within the State coastal zone and waters 

and municipal, parish, or State facilities to be used), transportation activities, air emissions, and 

secondary and cumulative impacts; and a Federal consistency certification, assessment, and 

findings. In addition, the State receives consistency reviews on a case-by-case basis for 

decommissioning activities within OCS Significant Sediment Blocks that the State utilizes marine 

mineral resources for restoration projects. The State requirements for Federal consistency review 

are based specifically on DOI’s regulations at 30 CFR parts 250, 254, 256, and 550, and NOAA’s 

Federal consistency regulations at 15 CFR part 930. BOEM is continuing a dialogue with the State 

of Louisiana on reasonably foreseeable coastal effects associated with pipelines and other permits, 

and the result of these discussions will be incorporated into future updates of the Bureau of Ocean 

Energy Management’s NTLs and/or permitting procedures.

State of Mississippi Coastal Program

The Mississippi Coastal Program (MCP) is administered by the Mississippi Department of 

Marine Resources. The MCP is built around several enforceable goals that promote comprehensive 
J-8 Gulf of Mexico Multisale EIS

management of coastal resources and encourage a balance between environmental protection/

preservation and development in the coastal zone. The primary coastal management statute is the 

Coastal Wetlands Protection Law. Other major features of the MCP include statutes related to 

fisheries, air and water pollution control, surface and groundwater, cultural resources, and the 

disposal of solid waste in marine waters. The Department of Marine Resources, the Department of 

Environmental Quality, and the Department of Archives and History are identified collectively as the 

“coastal program agencies.” Mississippi manages coastal resources by regulation and by promoting 

activities that use resources in compliance with the MCP. The State developed a coastal wetlands 

use plan, which includes designated use districts in coastal wetlands and Special Management Area 

Plans that steer development away from fragile coastal resources and help to resolve user conflicts.

For the purposes of the coastal program, the coastal zone encompasses the three coastal 

counties of Hancock, Harrison, and Jackson and all coastal waters. The Mississippi coast has 

359 miles (594 kilometers) of shoreline, including the coastlines of offshore barrier islands (Cat, 

Ship, Horn, and Petit Bois Islands). According to NOAA, there are no approved local CMPs for the 

State of Mississippi. The Southern Mississippi Planning and Development District serves in an 

advisory capacity to the State coastal agencies.

This Agency developed coordination procedures with the State for submittal of offshore lease 

sale consistency determinations and plans of operation. This Agency and the State of Mississippi 

revised CZM consistency information for OCS plans, permits and licenses to conform to the revised 

CZM regulations that were effective January 8, 2001, and updated on January 5, 2006, and have 

also incorporated streamlining improvements into the latest NTLs (NTLs 2008-G04, 2009-G27, and 

2015-BOEM-N01). Federal consistency for ROW pipelines is addressed in NTL 2007-G20. The 

State of Mississippi requires an adequate description, objective, and schedule for the project; sitespecific information on the onshore support base, support vessels, shallow hazards, oil-spill 

response, wastes and discharges, transportation activities, and air emissions; and a Federal 

consistency certification, assessment, and findings. The State requirements for Federal consistency 

review are based specifically on DOI’s regulations at 30 CFR parts 250, 254, 256, and 550, and 

NOAA’s Federal consistency requirements at 15 CFR part 930. BOEM is continuing a dialogue with 

the State of Mississippi on reasonably foreseeable coastal effects associated with pipelines and 

other permits, and the result of these discussions will be incorporated into future updates of the 

Bureau of Ocean Energy Management’s NTLs and/or permitting procedures.

State of Alabama Coastal Area Management Program

The Alabama Coastal Area Act (ACAA) provides statutory authority to review all coastal 

resource uses and activities that have a direct and significant effect on the coastal area. The 

Alabama Department of Conservation and Natural Resources (ADCNR) Lands Division, Coastal 

Section Office, the lead coastal management agency, is responsible for the management of the 

State’s coastal resources through the Alabama Coastal Area Management Program (ACAMP). The 

ADCNR is responsible for the overall management of the program, including fiscal and grants 

management and public education and information. The department also provides planning and 
State Coastal Management Programs J-9 

technical assistance to local governments and financial assistance to research facilities and units of 

local government when appropriate. The State Lands Division, Coastal Section, also has authority 

over submerged lands in regard to piers, marinas, bulkheads, and submerged land leases.

The Alabama Department of Environmental Management (ADEM) is responsible for coastal 

area permitting, regulatory, and enforcement functions. Most programs of ADCNR Coastal Section 

that require environmental permits or enforcement functions are carried out by the ADEM with the 

exception of submerged land issues. The ADEM has the responsibility of all permit, enforcement, 

regulatory, and monitoring activities, and the adoption of rules and regulations to carry out the 

ACAMP. The ADEM must identify specific uses or activities that require a State permit to be 

consistent with the coastal policies noted above and the more detailed rules and regulations 

promulgated as part of the ACAMP. Under the ACAA, State agency activities must be consistent 

with ACAMP policies and ADEM findings. Further, ADEM must make a direct permit-type review for 

uses that are not otherwise regulated at the State level. The ADEM also has authority to review 

local government actions and to assure that local governments do not unreasonably restrict or 

exclude uses of regional benefit. Ports and major energy facilities are designated as uses of 

regional benefit. The ADCNR Lands Division manages all lease sales of State submerged 

bottomlands and regulates structures placed on State submerged bottomlands.

Local governments have the option to participate in the ACAMP by developing local codes, 

regulations, rules, ordinances, plans, maps, or any other device used to issue permits or licenses. If 

these instruments are certified to be consistent with ACAMP, ADEM may allow the local government 

to administer them by delegating its permit authority, thereby eliminating the need for ADEM’s 

case-by-case review.

The South Alabama Regional Planning Commission provides ongoing technical assistance 

to ADCNR for Federal consistency, clearinghouse review, and public participation procedures. Uses 

subject to the Alabama’s CZM program are divided into regulated and nonregulated categories. 

Regulated uses are those that have a direct and significant impact on the coastal areas. These uses 

either require a State permit or are required by Federal law to be consistent with the management 

program. Uses that require a State permit must receive a certificate of compliance. Nonregulated 

uses are those activities that have a direct and significant impact on the coastal areas that do not 

require a State permit or Federal consistency certification. Nonregulated uses must be consistent 

with ACAMP and require local permits to be administered by ADEM.

This Agency developed coordination procedures with the State for submittal of offshore lease 

sale consistency determinations and plans of operation. This Agency and the State of Alabama 

have revised CZM consistency information for OCS plans, permits, and licenses to conform to the 

revised CZM regulations that were effective January 8, 2001, and updated on January 5, 2006, and 

have also incorporated streamlining improvements into the latest NTLs (NTLs 2008-G04, 2009-G27, 

and 2015-BOEM-N01). Federal consistency for ROW pipelines is addressed in NTL 2007-G20. The 

State of Alabama requires an adequate description, objective, and schedule for the project; sitespecific information on the onshore support base, support vessels, shallow hazards, oil-spill 
J-10 Gulf of Mexico Multisale EIS

response, wastes and discharges, transportation activities, and air emissions; and a Federal 

consistency certification, assessment, and findings. The State’s requirements for Federal 

consistency review are based specifically on DOI’s regulations at 30 CFR parts 250, 254, 256, and 

550, and NOAA’s Federal consistency requirements at 15 CFR part 930. BOEM is continuing a 

dialogue with the State of Alabama on reasonably foreseeable coastal effects associated with

pipelines and other permits, and the result of these discussions will be incorporated into future 

updates of Bureau of Ocean Energy Management’s NTLs and/or permitting procedures.

State of Florida Coastal Management Program

For purposes of the CZMA, the State of Florida’s coastal zone includes the area 

encompassed by the State’s 67 counties and its territorial seas. Lands owned by the Federal 

Government and the Seminole and Miccosukee Indian tribes are not included in the State’s coastal 

zone; however, Federal activities in or outside the coastal zone, including those on Federal or Tribal 

lands, that affect any land or water or natural resource of the State’s coastal zone are subject to 

review by Florida under the CZMA. The Florida Coastal Management Act, codified as Chapter 380, 

Part II, Florida Statutes, authorized the development of a coastal management program. In 1981, 

the Florida Coastal Management Program (FCMP) was approved by NOAA.

The policies identified by the State of Florida as being enforceable in the FCMP are the 

24 chapters that NOAA approved for incorporation in the State’s program. The 2011 Florida 

Statutes are the most recent version approved by NOAA and include the listing of OCSLA permits 

under Subpart E and the addition of draft EAs and EISs as necessary data and information for 

Federal consistency review

A network of eight State agencies and five regional water management districts implement 

the FCMP’s 24 statutes. The water management districts are responsible for water quantity and 

quality throughout the State’s watersheds. The State agencies include the following: the 

Department of Environmental Protection (DEP), the lead agency for the FCMP and the State’s chief 

environmental regulatory agency and steward of its natural resources; the Department of Community 

Affairs, which serves as the State’s land planning and emergency management agency; the 

Department of Health, which, among other responsibilities, regulates on-site sewage disposal; the 

Department of State, Division of Historical Resources, which protects historic and archaeological 

resources; the Fish and Wildlife Conservation Commission, which protects and regulates fresh and 

saltwater fisheries, marine mammals, and birds and upland species, including protected species and 

the habitat used by these species; the Department of Transportation, which is charged with the 

development, maintenance, and protection of the transportation system; the Department of 

Agriculture and Consumer Services, which manages State forests and administers aquaculture and 

mosquito control programs; and the Governor’s Office of Planning and Budget, which plays a role in 

the comprehensive planning process.

Effective July 1, 2000, the Governor of Florida assigned the State’s responsibilities under the 

OCSLA to the Secretary of the Florida DEP. The DEP’s Office of Intergovernmental Programs 
State Coastal Management Programs J-11

coordinates the review of OCS plans with FCMP member agencies to ensure that the plan is 

consistent with applicable State enforceable policies and the Governor’s responsibilities under the 

Act.

This Agency developed coordination procedures with the State for the submittal of offshore 

lease sale consistency determinations and plans of operation. In 2003, this Agency and the State 

revised CZM consistency information for OCS plans, permits, and licenses to conform with the 

revised CZM regulations that were effective on January 8, 2001, and updated on January 5, 2006, 

and they have also incorporated streamlining improvements into the latest NTLs (NTLs 2008-G04, 

2009-G27, and 2015-BOEM-N01). Federal consistency for ROW pipelines is addressed in NTL 

2007-G20. 

The State of Florida requires an adequate description, objective, and schedule for all 

activities associated with a project; specific information on the natural resources potentially affected 

by the proposed activities; and specific information on onshore support base, support vessels, 

shallow hazards, oil-spill response, wastes and discharges, transportation activities, and air 

emissions; and a Federal consistency certification, assessment, and findings. As identified by the 

State of Florida, the State enforceable policies that must be addressed for OCS oil- and gas-related 

activities are found at http://www.boem.gov/CZM-Program-Policies-for-GOM-States.aspx. These 

requirements have been incorporated into the Plans and Regional Oil-Spill Response NTLs. The 

State requirements for Federal consistency review are based on the requirements of State statutes, 

CZMA regulations at 15 CFR part 930, and DOI’s regulations at 30 CFR parts 250, 254, 256, and 

550. BOEM is continuing a dialog with the State of Florida on reasonably foreseeable coastal 

effects associated with OCS plans, pipelines, and other permits; the result of these discussions will 

be incorporated into future updates of the Bureau of Ocean Energy Management’s NTLs and/or 

permitting procedures.

REFERENCES

Federal Register. 2000. Coastal Zone Management Act federal consistency regulations. Final rule. 

65 FR 237, pp. 77124-77175, December 8, 2000.

Federal Register. 2006. Coastal Zone Management Act federal consistency regulations. Final rule. 

71 FR 3, pp. 788-831, January 5, 2006.

APPENDIX K 

 

CONSULTATION CORRESPONDENCE

Consultation Correspondence K-3 

K CONSULTATION CORRESPONDENCE
K-4 Gulf of Mexico Multisale EIS
Consultation Correspondence K-5 
K-6 Gulf of Mexico Multisale EIS
Consultation Correspondence K-7 
K-8 Gulf of Mexico Multisale EIS
Consultation Correspondence K-9 
K-10 Gulf of Mexico Multisale EIS
Consultation Correspondence K-11
K-12 Gulf of Mexico Multisale EIS
Consultation Correspondence K-13
K-14 Gulf of Mexico Multisale EIS
Consultation Correspondence K-15
K-16 Gulf of Mexico Multisale EIS
Consultation Correspondence K-17
K-18 Gulf of Mexico Multisale EIS
APPENDIX L 

RESPONSES TO PUBLIC COMMENTS 

ON THE DRAFT MULTISALE EIS

Responses to Public Comments on the Draft Multisale EIS L-3 

L RESPONSES TO PUBLIC COMMENTS ON THE DRAFT MULTISALE 

EIS

All comments (i.e., letters, public meeting transcripts, emails, etc.) were analyzed to identify 

all substantive issues raised by the public. Each substantive issue within an individual’s comment 

was assigned a unique identifier. For example, the first substantive comment from the American 

Petroleum Institute was assigned API-1. Comments were then grouped by similar issues into 

10 major categories, and responses are provided for each issue. The comments were reproduced 

verbatim as they were received. When similar issues were raised by several commenters, a single 

response has been provided for multiple comments. The comments and responses are presented in 

a matrix (Table L-1) and are organized by the following 10 topics: Topic 1–NEPA Process and 

Public Involvement; Topic 2–NEPA Analysis; Topic 3–Alternatives; Topic 4–Environmental Issues 

and Concerns; Topic 5–Cumulative Analysis; Topic 6–Oil Spills; Topic 7–Mitigation; Topic 8–

Regulations and Safety; Topic 9–Statutory Compliance; and Topic 10–Other. Some topics include 

subtopics to further group similar comments. Topic 3 includes a subtopic on stated preference for 

those commenters who stated a preference for a particular alternative. Topic 4 has 15 subtopics 

(i.e., Climate Change, Greenhouse Gases, Well Stimulation, Renewable Energy and Alternative 

Uses of the OCS, Natural Stressors, Air Quality, Coastal Habitats, Biologically Sensitive Areas, Fish 

and Invertebrates, Birds and Protected Birds, Marine Mammals, Sea Turtles, Infrastructure, 

Socioeconomics, and Environmental Justice) to separate the various environmental issues and 

concerns raised by commenters.

An index of comments, which is organized by topic and commenter, can be found below. An 

individual or group can search by name to more quickly find BOEM’s response. All comment letters, 

emails, and public meeting transcripts, along with their respective unique identifiers, are reproduced 

in their entirety following the matrix and references. 

Topic 1 – NEPA Process and Public Involvement

• American Petroleum Institute: API-2, API-6 

• Johanna de Graffenreid, Gulf Restoration Network: GRN-4 

• Thao Vu, Mississippi Coalition for Vietnamese-American Fisher Folk and 

Families: MCVAFFF-1, MCVAFFF-2, MCVAFFF-3, MCVAFFF-4, MCVAFFF-6, 

MCVAFFF-9 

• Sierra Club: SC-11

• Jennifer Crosslin, Steps Coalition: STEPS-1 

• Susan Feathers: SF-4 
L-4 Gulf of Mexico Multisale EIS

Topic 2 – NEPA Analysis

• United States Environmental Protection Agency: USEPA-1, USEPA-13, 

USEPA-16

• American Petroleum Institute: API-8, API-11, API-12, API-13, API-14, API-15

• Apalachicola Riverkeeper: AR-3 

• Center for Biological Diversity, Bold Louisiana, Gulf Restoration Network, 

Louisiana Bucket Brigade, Radical Arts and Healing Collective (CBD, BL, GRN, 

LBB, RAHC): CBD, BL, GRN, LBB, RAHC-4; CBD, BL, GRN, LBB, RAHC-5; 

CBD, BL, GRN, LBB, RAHC-7; CBD, BL, GRN, LBB, RAHC-10

• Gulf Restoration Network: GRN-2 

• Howard Page, Gulf Restoration Network: GRN-5 

• Lone Star Chapter of the Sierra Club: LSCSC-2, LSCSC-8, LSCSC-9, 

LSCSC-10, LSCSC-17

• Sharon Hayes, Restore Mississippi Sound: RMS-5, RMS-6 

• Sierra Club: SC-1, SC-2, SC-7, SC-10

• ConocoPhillips: CP-1, CP-2, CP-4 

• Susan Feathers: SF-2 

• Yolanda Ferguson: YF-1 

• Renate Heurich: RH-8 

• Hilton Kelley: HK-5 

• Cyrus Reed: CR-1 

• Robert Desmarais Sullivan: RDS-2 

• Community Advocate: CA-2 (BOEM received two additional comment letters 

from this respondent covering the same topic.)

• Ronald Kardos: RK-1 

• Rachel Walsh: RW-2 

Topic 3 – Alternatives

• American Petroleum Institute: API-10

• Center for Biological Diversity, Bold Louisiana, Gulf Restoration Network, 

Louisiana Bucket Brigade, Radical Arts and Healing Collective (CBD, BL, GRN, 

LBB, RAHC): CBD, BL, GRN, LBB, RAHC-11; CBD, BL, GRN, LBB, RAHC-12
Responses to Public Comments on the Draft Multisale EIS L-5 

• Sierra Club: SC-3, SC-4 

• Lone Star Chapter of the Sierra Club: LSCSC-3 

• Johanna de Graffenreid, Gulf Restoration Network: GRN-1 

• Cyrus Reed: CR-10

Stated Preference

• Carol Adams-Davis, Alabama Chapter of the Sierra Club: ACSC-2 

• American Petroleum Institute: API-5 

• Apalachicola Riverkeeper: AR-6 

• Lone Star Chapter of the Sierra Club: LSCSC-4 

• No New Leases Form Letter: NNL-5 

• Spectrum Geo: SPECTRUM-1 

• Brenda Warger: BW-1 

• Kellan Lyman: KL-1 

• Rachel Walsh: RW-1 

• Andrea Alexander: AA-1 

• Community Advocate: CA-3 (BOEM received two additional comment letters 

from this respondent covering the same topic.)

• David Hilfiker: DH-1 

• Diana Tomlinson: DT-1 

• Erica Heimberg: HM-1 

• J Conn: CONN-1 

• James Mulcare: JM-1 

• Jane McBride: JMB-1 

• Jason Hannon: JH-1 

• Jeff Cobb: JC-1 

• Joanna Nasar: JN-1 

• John Kersting: JK-1 

• Leah Gentry: LG-1 

• Margie Vicknair-Pray: MVP-1 
L-6 Gulf of Mexico Multisale EIS

• Melissa Fleming: MF-1 

• Michelle Macy: MM-1 

• Rebecca Parsons: RP-3 

• Ronald Kardos: RK-3 

• Sally Stevens: SS-1 

• Suzanne Cohen: COHEN-1 

Topic 4 – Environmental Issues and Concerns

Climate Change

• Leon Soil and Water Conservation District Supervisory Board: LSWCDSB-1 

• Center for Biological Diversity, Bold Louisiana, Gulf Restoration Network, 

Louisiana Bucket Brigade, Radical Arts and Healing Collective (CBD, BL, GRN, 

LBB, RAHC): CBD, BL, GRN, LBB, RAHC-6 

• Alabama Chapter of the Sierra Club: ACSC-1 

• Lone Star Chapter of the Sierra Club: LSCSC-13, LSCSC-15

• Sierra Club: SC-9 

• Katrina Dubytz: KD-3 

• Renate Heurich: RH-6 

• Harriett Myers: HM-2 

• Cyrus Reed: CR-2, CR-6 

• Kim Ross: KR-3 

• Brenda Warger: BW-3 

• Jane McBride: JMB-2 

• John Kersting: JK-3 

• Kim Schultz: KS-1 

• Rebecca Parsons: RP-1 

Greenhouse Gases

• Lone Star Chapter of the Sierra Club: LSCSC-5, LSCSC-12

• No New Leases Form Letter: NNL-3 

• Sierra Club: SC-8 
Responses to Public Comments on the Draft Multisale EIS L-7 

• Jennifer Crosslin, Steps Coalition: STEPS-3 

• Katrina Dubytz: KD-2 

• Cyrus Reed: CR-5 

Well Stimulation

• United States Environmental Protection Agency: USEPA-3 

• Center for Biological Diversity, Bold Louisiana, Gulf Restoration Network, 

Louisiana Bucket Brigade, Radical Arts and Healing Collective (CBD, BL, GRN, 

LBB, RAHC): CBD, BL, GRN, LBB, RAHC-9 

• John Young: JY-1 

Renewable Energy and Alternative Uses of the OCS

• Howard Page, Gulf Restoration Network: GRN-12

• Lone Star Chapter of the Sierra Club: LSCSC-7 

• Sharon Hayes, Restore Mississippi Sound: RMS-7 

• Hilton Kelley: HK-6 

• Jennifer Crosslin, Steps Coalition: STEPS-4 

• Brenna Landis: BL-2 

• Bruce Melton: BM-1 

• Rebecca Parsons: RP-2 

Natural Stressors

• Apalachicola Riverkeeper: AR-2 

• Sharon Hayes, Restore Mississippi Sound: RMS-3 

• Brenna Landis: BL-1 

Air Quality

• United States Environmental Protection Agency: USEPA-9, USEPA-10

• American Petroleum Institute: API-16, API-17, API-18, API-19, API-20, API-21, 

API-22, API-23

• Lone Star Chapter of the Sierra Club: LSCSC-16

• Renate Heurich: RH-4 
L-8 Gulf of Mexico Multisale EIS

• Cyrus Reed: CR-7 

• Kim Ross: KR-1, KR-2, KR-4 

Coastal Habitats

• United States Environmental Protection Agency: USEPA-5, USEPA-8 

• Louisiana Department of Natural Resources: LADNR-2 

• Steve Shepard, Gulf Coast Group of the Mississippi Sierra Club: GCGMSC-2 

• Charles Mackey Clark: CMC-1 

• Hilton Kelley: HK-2, HK-4 

Biologically Sensitive Areas

• Apalachicola Riverkeeper: AR-4 

• Cyrus Reed: CR-4 

Fish and Invertebrates

• American Petroleum Institute: API-24, API-25, API-26, API-27, API-28

Birds and Protected Birds

• American Petroleum Institute: API-29, API-30

• Lone Star Chapter of the Sierra Club: LSCSC-11

Marine Mammals

• American Petroleum Institute: API-31, API-32, API-33, API-34, API-35, API-36, 

API-37, API-38, API-39, API-40, API-41, API-42, API-43, API-44, API-45, API-46 

Sea Turtles

• American Petroleum Institute: API-47, API-48, API-49, API-50, API-51, API-52, 

API-53

Infrastructure

• United States Environmental Protection Agency: USEPA-6, USEPA-12, 

USEPA-14
Responses to Public Comments on the Draft Multisale EIS L-9 

Socioeconomics

• Louisiana Department of Natural Resources: LADNR-1 

• Consumer Energy Alliance: CEA-1, CEA-2 

• Steve Russell, OffshoreAlabama.com: OAL-1 

• Cyrus Reed: CR-3 

• Rachel Walsh: RW-3 

Environmental Justice

• Center for Biological Diversity, Bold Louisiana, Gulf Restoration Network, 

Louisiana Bucket Brigade, Radical Arts and Healing Collective (CBD, BL, GRN, 

LBB, RAHC): CBD, BL, GRN, LBB, RAHC-13

• Sierra Club: SC-12

• Lone Star Chapter of the Sierra Club: LSCSC-6 

• No New Leases Form Letter: NNL-2 

• Katrina Dubytz: KD-1 

• Howard Page, Gulf Restoration Network: GRN-11

• Renate Heurich: RH-5, RH-7 

• Jennifer Crosslin, Steps Coalition: STEPS-2 

• Thao Vu, Mississippi Coalition for Vietnamese-American Fisher Folk and 

Families: MCVAFFF-5 

Topic 5 – Cumulative Analysis

• American Petroleum Institute: API-9 

• Thao Vu, Mississippi Coalition for Vietnamese-American Fisher Folk and 

Families: MCVAFFF-7 

• David Underhill: DU-1 

• Brenda Warger: BW-2 

• Community Advocate: CA-1 (BOEM received two additional comment letters 

from this respondent covering the same topic.)
L-10 Gulf of Mexico Multisale EIS

Topic 6 – Oil Spills

• Brian Lee, Leon Soil and Water Conservation District Supervisory Board in Leon 

County, Florida: LSWCDSB-2 

• Apalachicola Riverkeeper: AR-1 

• Center for Biological Diversity, Bold Louisiana, Gulf Restoration Network, 

Louisiana Bucket Brigade, Radical Arts and Healing Collective (CBD, BL, GRN, 

LBB, RAHC): CBD, BL, GRN, LBB, RAHC-8 

• Steve Shepard, Gulf Coast Group of the Mississippi Sierra Club: GCGMSC-1 

• Johanna de Graffenreid, Gulf Restoration Network: GRN-3 

• Howard Page, Gulf Restoration Network: GRN-9, GRN-10

• Lone Star Chapter of the Sierra Club: LSCSC-18

• Thao Vu, Mississippi Coalition for Vietnamese-American Fisher Folk and 

Families: MCVAFFF-8 

• No New Leases Form Letter: NNL-4 

• Sharon Hayes, Restore Mississippi Sound: RMS-1, RMS-2, RMS-4 

• Sierra Club: SC-5, SC-6 

• Yolanda Ferguson: YF-6, YF-7 

• Renate Heurich: RH-2 

• Hilton Kelley: HK-5 

• Harriett Myers: HM-3, HM-4 

• Cyrus Reed: CR-9 

• Sky Yardley: SY-1 

• John Kersting: JK-2 

• Ronald Kardos: RK-2 

• John Young: JY-5 

Topic 7 – Mitigation

• United States Environmental Protection Agency: USEPA-4, USEPA-7, 

USEPA-11

• Alabama Department of Environmental Management (ADEM): ADEM-1 
Responses to Public Comments on the Draft Multisale EIS L-11

• Alabama Historical Commission: AHC-1 

• State of Louisiana Department of Natural Resources (LADNR): LADNR-3 

Topic 8 – Regulations and Safety

• United States Environmental Protection Agency: USEPA-2 

• American Petroleum Institute: API-3 

• Apalachicola Riverkeeper: AR-5 

• Howard Page, Gulf Restoration Network: GRN-6, GRN-7, GRN-8 

• ConocoPhillips: CP-3 

• Yolanda Ferguson: YF-3, YF-4, YF-5 

• Renate Heurich: RH-3 

• Harriett Myers: HM-1 

• Jack Radosta: JR-1 

• Maxine Ramsay: MR-1 

• Cyrus Reed: CR-8 

• John Young: JY-4 

Topic 9 – Statutory Compliance

• United States Environmental Protection Agency: USEPA-15

• American Petroleum Institute: API-7 

• Care2Petition: Care2Petition-1 

• Center for Biological Diversity, Bold Louisiana, Gulf Restoration Network, 

Louisiana Bucket Brigade, Radical Arts and Healing Collective (CBD, BL, GRN, 

LBB, RAHC): CBD, BL, GRN, LBB, RAHC-2; CBD, BL, GRN, LBB, RAHC-3; 

CBD, BL, GRN, LBB, RAHC-14

• Lone Star Chapter of the Sierra Club: LSCSC-14

Topic 10 – Other

• American Petroleum Institute: API-1, API-4 

• Center for Biological Diversity, Bold Louisiana, Gulf Restoration Network, 

Louisiana Bucket Brigade, Radical Arts and Healing Collective (CBD, BL, GRN, 

LBB, RAHC): CBD, BL, GRN, LBB, RAHC-1 
L-12 Gulf of Mexico Multisale EIS

• Consumer Energy Alliance: CEA-3, CEA-4 

• Caitlin Switzer, The Ehrhardt Group: EG-1 

• Melissa Cloutet, Louisiana Mid-Continent Oil and Gas Association (LAMOGA): 

LAMOGA-1, LAMOGA-2 

• Lone Star Chapter of the Sierra Club: LSCSC-1 

• No New Leases Form Letter: NNL-1 

• Susan Feathers: SF-1, SF-3 

• Yolanda Ferguson: YF-2 

• Renate Heurich: RH-1 

• Hilton Kelley: HK-1, HK-3 

• Robert Desmarais Sullivan: RDS-1 

• John Young: JY-2, JY-3 
Responses to Public Comments on the Draft Multisale EIS L-13

Table L-1. Public Comments and BOEM’s Response Matrix. 

Commenter Comment ID Comment Response

Topic 1 – NEPA Process and Public Involvement

American 

Petroleum 

Institute (API),

Andy Radford

API-2 To the extent that BOEM plans to use the new 

geospatial platform (GeoPortal) as part of this EIS 

scoping process, API understands the quest to make 

the process more efficient by allowing information 

submitted to be depicted in a mapping format, but we 

are concerned about the quality and consistency of 

data being submitted as comments through this 

system. We recognize that any form of public 

comment may include anecdotal data that may be 

outdated and may or may not be standardized, peer 

reviewed, or subjected to quality assurance 

procedures. We request that BOEM consider 

instituting a quality assurance, quality control system 

whereby data received through the new GeoPortal 

are reviewed for validity and scientific integrity prior 

to consideration during the PEIS process. BOEM 

should take any other necessary steps to make sure 

data are not biased or improperly interpreted. The 

EIS must use data from the best available peerreviewed scientific literature, and not speculation, 

when assessing potential impacts of oil and natural 

gas activities on the environment.

Thank you for your comment. BOEM used the 

GeoPortal technology during the public comment 

period on the Five-Year Program EIS. This 

technology was not used in the public comment 

process for this Multisale EIS. However, any 

information received through the GeoPortal software 

was properly vetted prior to its use in developing the 

Five-Year Program EIS. BOEM is committed to 

using the best available scientific information in all of 

its EISs, consistent with the information requirements 

under NEPA.

American 

Petroleum 

Institute (API), 

Andy Radford

API-6 API believes that the detailed analysis provided in 

the DEIS, along with the other supporting 

environmental documents and additional 

assessments being conducted by BOEM provide a 

thorough analysis upon which to make decisions 

related to the first proposed lease sale (Regionwide 

Lease Sale 249), new or revised exploration and 

development plans in the CPA, and future permit 

applications, without delay.

API supports the analysis made by BOEM in the 

Multisale DEIS, but there are issues that BOEM 

needs to address before finalizing the DEIS. API 

notes that the DEIS contains (by reference) updated. 

BOEM appreciates your comment. The technical 

information prepared in support of this Multisale EIS 

has previously appeared in the Gulf of Mexico OCS 

Region’s NEPA documents and was made available 

for public review and comments at those times. After 

review of these documents and the comments 

received from the public on these chapters, BOEM 

determined that no substantial comments have been 

received. Furthermore, BOEM determined that no 

substantial changes were needed prior to updating 

and publishing these technical papers. Therefore, 

this information has been incorporated by reference 

into this Multisale EIS. Updates to the technical 

papers will occur as needed. Because 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-14 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

information and analyses regarding the 2010 

Macondo oil spill 

This new information supports the NEPA process by 

describing the current environmental baseline 

conditions in the GOM including the results of new 

scientific studies regarding the spill. We encourage 

BOEM to continue reviewing and evaluating the 

good, peer-reviewed science in this and other areas 

and to avoid the use of unsubstantiated or anecdotal 

information.

API supports BOEM's effort to develop technical 

reports supporting technical information in previous 

NEPA reviews and reduce the overall page length 

and encyclopedic nature of NEPA reviews. Due to 

the report lengths, publication dates of the reports 

(2016), and time allotted to the review the DEIS, we 

recommend that BOEM provide an opportunity to 

review and comment on technical reports to support 

an adaptive approach "conducive to reducing the 

size of this Multisale EIS and future NEPA 

documents". While BOEM believes there have been 

minimal updates to information in the technical 

reports, that should not be the reason for not 

providing an opportunity for stakeholder input, 

especially with reports that could be influenced by 

the substantial data and information being provided 

post-Macondo by stakeholders, including the oil and 

gas industry. API hopes that future NEPA 

documents represent a truly streamlined analysis of 

only new information, but only supports if such 

information is added through appropriate consultation 

from all appropriate stakeholders, including the oil 

and gas industry, in the Gulf of Mexico region.

BOEM values the input of its stakeholders, BOEM 

would welcome and consider substantial comments 

on supporting technical information that is 

incorporated by reference in an EIS.

Sierra Club, 

Devorah 

Ancel,

SC-11 BOEM does not make Oil Spill Response Plans and 

the certification process open to public notice and 

comment. However, NEPA requires more: "The 

Oil-spill response plans are discussed in Chapter 

3.2.8.1.1 and Appendix A.5 of this Multisale EIS, 

and the discussion of mitigating measures can be 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-15

Commenter Comment ID Comment Response

Staff Attorney NEPA process has two purposes. First, '[i]t ensures 

that the agency, in reaching its decision, will have 

available, and will carefully consider, detailed 

information concerning significant environmental 

impacts.' Second, it 'guarantees that the relevant 

information will be made available to the larger 

audience that may also play a role in both the 

decision-making process and the implementation of 

that decision." "The 'informational role' of an EIS is 

to 'giv[e] the public the assurance that the agency 

'has indeed considered environmental concerns in its 

decision-making process,' and, perhaps more 

significantly, provides a springboard for public 

comment' in the agency decision­making process 

itself." In Quechan, the court found the NEPA 

process adequately fulfilled in the analysis of a land 

transfer for a refinery where the public would be 

given the opportunity to comment on later stages of 

construction of the refinery. However, BOEM 

provides no avenue to fulfill the second purpose of 

NEPA-public participation-in regards to oil spill 

response plans ("OSRPs"). OSRPs provide the 

"mitigation" which BOEM uses to claim that the 

environmental risk of a blowout resulting in a large oil 

spill has been reduced to an insignificant level. The 

public cannot meaningfully participate in an 

environmental review of a lease sale where the basis 

for the minimization of risk associated with the 

activities that are reasonably foreseeable pursuant to 

that sale have not been exposed to public scrutiny 

and comment.

found in Appendix B. While outside of the scope of 

this Multisale EIS, BOEM notes that oil-spill 

response plans fall under BSEE’s jurisdiction. While 

other later OCSLA stages are supported by NEPA 

reviews of various types, oil-spill response plans are 

not subject to reviews under NEPA and the ESA. 

This was recently upheld in an Appeals Decision by 

the 9th Circuit Court (Nguyen and Nelson, 2015). 

The 9th Circuit Court’s panel rejected the plaintiffs’ 

contention that BOEM violated NEPA by failing to 

prepare an EIS before approving the plans. The 

panel held that BOEM reasonably concluded that it 

must approve any plan that met the statutory 

requirements of the Clean Water Act. The panel 

concluded that BOEM’s approval of Shell’s plans 

was not subject to the requirements of NEPA 

(Nguyen and Nelson, 2015). While BOEM 

discusses reasonably foreseeable oil spills and oilspill response activities in Chapter 3.2.1, a 

catastrophic oil spill as a result of a blowout is not 

part of a proposed action nor is it considered likely 

to occur. BOEM, nevertheless, provides an analysis 

of such a spill in the Catastrophic Spill Event 

Analysis technical report (USDOI, BOEM, 2017).

Steps 

Coalition, 

Jennifer 

Crosslin, 

Community 

Organizer

STEPS-1 Thirty days to review over 700 pages of technical 

scientific information is not enough time to provide 

meaningful comments. Thus, I am requesting that 

the public comment period be extended at least 60 

days.

On April 22, 2016, BOEM published a Notice of 

Availability on the Draft Multisale EIS. NEPA 

requires a 45-day comment period on Draft EISs, a 

period that may be extended at the discretion of the 

agency issuing the document. In the case of the 

Draft Multisale EIS, BOEM determined that 45 days 

was adequate and appropriate for a programmatic 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-16 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

document. However, all stakeholders were 

encouraged to provide comments on the EIS during 

the comment period, which ended on June 7, 2016. 

BOEM recognizes the importance of input from 

public stakeholders and appreciates the timing 

constraints noted by the commenter. 

Gulf 

Restoration 

Network, 

Johanna de 

Graffenreid

GRN- 4 Additionally, hosting public comment opportunities 

after work hours and in a location accessible by 

public transit is appreciated and allows for full 

community participation.

Thank you for your comment. BOEM did its best to 

consider work hours and locations that were easily 

accessible for the public. BOEM will continue to 

consider these factors when planning future public 

participation opportunities.

Susan 

Feathers

SF-4 Thanks for a great discussion, information, and a 

good diligence to inform the public. Well done.

Thank you for your comment. BOEM is continually 

looking for ways to improve public involvement. 

BOEM’s open-house meeting format is designed to

create a better atmosphere for open and honest 

dialogue to not only provide information to the public 

but to also help with the solicitation of meaningful 

comments to improve the NEPA review.

Mississippi 

Coalition for 

VietnameseAmerican 

Fisher Folk 

and Families, 

Thao Vu, 

Director

MCVAFFF-1 We reiterate the great importance to extend the 

public comment deadline to 60 additional days. It is 

an extremely lengthy, technical document that needs 

translation & dissemination to the VietnameseAmerican fishing communities in the Gulf Region.

Thank you for your comment. BOEM had several 

follow-up discussions with Ms. Vu to identify specific 

areas of interest and sections of this Multisale EIS 

that would be most beneficial to the community. As 

a result, BOEM provided translations of all the 

meeting handouts, visual aids, and Executive 

Summary, as well as the chapters on fish and 

invertebrate resources and commercial fishing. 

Staff also went on a dock tour with Ms. Vu and her 

constituents along the Gulf Coast of Mississippi to 

view, firsthand, the docks and facilities used by 

fisherfolks, to talk with constituents, and to provide 

additional information on BOEM’s environmental 

review process. Because of the special language 

needs, BOEM agreed to accept comments from the 

Coalition and its members through August 31, 2016. 

MCVAFFF-3 And another challenge is that many have language 

access, right, needs. They arrive here as adults in 

the Gulf and they didn’t have an opportunity to obtain 

a higher education, so they have limited English 

proficiency. They have challenges in terms of 

accessing computers and they are unaware of the 

Federal Register, right. And we don't think that any 

of their documents have been translated.

MCVAFFF-6 We also want to -- we're very concerned about 

environmental injustices, because there's a principle 

-- you know, a principle is called environmental 

justice principles. And part of that means being able 

to meaningfully engage and participate, you know, 

and we believe that particularly for minority, 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-17

Commenter Comment ID Comment Response

underserved populations, where language access or 

computer access challenges, they haven't been 

meaningfully engaged and they still have -- they 

suffering from huge economic, social, and health 

impacts that hasn't been remediated, reduced.

Mississippi 

Coalition for 

VietnameseAmerican 

Fisher Folk 

and Families, 

Thao Vu, 

Director

MCVAFFF-2 First of all, you know, I work with -- closely with a lot 

of the Vietnamese American fishing communities 

here in of Mississippi. And one of our key concerns 

is an accurate public notice, right, and that we think 

that right now, first of all, it's shrimping season in 

Louisiana and a number of the Fisher Folks are 

either shrimping in Louisiana or they're getting ready 

to go to Louisiana, right. And they weren't aware of 

this very important hearing.

BOEM works diligently to inform the public of 

upcoming meetings. An announcement of the 

dates, times, and locations of the public meetings 

was included in the Notice of Availability of the Draft 

Multisale EIS. A copy of the public meeting notices 

was included with the Draft Multisale EIS that was 

mailed to the parties listed in Chapter 5.6.2.5, was 

published in local newspapers, and was posted on 

BOEM’s website at http://www.boem.gov/

nepaprocess/. Furthermore, in response to 

Ms. Vu’s comments, BOEM met with Ms. Vu and 

several of her constituents to listen to their 

concerns, provided Vietnamese translations of 

specific sections of concern of the Draft Multisale 

EIS, and provided additional time for the MCVAFFF 

to provide more comments.

Mississippi 

Coalition for 

VietnameseAmerican 

Fisher Folk 

and Families, 

Thao Vu, 

Director

MCVAFFF-4 It's a very lengthy, technical documents, and 

because of all those challenges, you know, we are 

asking for this comment period to be extended 60 

days. Adequate time to -- for outreach and 

disseminating this information and giving enough 

people -- giving people enough time to comment on 

it, right? So that's critically important, you know.

After the translated documents were provided to 

Ms. Thao Vu, Director, Mississippi Coalition for 

Vietnamese American Fisher Folks and Families, 

BOEM met with Ms. Vu on July 15, 2017, to conduct 

a tour of the facilities used by her constituents. 

Because of the special language needs, BOEM 

agreed to accept any comment from Ms. Vu and the 

community through August 31, 2016. BOEM did not 

receive any additional comments.

Mississippi 

Coalition for 

VietnameseAmerican 

Fisher Folk 

and Families, 

Thao Vu, 

MCVAFFF-9 So in terms of this BOEM public hearing the way it's 

structured, we don't think that it's a good process. A 

good process is actually just -- you could have a 

presenter and you could also have it rolling at the 

same time, and you could actually have materials 

and handouts for the public. Right. All of that. But 

you need to set aside time for folks to be able to 

comment, an accurate time. Not just three minutes, 

BOEM has determined (through internal processes 

and informal public comment) that the new openhouse meeting format provides more productive 

meetings. To ensure that all meeting attendees had 

the opportunity to provide verbal/oral comments, an 

initial time limit was set for 3 minutes. Afterward, if 

time allowed (i.e., no other individuals were waiting 

to make comments), anyone was allowed to provide 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-18 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Director but at least six minutes. Right. Because some of us 

may have to interpret for others who have language 

access problems, challenges. Right. In addition, you 

know, the purpose of a public hearing is there for us 

to express our comments or our recommendations, 

our concerns, and everyone have equal access, 

opportunity to hear, right. And be informed about it. 

And by setting -- by creating this structure and asking 

us to submit our comments to a court reporter, you 

know, without anyone else being able to hear our 

comments, concerns and recommendations, we don't 

think – we think that's not a fair or inclusive process. 

In fact, it's very exclusionary.

additional oral comments. Additionally, there were 

multiple ways to provide comments on the Draft 

Multisale EIS. These included providing written 

comments at the public meetings, mailing 

comments, emailing comments, and using the 

regulations.gov portal.

Topic 2 – NEPA Analysis

American 

Petroleum 

Institute (API), 

Andy Radford

API-8 BOEM indicates the DEIS will be used to decide 

whether, and under what circumstances, lease sale 

249 will be held in 2017. DEIS at p. iii. However, the 

DEIS is also intended to consider the environmental 

impacts associated with nine additional lease sales 

from 2018-2022. Though additional NEPA review 

will occur for later decisions to hold any of those 

individual lease sales, that analysis likely will tier 

heavily from the current DEIS (see p. 2-4). Although 

it is clear in the introductory material and the 

discussion of the alternatives in Chapter 2 that the 

DEIS is intended to cover up to 10 lease sales, it 

becomes less clear as BOEM moves on to discuss 

the direct, indirect, and cumulative impacts of "a 

proposed action." BOEM should first clarify that "a 

proposed action" means "any of the 10 lease sales 

proposed for the GOM in 2017 to 2022." More 

importantly, BOEM should ensure that its impact 

analysis considers not only the environmental 

impacts of each lease sale, but also the cumulative 

impacts of all contemplated lease sales. Doing so is 

not only an important aspect of the cumulative impact 

analysis for Lease Sale 249, but also will likely 

reduce the NEPA burden for each of the nine 

Thank you for your comment. The text in the 

Abstract, Executive Summary, and Chapters 1, 

3, and 4 has been revised to clearly show the 

application of this Multisale EIS for all 10 proposed 

lease sales, as well as clearly showing that the 

analysis is for a single proposed lease sale to 

support a decision for a single proposed lease sale, 

regardless of the lease sale number. After 

completion of this Multisale EIS, BOEM will make a 

decision on proposed Lease Sale 249. BOEM 

recognizes that the decision for each of the nine 

subsequent proposed lease sales will rely heavily 

on this Multisale EIS and that the appropriate level 

of supplemental review will be conducted to account 

for new information since this Multisale EIS was 

prepared. The impacts of holding 10 GOM lease 

sales in the Five-Year Program were analyzed in 

the 2017-2022 Five-Year Program EIS (USDOI, 

BOEM, 2016a).
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-19

Commenter Comment ID Comment Response

subsequent lease sales.

American 

Petroleum 

Institute (API), 

Andy Radford

API-11 BOEM should ensure that it applies the appropriate 

regulatory standard to its consideration of incomplete 

and unavailable information. The Council on 

Environmental Quality regulation at 40 C.F.R. § 

1502.22 requires agencies to consider incomplete or 

unavailable information. When preparing an EIS, an 

agency must either obtain information that is 

"essential to a reasoned choice among the 

alternatives" or explain why such information is too 

costly or difficult to obtain. Id., Native Village of Point 

Hope, 740 F.3d at 496.

BOEM deals admirably with the reality of incomplete 

or unavailable information throughout the DEIS, but 

in a few places it misstates the appropriate regulatory 

standard. For example, with respect to deepwater 

benthic communities, BOEM acknowledges that 

knowledge concerning deepwater benthic community 

composition, life cycles, and location is currently 

incomplete. See DEIS at p. 4-118. BOEM also 

acknowledges that "[d]etailed information on impactproducing factors [such as exposure to oil spill 

events] may be relevant to the evaluation of impacts 

on deepwater benthic communities." Id., at 4-118 -4-

119. However, BOEM concludes that, because the 

agency used the "best available science to determine 

the range of reasonably foreseeable impacts," and 

"appl[ied] accepted scientific methodologies 

to...integrate existing information and extrapolate 

potential outcomes," "[t]herefore, BOEM has 

determined that the incomplete information is not 

essential to a reasoned choice among alternatives." 

Id. at 4-119. In numerous sections of the DEIS 

dealing with incomplete or unavailable information, 

BOEM reaches similar conclusions or no conclusion 

at all with respect to the "essential" nature of the 

incomplete and unavailable information. E.g., DEIS 

Thank you for your comment. BOEM has reviewed 

each subchapter in Chapter 4 where information 

was incomplete or unavailable, and BOEM has 

confirmed that it complied with its obligations under 

NEPA to determine if the information was relevant 

to reasonably foreseeable significant adverse 

impacts and, if so, whether it was essential to a 

reasoned choice among alternatives and, if it was 

essential, whether it can be obtained and whether 

the cost of obtaining the information is exorbitant, as 

well as whether scientifically credible information 

using generally accepted scientific methodologies 

can be applied in its place (40 CFR § 1502.22).
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-20 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

at pp. 4-7 - 4-8 (discussing impacts associated with 

the Deepwater Horizon spill); 4-353 (assessing visual 

impacts, and making no finding with respect to 

whether the missing information is essential to a 

reasoned choice among the leasing alternatives).

BOEM's use of the best available science does not 

make essential information nonessential. To meet its 

requirements under 40 C.F.R. § 1502.22, BOEM 

must first determine whether the missing information 

is essential to a reasoned choice among the 

alternatives. If BOEM determines that the missing 

information is essential, then the agency must 

determine whether the costs of obtaining the 

information are exorbitant or the means of obtaining 

it are not known. Oceana v. BOEM, 37 F. Supp. 

3d 147 (D.D.C. 2014); Native Village of Point Hope, 

740 F.3d at 495-497. If either is true, then BOEM 

must do precisely what it has done: explain that the 

information is incomplete or unavailable, explain the 

relevance of the incomplete or unavailable 

information, provide a summary of the existing 

science, and provide an analysis based on 

theoretical approaches or generally accepted 

research methods. 40 C.F.R. § 1502.22(b).

Although BOEM has supplied all the information and 

analysis it can where it perceives missing 

information, in some instances it has not determined 

whether the missing information is essential to a 

reasoned choice among the alternatives. Moreover, 

in some instances BOEM has not determined 

whether obtaining additional essential information is 

feasible. BOEM should clearly make the required 

determinations to ensure adherence with 40 C.F.R. § 

1502.22.

Community 

Advocate

CA-2 BOEM staff admitted to gaps in the analytical 

process, which does not meet the minimum “Best 

BOEM has determined that the analysis in this 

Multisale EIS is centered on the best available and 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-21

Commenter Comment ID Comment Response

science/Best Practice for NEPA compliance. credible scientific information. BOEM’s subjectmatter experts are experts in their fields, and they

conducted extensive scientific and literature reviews 

to ensure their analyses and impact conclusions are 

fully supported by the best available and credible 

scientific information. BOEM’s subject-matter 

experts have clarified in this Multisale EIS where 

incomplete or unavailable information may be 

essential to a reasoned choice among alternatives, 

if the information could be obtained or, if the costs of 

obtaining it are exorbitant, and that what 

scientifically credible information is available was 

applied using accepted scientific methodologies.

American 

Petroleum 

Institute (API), 

Andy Radford

API-12 In the Draft Programmatic Environmental Impact 

Statement (DPEIS) on the Outer Continental Shelf 

(OCS) Oil and Gas Leasing Program: 2017 -2022 

BOEM introduced the concept of Environmentally 

Important Areas and uses the acronym "EIA" when 

discussing them. Our review of the DEIS does not 

show any discussion of "Environmentally Important 

Areas." The DPEIS emphasized the importance of 

Environmentally Important Areas (EIAs) to the extent 

that they are the focus of the Alternative B (Reduced 

Proposed Program) approach, and BOEM has even 

provided a Fact Sheet to help explain these. 

Additionally, in discussing "Topographic Stipulation 

Blocks" in the Draft PEIS, these are considered 

among the "EIAs that could be geographically 

defined, were supported by adequate data, but would 

not affect the size or location of potential leasing." 

However, this DEIS does not consider EIAs 

specifically by name, but rather defines the acronym 

"EIA" as an Economic Impact Area (DEIS 3-79). In 

contrast, in this DEIS, Topographic Stipulation Blocks 

are considered in Alternative D because they "can be 

geographically defined, and adequate information 

exists regarding their ecological importance and 

sensitivity to OCS oil- and gas-related activities." 

In this Multisale EIS, the term EIA (i.e., economic 

impact area) represents regions of important 

environmental value where there is potential for 

conflict between ecologically important or sensitive 

habitats; maintenance of social, cultural, and 

economic resources; and possible oil and gas 

development. Only one “environmentally important 

area” within the Gulf of Mexico was identified at the 

program level, i.e., the topographic features. The 

Five-Year Program EIS did not analyze this 

environmentally important area as an alternative 

because, even though the topographic features can 

be geographically defined, this area would not 

generally affect the size or location of potential 

leasing at the programmatic level. Instead, the 

Five-Year Program EIS considered the blocks 

subject to the Topographic Features and Live 

Bottom (Pinnacle Trend) Stipulations as 

programmatic mitigation that is intended to 

streamline subsequent environmental reviews and 

decisions at the lease sale stage.

It is more appropriate to analyze these areas on a 

finer scale at the region level (i.e., this Multisale 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-22 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

The two definitions are very similar, which makes the 

EIA concept even more confusing and hard to justify 

its exclusion from the multi-lease EIS. Furthermore, 

the inclusion of Alternative D, which could exclude 

blocks subject to the Topographic Features 

Stipulation, is in direct contrast to the Draft PEIS, 

which identified them as not affecting the size or 

location of potential leasing.

BOEM is mixing the use these terms or dropping 

some terms altogether that were regularly used in the 

past (such Areas of Special Concern [AOCs]), which 

is confusing and should be clarified between the two 

documents.

AOCs, in particular, had been part of BOEM's NEPA 

vocabulary going back to 2002, which included 

federally managed areas (e.g., Marine Protected 

Areas, National Marine Sanctuaries, National Parks, 

and National Wildlife Refuges). AOCs in previous 

BOEM NEPA documents included locations that 

have been given special designations by Federal, 

State, and nongovernmental organizations (e.g., 

National Estuarine Research Reserves, National 

Estuary Program Sites, and Military and National 

Aeronautics and Space Administration [NASA] Use 

Areas) (see BOEM 2012 -2017 OCS Oil and Gas 

Leasing Program DPEIS 3.9). Essential fish habitat 

as designated by the United States Department of 

Commerce (USDOC), National Marine Fisheries 

Service (NMFS) was also included as an AOC in 

assessing impact levels for biological and physical 

resources (BOEM 2012 -2017 DPEIS p.4-9), but 

discussed in BOEM technical whitepaper and not this 

DEIS.

The dual-use of EIA is confusing and should be 

clarified across each EIS. If BOEM is changing its 

EIS). Subsequently, blocks with sensitive biological 

features such as topographic features and pinnacle 

trends were analyzed as a separate alternative to 

determine if additional protection, i.e., excluding 

these blocks from future lease sales, is warranted.

As far as the use of the term “areas of concern” 

versus “environmentally important areas” in the 

Five-Year Program EIS, the use of environmentally 

important areas is broader than areas of concern 

and therefore more appropriate in this context. 

BOEM introduced this term in the Five-Year 

Program EIS to address the Secretary’s 

requirement for consideration of a landscape-scale 

approach to planning. For the use of EIA in this 

Multisale EIS, this term EIA has been used for 

economic impact areas since the 2007-2012 

WPA/CPA Multisale EIS (USDOI, MMS, 2007).

No CEQ regulations or guidance exist for the use of 

acronyms. However, style guides recommend, 

when you introduce new or unfamiliar acronyms, 

spelling out the component words first and then 

placing the acronym in parentheses. As is common 

with most technical and government documents, 

BOEM also includes an abbreviations and acronyms 

list for each NEPA document.
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-23

Commenter Comment ID Comment Response

terminology to replace AOCs with Environmentally 

Important Areas, additional discussion and 

explanation of this change is needed to reduce 

confusion going forward. API recommends that 

BOEM align the language across the DPEIS and this 

DEIS to eliminate unnecessary confusion and to 

provide an explanation of language clarification and 

the meaning of such terms in regards to impact 

analysis in each NEPA document. We also 

recommend that once BOEM aligns the language, 

that terminology remains consistent in any NEPA 

document associated with 2017-2022 OCS activities.

API-15 Clarify discrepancies in terminology between the 

2017 – 2022 GOM Multisale EIS and the 2017 – 

2022 Proposed Leasing Program Draft (and Final) 

Programmatic EIS (herein DPEIS).

American 

Petroleum 

Institute (API), 

Andy Radford

API-13 This DEIS generally lacks sufficient references for 

the included information. In many instances, BOEM 

refers to specific examples, occurrences, or data 

(See Comments on specific areas of analysis). 

When discussing marine mammals, BOEM 

references metrics provided from different Federal 

agencies (i.e. NMFS) and then describes potential 

impacts to populations without providing reference to 

quantitative metrics, peer reviewed literature or other 

sources to support the designation of an impact level 

or factor. In some cases, it seems that the 

information may originate from unpublished data, 

technical memorandums, whitepapers, surveys, etc. 

Regardless of the source, all information leading to 

conclusions of impact determinations should be 

referenced.

BOEM appreciates the substantive content of this 

comment and has revisited all EIS chapters and 

specifically Chapter 4.9.1 (Marine Mammals). All 

information leading to impact determinations was 

clarified, and the corresponding literature was cited. 

Specifically for Chapter 4.9.1, BOEM has clarified 

the consideration of marine mammal stock 

assessment reports provided by NMFS when 

making impact determinations. Because NMFS has 

jurisdiction to manage marine mammal stocks of the 

Gulf of Mexico under the Marine Mammal Protection 

Act and Endangered Species Act, BOEM considers 

much of their information when making impact 

determinations for the decisionmaker. Revisions to 

the text can be found throughout Chapter 4.9

(Protected Species), which also addresses the 

“Specific Marine Mammal Comments” for Chapters 

4.9.1.1 and 4.9.1.2.

American 

Petroleum 

Institute (API), 

Andy Radford

API-14 Construct tables for each evaluated impact that it 

clearly links the impact determinations, specifically 

for ranges, and (individual and cumulative) data and 

conclusions with supported evidence and uncertainty 

Thank you for your comment. A majority of the 

subchapters within Chapter 4 include a table that 

identifies the potential impacts as a result of the 

routine activities, accidental events, and cumulative 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-24 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

for the resulting determination(s). impacts of a proposed action. The intent of the 

table is to provide a summary comparison of the 

expected impact levels by alternative, which 

considered impact-producing factors that have the 

greatest potential impact to each resource. We 

added a note to each table to refer the reader to the 

subsequent narrative for further detail on the 

analysis that clearly links the impact determination 

to the impact-producing factor and alternative. For 

example, please refer to Table 4-1 of the Final 

Multisale EIS. Furthermore, BOEM added chapter 

numbers to the subheadings of routine activities, 

accidental events, and cumulative impacts in order 

to more clearly cross reference the table to the 

analysis.

Center for 

Biological 

Diversity, Bold 

Louisiana, 

Gulf 

Restoration 

Network, 

Louisiana 

Bucket 

Brigade, 

Radical Arts 

and Healing 

Collective

(CBD, BL, 

GRN, LBB, 

RAHC), 

Kristen 

Monsell, 

Staff Attorney

CBD, BL, GRN, 

LBB, RAHC-4 

BOEM's Draft EIS fails to properly define baseline 

conditions. NEPA requires BOEM to "describe the 

environment of the areas to be affected or created by 

the alternatives under consideration." Thus, the 

establishment of the baseline conditions of the 

affected environment is a fundamental requirement 

of the NEPA process. "Without establishing the 

baseline conditions which exist in the vicinity . . . 

there is simply no way to determine what effect the 

proposed [project] will have on the environment and, 

consequently, no way to comply with NEPA."

BOEM lacks critical information regarding the effects 

of the Deepwater Horizon oil spill on the Gulf of 

Mexico. The Deepwater Horizon disaster resulted in 

the deaths of 11 workers and caused a spill of 

approximately 206 million gallons of oil over the 

course of at least 87 days. More than 1,000 miles of 

shoreline were contaminated with oil; 88,522 square 

miles of ocean- totaling one-third of the Gulf of 

Mexico-were closed to commercial and recreational 

fishing; millions of animals were killed or harmed; 

and local residents were sickened.

Thank you for your comment. BOEM acknowledges 

that there is some lingering uncertainty regarding 

the impacts of the Deepwater Horizon oil spill. 

However, this uncertainty has diminished as time 

passes and as new data and studies have become 

available. In addition, BOEM has complied with 

NEPA procedures for dealing with incomplete or 

unavailable information. BOEM has made some 

changes to this Multisale EIS in light of this 

comment in order to clarify the nature of the 

incomplete or unavailable information related to the 

impacts of the Deepwater Horizon oil spill on the 

baseline conditions of various resources.

Current baselines are described for all resources 

under their respective “Description of the Affected 

Environment” chapters. Specific to the Trustees’ 

PDARP/PEIS (Deepwater Horizon Natural 

Resource Damage Assessment Trustees, 2016), 

the altered baseline includes individual protected 

species directly affected by this unexpected unique 

catastrophic event. BOEM understands that each 

oil-spill event is unique and that its outcome 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-25

Commenter Comment ID Comment Response

Six years later, the Gulf is still reeling from the effects 

of the spill. Recent studies demonstrate severe lung 

disease in dolphins; near-record lows of critically 

endangered Kemp's Ridley sea turtle nesting; oil 

dispersants toxic to corals and jellyfish; and a 

"bathtub ring" of oil on the seafloor. Another recent 

study published in April 2016 indicates that the spill 

impacted 19% more coastline that originally believed, 

finding that oil washed up on 1,313 miles of coastline 

along the Gulf of Mexico. In addition, the 50,000 

people involved in cleanup efforts suffer from an 

increased risk of physical and psychological injury. 

Gulf residents are still suffering from increased 

symptoms of depression, anxiety, mental illness, and 

posttraumatic stress.

However, the impacts of the spill are not yet fully 

understood and are still being studied. For example, 

the Natural Resource Damage Assessment, which 

will assess impacts to natural resources that may 

have been impacted by the spill (including clean-up 

efforts), is still underway. Moreover, BOEM has 

repeatedly admitted in other environmental review 

documents that there are data gaps regarding 

numerous resources in the Gulf of Mexico, including 

wetlands, coastal water quality, offshore water 

quality, air quality, commercial and recreational 

fishing and environmental justice, and that the 

impacts of the Deepwater Horizon oil spill on such 

resources may have changed baseline conditions.

Further, while BOEM reinitiated Section 7 

consultation under the ESA following the Deepwater 

Horizon oil spill, BOEM has yet to complete that 

consultation. Accordingly, BOEM does not have an 

accurate picture of the effects that authorizing more 

offshore oil and gas drilling (including in the very 

depends on several factors, including time of year 

and location of the release relative to winds, 

currents, land, and sensitive resources, as well as 

specifics of the well and response effort. BOEM 

also understands that the severity of impacts from 

an oil spill cannot be predicated on volume alone. 

BOEM has analyzed a low-probability catastrophic 

event (USDOI, BOEM, 2017) in conjunction with its 

analysis of potential effects, as requested by CEQ 

pursuant to its regulation at 40 CFR § 1502.22. A 

low-probability catastrophic spill is, by definition, not 

reasonably certain to occur. Other methods of 

analysis are significantly limited in their applicability 

and availability, and they would not provide any 

meaningful or useful information to be used to 

assess the risk of a catastrophic spill occurrence at 

this programmatic level of OCS oil- and gas-related 

activities in the GOM. The return period of a 

catastrophic oil spill in OCS areas is estimated to be 

165 years, with a 95 percent confidence interval 

between 41 years and more than 500 years (Ji 

et al., 2014).

BOEM's produced-water data are collected from the 

Office of Natural Resources Revenue (ONRR). The 

ONRR's “Oil and Gas Operations Report” (OGOR) 

collects produced-water data, which can be found 

on ONRR’s website at http://www.onrr.gov/

ReportPay/production-reporting.htm). The OGOR-B 

report includes a disposition code to indicate how 

the produced water is disposed of (i.e., injected on 

lease, injected or transferred off lease, or disposed 

of). BOEM does not manage USEPA’s data. It is 

likely that data collected in different databases will 

be different. Despite the difference, BOEM 

considers the potential impacts from the offshore 

discharge of produced water to be negligible beyond 

1,000 m (3,281 ft) from the discharge point to 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-26 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

same area where the Deepwater Horizon spill 

occurred) could have on already imperiled species.

Moreover, BOEM's analysis of baseline conditions 

regarding water quality is fundamentally flawed. 

BOEM's Draft EIS states that all offshore oil and gas 

platforms in the Gulf of Mexico discharged roughly 

15.3 billion gallons of produced water in 2014. 

However, a review of records obtained from the 

Environmental Protection Agency pursuant to a 

request under the Freedom of Information Act 

reveals that offshore oil and gas platforms under the 

jurisdiction of Region 6-federal waters in the Western 

Planning Area and the Central Planning Area off the 

coasts of Texas and Louisiana-discharged more than 

76 billion gallons of produced waters in 2014. This is 

a significant discrepancy that must be remedied, 

particularly considering that produced water contains 

toxic pollutants released during the drilling process. 

For example, produced water can contain harmful 

substances like benzene, arsenic, lead, hexavalent 

chromium, barium, chloride, sodium, sulfates, and 

boron, and it also can be radioactive. Produced 

water itself is potentially harmful to humans, aquatic 

life, and ecosystems-in fact, a study sponsored by 

the U.S. Department of Energy demonstrated that oil 

production yields "environmentally hazardous" 

produced water.

For all of these reasons, BOEM cannot properly 

define the environmental baseline, and BOEM 

cannot conduct a proper NEPA analysis unless and 

until these significant data gaps are filled. Yet BOEM 

is arbitrarily and capriciously proceeding to allow 

substantially more offshore oil and gas drilling 

regardless.

moderate within 1,000 m (3,281 ft). The 

conclusions reached in this Multisale EIS remain the 

same, regardless of which estimate is used.

In response to the comment on the alleged harmful 

effects of produced water, additional language 

describing how USEPA regulates these discharges 

to prevent unreasonable degradation of the 

receiving waters has been added to Chapter 

4.2.2.1. 

Regarding wetlands, please refer to the updated 

text in Chapter 4.3. The NRDA studies are 

ongoing, but the Trustees’ PDARP/PEIS has been 

released and analyzed for relevant information. 

With the release of the Trustees’ PDARP/PEIS, our 

understanding of the environmental impacts of the 

Deepwater Horizon explosion, oil spill, and 

response has greatly increased; however, there are 

many ongoing long-term and monitoring studies that 

are not complete. Therefore, our understanding of 

the lasting effects or long-term recovery of the 

system is still incomplete and has data gaps, but the 

information is not essential to a reasoned choice 

among alternatives.

BOEM has revisited the baseline descriptions for 

the land use/coastal infrastructure and social factors 

sections and does not agree that enough evidence 

exists yet to conclusively determine that the 

Deepwater Horizon explosion, oil spill, and 

response has changed the baseline conditions. 

However, some additional clarifying language and 

references been added to supplement the baseline 

descriptions and the cumulative impacts analysis 

contained in the Draft Multisale EIS.

Restore 

Mississippi 

RMS-5 No real-life, regional information from the Gulf and 

coastal areas is used in the decision. For example, 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-27

Commenter Comment ID Comment Response

Sound, 

Sharon Hayes, 

Director

baseline conditions in the Gulf are modeled. There is 

no on-the-ground data used in the EIS. For example, 

coastal residents believe that the Mississippi Sound 

is so polluted, they won't go in the water. Tourists 

who aren't familiar with the water quality will. Earlier 

this year the entire Mississippi coastal beach was 

closed for over a month because of Red Tide. 

Extremely unusual in -- in the cold months. Oysters 

have practically disappeared from the Mississippi 

Coast, and shrimp and fish catches are falling. Over 

50 dead baby dolphins have washed ashore this year 

alone. An article published in the last few weeks 

suggests that the cause of those dead dolphins was 

the oil spill. Tarballs have been seen regularly on 

Mississippi beaches, and studies show the deadly 

vibrio virus feeds on oil and can be found in very high 

concentrations in proximity to tarballs.

Lone Star 

Chapter of the 

Sierra Club

(LSCSC), 

Cyrus Reed, 

Conservation 

Director

LSCSC-17 BOEM has repeatedly admitted that it lacks critical 

information regarding the effects of the Deepwater 

Horizon oil spill on the Gulf of Mexico. It has also 

repeatedly admitted that there are data gaps 

regarding numerous resources in the Gulf, including 

wetlands, coastal water quality, offshore water 

quality, air quality, commercial and recreational 

fishing and environmental justice, and that the 

impacts of the Deepwater Horizon oil spill on such 

resources may have changed baseline conditions. 

BOEM therefore cannot properly define the 

environmental baseline, and cannot conduct a proper 

NEPA analysis unless and until these significant data 

gaps are filled.

BOEM acknowledges that there is some lingering 

uncertainty regarding the impacts of the Deepwater 

Horizon oil spill. However, this uncertainty has 

diminished as time passes and as new data and 

studies have become available. In addition, BOEM 

has complied with NEPA procedures for dealing 

with incomplete or unavailable information. BOEM 

has made some changes to this Multisale EIS in 

light of this comment in order to clarify the nature of 

the incomplete or unavailable information related to 

the impacts of the Deepwater Horizon oil spill on the 

baseline conditions of various resources.

BOEM has revisited the baseline description and 

cumulative impacts analysis and has added 

clarifications and additional information where 

appropriate (i.e., in the land use and social factors 

chapters).
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-28 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Center for 

Biological 

Diversity, Bold 

Louisiana, 

Gulf 

Restoration 

Network, 

Louisiana 

Bucket 

Brigade, 

Radical Arts 

and Healing 

Collective

(CBD, BL, 

GRN, LBB, 

RAHC), 

Kristen 

Monsell, 

Staff Attorney

CBD, BL, GRN, 

LBB, RAHC-5 

BOEM's Draft EIS fails to consider the greenhouse 

gas emissions that would be emitted by refining, 

transporting and burning the oil and gas to be 

extracted under its proposal. In evaluating the 

environmental impacts of the proposed action, NEPA 

requires BOEM to consider and describe the direct 

and indirect impacts. These impacts are distinct from 

one another. Direct effects are "caused by the action 

and occur at the same time and place." Indirect 

effects are caused by the action but, "are later in time 

or farther removed in distance, but are still 

reasonably foreseeable. Indirect effects may include 

growth inducing effects and other effects related to 

induced changes in the pattern of land use, 

population density or growth rate, and related effect 

on air and water and other natural systems, including 

ecosystems. Downstream greenhouse gas 

emissions are precisely the kind of indirect effects 

that BOEM must consider in analyzing the impacts of 

its leasing proposal.

Indeed, guidance from the Council on Environmental 

Quality instructs agencies that "[e]missions from 

activities that have a reasonably close causal 

relationship to the federal action, such as those that 

may occur . . . as a consequence of the agency 

action (often referred to as downstream emissions) 

should be accounted for in the NEPA analysis.' As it 

described, "[f]or example, a particular NEPA analysis 

for a proposed open pit mine could include the 

reasonably foreseeable effects of various 

components of the mining process, such as . . . 

refining or processing the resource, and using the 

resource . . . as the direct and indirect effects of 

phases of a single proposed action."

BOEM estimates that its proposal could result in the 

development and production of up to an estimated 

BOEM recognizes the importance of climate change

in its NEPA analyses and considers many facets of 

the potential effects of climate change in its 

decisionmaking with respect to oil and gas leasing, 

whether in the Five-Year Program or lease sale 

analyses. In the Five-Year Program EIS, BOEM 

compares greenhouse gas emissions from direct 

OCS emissions to those that could occur from 

energy substitutes that would presumably replace 

OCS production in the absence of a new OCS 

Program and comparable demand levels. 

Downstream greenhouse gases have been 

quantified. Please refer to the Five-Year Program 

EIS for additional information about how BOEM 

evaluates greenhouse gas emissions and climate 

change. BOEM expects that reducing OCS oil and 

gas consumption in the U.S. and the associated 

emissions from limiting OCS leasing would largely 

be offset by substitutes from other energy sources, 

either within the United States or elsewhere. BOEM 

has considered a no action alternative (i.e., 

cancellation of a proposed lease sale); however, 

that does not necessarily equate to zero 

downstream greenhouse gas emissions from oil and 

gas unless energy demand or supply changes 

drastically or cost-competitive clean energy sources 

are substituted.

This Multisale EIS tiers from the Five-Year Program 

EIS and has included additional information 

regarding greenhouse gas and downstream 

emissions information that may result from a Gulf of 

Mexico oil and gas lease sale in Chapter 4.1. 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-29

Commenter Comment ID Comment Response

9.5 billion barrels of oil equivalent. It is possible even 

more oil will be developed given BOEM 's estimates 

that put all undiscovered technically recoverable 

resources in the Gulf of Mexico at 73 billion barrels of 

oil equivalent. Using EPA's carbon equivalent 

calculator, this means that BOEM's proposal could 

result in up to roughly 4.1 to 31.4 billion metric tons 

of greenhouse gas emissions from consumption of 

the oil. But BOEM wholly failed to consider the 

impacts of these emissions or how allowing offshore 

oil and gas leases in federal waters will impact our 

ability to limit warming to 1.5 or 2°C consistent with 

the Paris Agreement.

Climate change, driven primarily by the combustion 

of fossil fuels, poses a severe and immediate threat 

to the health, welfare, ecosystems, and economy of 

the United States and the world. In recognition of 

these threats, the Paris Agreement- adopted by 

197 countries, including the United States, on 

December 12, 2015-codifies the international, 

scientific consensus that climate change is an 

"urgent and potentially irreversible threat to human 

societies and the planet and thus requires the widest 

possible cooperation by all countries." Accordingly, 

the Paris Agreement commits all signatories to an 

articulated target to hold the long-term global 

average temperature ''to well below 2°C above pre-

industrial levels and to pursue efforts to limit the 

temperature increase to l.5°C above pre-industrial 

levels." Immediate and aggressive greenhouse gas 

emissions reductions are necessary to keep warming 

below a 1.5° or 2°C rise above pre-industrial levels.

Put simply, there is only a finite amount of carbon 

dioxide ("C02") that can be released into the 

atmosphere without rendering the goal of meeting 

the 1.5°C (or even a 2°C) target virtually impossible. 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-30 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Globally, proven fossil fuel reserves, let alone 

additional recoverable resources, if extracted and 

burned, would release enough C02 to exceed this 

limit several times over. Consequently, the vast 

majority of fossil fuels must remain in the ground.

The physical question of what amount of fossil fuels 

can be extracted and burned without negating a 

realistic chance of meeting a 1.5°C or even 2°C 

target is relatively easy to answer. The Fifth 

Assessment Report of the International Panel on 

Climate Change ("IPCC") and other expert 

assessments have established global carbon 

budgets, or the total amount of remaining carbon that 

can be burned while maintaining some probability of 

staying below a given temperature target. According 

to the IPCC, total cumulative anthropogenic 

emissions of C02 must remain below about 1,000 

gigatons ("GtC02") from 2011 onward for a 66% 

probability of limiting warming to 2°C above pre-

industrial levels. The Paris Agreement aim of limiting 

the temperature increase to 1.5°C requires a more 

stringent carbon budget of only 400 GtC02 from 2011 

onward (of which more than 100 GtC02 has already 

been emitted) for a 66% probability of limiting 

warming to 1.5°C above pre-industrial levels. 

Increasing the odds of meeting these targets requires 

meeting even stricter carbon budgets. Given that 

global C02 emissions in 2014 alone totaled 36 

GtC02, humanity is rapidly consuming the remaining 

burnable carbon budget needed to have even a 66% 

chance of meeting the l.5°C temperature limit.

Recent analysis shows that the potential emissions 

from all U.S. federal fossil fuel resources are 

between 349 and 492 GtC02e, with unleased fossil 

fuels comprising 91% of these potential emissions. 

The OCS accounts for 64% of all unleased federal 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-31

Commenter Comment ID Comment Response

natural gas and 72% of all unleased federal oil, for an 

estimated total of between 52 and 62 GtC02e. In 

other words, unleased federal fossil fuels, if extracted 

and burned, would consume between roughly 70 and 

100% of a global budget of 450 GtC02e, the amount remaining at the start of 2016 under a budget 

scenario that itself has only a 66% chance of limiting 

temperature increase to 1.5°C. Unleased OCS areas 

alone would consume between 11.6% and 13.8% of 

that global budget. Continued leasing of these fossil 

fuels is incompatible with any reasonable domestic 

and international path to limiting warming to l.5°C or 

even 2°C.

Conversely, keeping fossil fuels in the ground by 

ending new offshore leases will help limit warming by 

reducing greenhouse gas emissions. For example, a 

recent report found that for each unit of oil that is not 

extracted from federal lands, net global consumption 

of oil and substitute fuels falls by 0.22 units by 2030, 

with a proportionate decrease in greenhouse gas 

emissions. Accordingly, the report estimates that 

ending new offshore and onshore oil leases would 

lead to a net reduction of global C02 emissions from 

oil of 31 MtC02 in the year 2030. Of this total, 85% 

(or 26 MtC02 in 2030) can be attributed to offshore 

oil leases covered by BOEM's Five-Year Program. 

And the reduction in greenhouse gas emissions 

would increase in the years after 2030.

Yet because BOEM ignores the impacts of 

consuming the oil and gas to be extracted under its 

proposal, BOEM wholly fails to discuss how its 

proposal can possibly be consistent with the Paris 

Agreement and efforts to limit warming to l.5°C or 

even 2°C to avert the worst impacts of climate 

change. This failure violates NEPA.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-32 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Center for 

Biological 

Diversity, Bold 

Louisiana, 

Gulf 

Restoration 

Network, 

Louisiana 

Bucket 

Brigade, 

Radical Arts 

and Healing 

Collective

(CBD, BL, 

GRN, LBB, 

RAHC), 

Kristen 

Monsell, 

Staff Atorney

CBD, BL, GRN, 

LBB, RAHC-7 

Offshore oil and gas development consistently 

results in both chronic and disaster-related oil spills. 

For example, in 1979, an exploratory well in the Gulf 

of Mexico blew out and spilled 140 million gallons of 

oil over the course of 10 months. In 1989, the Exxon 

Valdese spilled more than 11 million gallons of oil 

into Alaska's Prince William Sound. In 2004, 

Hurricane Ivan hit the Gulf of Mexico off the coast of 

Louisiana toppling an offshore well platform owned 

by Taylor Energy, which has been leaking gallons 

upon gallons of oil every day for over a decade, and

recent reports indicate a dramatic spike in the size of 

oil sheens and the volume of spilled oil since 

September, 2014. In 2009, the Montara oil rig spilled 

between 29,600 and 222,000 barrels of oil into the 

Timor Sea over the span of ten weeks. In 2010, BP's 

Deepwater Horizon rig exploded, causing estimated 

206 million gallons of oil to spill into the Gulf of 

Mexico over the course of almost three months.

These spills cause irreversible damage to marine 

and coastal environments, and the destructive 

impacts of large spills are immediate and severe. Oil 

spills and cleanup efforts are not just deadly to 

marine life, but also disruptive to ship traffic and 

detrimental to impacted shorelines, subsistence 

activities, commercial and recreational fishing, 

tourism, and the health of people living along the 

coast and people involved in clean-up efforts.

Nevertheless, BOEM largely dismisses the impacts 

of a catastrophic oil spill because oil and gas 

activities are regulated and changes have been 

implemented since Deepwater Horizon. But this selfserving assumption contradicts several federal 

studies published since the disaster finding that 

sufficient regulatory changes are still lacking. For 

example, a recent government report issued by the 

BOEM determined that, because a catastrophic 

event like the Deepwater Horizon explosion, oil spill, 

and response is not considered reasonably 

foreseeable as a result of a proposed action, the 

analysis should not be overly emphasized in this 

Multisale EIS to avoid confusion over whether it is or 

is not part of a proposed action. This is allowed 

under CEQ’s regulations that removed the 

requirement to analyze worst-case scenarios. The 

key to managing the risk of such an event is to 

implement a rigorous regulatory regime to ensure 

that postlease drilling activities are conducted in a 

safe manner. It is at this stage that detailed 

information regarding a specific proposed action is 

available for review, including reservoir 

characteristics, infrastructure designs, and features, 

to ensure safety and reduce environmental risk. For 

a detailed analysis of reasonably foreseeable 

impacts associated with a low-probability 

catastrophic spill, such as the Deepwater Horizon

explosion and oil spill, refer to the Catastrophic Spill 

Event Analysis technical report (USDOI, BOEM, 

2017). Additionally, the work of Ji et al. (2014) 

defined a reasonable range of potentially 

catastrophic spill sizes and applied extreme value 

statistics to historical spill data to describe the 

statistical likelihood of the occurrence of a 

catastrophic oil spill. While there are competing 

analyses (e.g., Eckle et al., 2012), BOEM believes 

the Ji et al. (2014) provides a more robust statistical 

analysis by utilizing both extreme value statistical 

methods and complementary risk assessment 

methods to characterize the potential frequency of a 

catastrophic spill event.
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-33

Commenter Comment ID Comment Response

U.S. Chemical Safety and Hazard Investigation 

Board found that the causes of the Deepwater 

Horizon oil spill still have not been fully addressed, 

leading to the distinct risk that another catastrophic 

spill will occur, especially in the context of deepwater 

drilling. This is particularly alarming considering that 

BOEM's Five-Year Program suggests that oil and 

gas activity in the Gulf of Mexico will be focused on 

drilling increasingly deepwater wells: ''the greatest 

undiscovered resource potential in the U.S. OCS is 

forecast to exist in the deep and ultra-deep waters of 

the [Gulf of Mexico]." In other words, oil companies 

will be drilling increasingly deeper wells-wells even 

deeper than that which led to the Deepwater Horizon 

spill-thereby increasing the risk of a catastrophic oil 

spill.

Another recent report from the U.S. Government 

Accountability Office found that BSEE, BOEM's sister 

agency, "has not fully addressed deficiencies in its 

investigative, environmental compliance, and 

enforcement capabilities identified by investigations 

after the Deepwater Horizon incident." It concludes 

that "BSEE continues to face deficiencies in each of 

these capabilities that undermine its ability to 

effectively oversee offshore oil and gas 

development." In a nutshell, another Deepwater 

Horizon catastrophe is not a question of if, but a 

question of when. BOEM must therefore analyze the 

impacts of a catastrophic oil spill as part of the 

proposed action.

Center for 

Biological 

Diversity, Bold 

Louisiana, 

Gulf 

Restoration 

Network, 

CBD, BL, GRN, 

LBB, RAHC-10

In evaluating the environmental impacts of the 

proposed action, NEPA requires BOEM to consider 

and describe the direct, indirect, and cumulative 

impacts. Cumulative impacts are those impacts that 

"result from the incremental impact of the action 

when added to other past, present, and reasonably 

foreseeable future actions regardless of what agency 

Thank you for your comment. Each resource 

chapter was reviewed, and clarifying language was 

added to ensure that the incremental, program, nonOCS, and reasonably foreseeable impacts were 

clearly identified.

The cumulative impacts chapters for land 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-34 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Louisiana 

Bucket 

Brigade, 

Radical Arts 

and Healing 

Collective

(CBD, BL, 

GRN, LBB, 

RAHC), 

Kristen 

Monsell, 

Staff Attorney

(Federal or non­Federal) or person undertakes such 

other actions. Cumulative impacts can result from 

individually minor but collectively significant actions 

taking place over a period of time." BOEM's Draft 

EIS fails to adequately consider the indirect and 

cumulative impacts of its proposal to adopt the 

preferred alternative and auction off yet more of the 

Gulf of Mexico to oil companies.

Specifically, BOEM wholly fails to actually analyze 

the impacts of the proposed action in light of other 

activities affecting the Gulf of Mexico because nonOCS activities generate more impacts, such as more 

air emissions than OCS activities. But NEPA 

requires agencies to consider all the significant 

impacts of their actions; it does not excuse 

consideration of one impact simply because another 

impact may be more significant.

Moreover, BOEM often concludes that the 

cumulative impacts from its proposal will not be 

significant because it is not significant compared to 

all the other impacts that affect the Gulf of Mexico. 

But, as its name suggests, when conducting a 

cumulative impacts analysis, BOEM must add the 

impacts of its proposal to all other past, present and 

reasonably foreseeable future impacts, not just 

compare the impacts. BOEM's failure to conduct a 

proper cumulative impacts analysis renders its Draft 

EIS fatally flawed.

use/coastal infrastructure and social factors have 

been edited to more clearly describe the 

incremental impact of one proposed lease sale 

when added to all past, present, and reasonably 

foreseeable future events. For more information on 

BOEM’s cumulative impacts analysis, refer to 

Chapter 4.0.2.3. 

Sierra Club,

Devorah 

Ancel, 

Staff Attorney

SC-1 BOEM must define the purpose and need for the 

proposed action based on an accurate picture of our 

nation's demand for and projected consumption of oil 

and gas in the decades to come. According to the 

EIA's energy outlook projections through 2040, crude 

oil consumption in the transportation sector will 

experience a gradual decline, underscoring that the 

need for new leasing and production is largely 

The determination of the U.S. energy needs is 

based on the U.S. Dept. of Energy’s Energy 

Information Administration's 2016 demand 

projections and is discussed in detail in the FiveYear Program. The Energy Information 

Administration is the principal Federal agency 

responsible for collecting, analyzing, and 

disseminating energy information to promote sound 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-35

Commenter Comment ID Comment Response

absent. The widespread implementation of federal 

policies improving fuel economy throughout the 

transportation sector will further reduce overall 

domestic oil consumption. Oddly, the DEIS makes 

the following contradiction without explanation: while 

"consumption of liquid fuels will decrease"... the 

nation will need to "rely on more oil" in the years to 

come. BOEM cannot simply rely on these 

contradictory statements to justify further drilling 

development in the Gulf of Mexico.

Further, the DEIS significantly overstates the nation's 

consumption of natural gas. The DEIS states that 

U.S. consumption of natural gas in 2014 was 

25.26 trillion cubic feet per day. However, the DEIS 

conflates annual with daily consumption, resulting in 

an inflation of consumption by a factor of 365. Accor 

ding to the EIA, 2014 annual U.S. natural gas 

consumption totaled 26.70 tcf. BOEM must rectify 

any conclusions it reaches about the purpose and 

need for the proposed lease sales if they are based 

on this inflated figure.

BOEM's conclusion that continued leasing and 

development of the Gulf is necessary as a longterm, stable energy supply and to provide economic 

security is in error. BOEM reasons that the current 

glut in onshore natural gas production and higher 

pricing on the world market is pushing industry to 

export excess natural gas, thus creating the need for 

additional offshore leasing. But, BOEM misses a 

critical point, evidenced by recent EIA and NERA 

studies, which is that as world demand and U.S. 

exports of natural gas increase, the accompanied 

increase in prices will cause U.S natural gas 

consumption to decline. BOEM's reasoning omits 

the critical point that a reduction in U.S. consumption 

will result, thus minimizing the demand for additional 

policymaking, efficient markets, and public 

understanding of energy and its interaction with the 

economy and the environment. The Energy 

Information Administration forecasts future energy 

demand and supply based on current laws and 

regulations. BOEM relies on special runs performed 

by the Energy Information Administration's National 

Energy Modeling System (NEMS) to feed its 

MarketSim model that, in turn, is used to determine 

changes in energy demand and energy substitutes 

under the No Action alternative.

The energy demand analysis from the Five-Year

Program is incorporated into this Multisale EIS 

through the tiering process. This Multisale EIS 

analyzes environmental and economic impacts and 

benefits for the alternatives, including the proposed 

action and No Action alternative (i.e., no new 

leasing).
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-36 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

natural gas supplies. Given the huge glut of natural 

gas supply serving the world market and domestic 

demand, these studies affirm the absence of 

additional demand for new offshore sources of oil 

and gas supply.

Moreover, the natural gas industry reports that the 

significant increase in unconventional natural gas 

production, due to technological advances such as 

horizontal and directional drilling and hydraulic 

fracturing, have led to a decrease in conventional 

production whereby conventional rigs such as those 

found in the offshore are mostly directed at oil 

drilling. Unconventional onshore natural gas plays 

are expected to comprise more than 80% of the 

natural gas production in the US by 2040, whereas 

conventional offshore production will decrease to 

approximately 6% of total production.

Further, the American Petroleum Industry report and 

the EIA and NERA studies all show that although 

demand for natural gas will gradually increase over 

the next two decades, overall domestic supply will 

surpass U.S. consumption and world market export 

demand combined. In addition, domestic supply will 

continue to respond to market fluctuations, and has 

the capacity to supply both world market export and 

domestic consumption demands even as they 

increase according to projections in the coming 

decades.

In addition, the high rates of onshore natural gas well 

shut-ins provide further evidence of the diminishing 

need to develop new offshore leases in the Gulf of 

Mexico under increased natural gas demand 

conditions. Because shut-in wells are readily 

capable of producing as market conditions become 

more favorable, the additional production capacity 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-37

Commenter Comment ID Comment Response

could fulfill demand in the unlikely scenario that there 

is a supply deficit.

BOEM also fails to acknowledge the sharp rise in 

exports of processed crude coming out of the Gulf 

Coast in recent years, and the potential for 

increasing exports given the recent lifting of the 

federal export ban for domestically produced raw 

crudes. Within this new context, Gulf of Mexico 

production may not actually serve domestic 

consumption needs as the Draft EIS contends. 

Thus, BOEM's unsubstantiated conclusion that new 

Gulf of Mexico leases are necessary to ensure 

domestic energy supply and economic security 

requires further analysis.

Sierra Club, 

Devorah 

Ancel, 

Staff Attorney

SC-2 BOEM also fails to evaluate the state of existing 

offshore Gulf leases. As of 2016, more than 

22 million acres of the Gulf of Mexico have been 

leased to the oil and gas industry, with additional 

lease sales scheduled in 2016. However, 

approximately 80% of the leased acreage has not yet 

been developed while much of the producing areas 

will continue to produce for the foreseeable future. 

These facts coupled with the glut of onshore natural 

gas supply and the projected decline in oil 

consumption in the decades to come are sufficient to 

meet current energy needs for the 2017 to 2022 

period and beyond, thereby refuting BOEM's alleged 

need to lease the remaining unleased blocks of the 

Gulf of Mexico.

The Draft EIS uses flawed reasoning and 

misinformation to erroneously narrow the purpose 

and need of the proposed action in order to justify 

leasing all remaining economically recoverable 

blocks of the Gulf. By asserting future energy 

demand is far greater than actual projections, BOEM 

has set itself up to select only one alternative and 

BOEM is responsible for administering the leasing 

program for oil and gas resources on the OCS and 

for developing a 5-year schedule of proposed lease 

sales designed to “best meet national energy needs 

for the five-year period following [the schedule’s] 

approval . . .” (Section 18 of the OCSLA [43 U.S.C. 

§ 1344]). The Five-Year Program is an important 

component of the President’s comprehensive 

energy strategy to allow for safe and responsible 

domestic oil and natural gas production as a means 

to support economic growth and job creation, and 

enhance energy security. As stated in Chapter 1.2 

of the Five-Year Program EIS (USDOI, BOEM, 

2016a), “Offshore oil and gas production represents 

approximately 11 percent of the total national oil and 

gas production. Domestic oil and natural gas 

supplies contribute to meeting domestic demand 

and enhance national economic security. The 

development of an OCS oil and gas lease sale 

schedule for 2017-2022 will facilitate domestic oil 

and gas production to meet this need.” This 

Multisale EIS tiers from the Five-Year Program EIS, 

which provides an analysis of existing and future 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-38 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

reject all other possible action alternatives in violation 

of NEPA and OCSLA.

leases and their sufficiency to supply the Nation’s 

energy needs.

For the GOM’s regionwide single lease sale 

analysis, all areas currently under lease are taken 

into consideration throughout the environmental 

analyses (i.e., cumulative impacts). The cumulative 

impacts analysis considers all of BOEM’s past, 

present, and reasonably foreseeable future actions, 

as well as other non-OCS oil- and gas-related 

activities.

Sierra Club, 

Devorah 

Ancel, 

Staff Attorney

SC-7 NEPA requires BOEM to "describe the environment 

of the areas to be affected or created by the 

alternatives under consideration." Thus, the 

establishment of the baseline conditions of the 

affected environment is a fundamental requirement 

of the NEPA process. "Without establishing the 

baseline conditions which exist in the vicinity . . . 

there is simply no way to determine what effect the 

proposed [project] will have on the environment and, 

consequently, no way to comply with NEPA."

BOEM lacks critical information regarding the effects 

of the Deepwater Horizon oil spill on the Gulf of 

Mexico. The Deepwater Horizon disaster resulted in 

the deaths of 11workers and caused a spill of 

approximately 206 million gallons of oil over the 

course of at least 87 days.

More than 1,000 miles of shoreline were 

contaminated with oil; 88,522 square miles of oceantotaling one-third of the Gulf of Mexico-were closed 

to commercial and recreational fishing; millions of 

animals were killed or harmed; and local residents 

were sickened.

Six years later, the Gulf is still reeling from the effects 

Thank you for your comment. BOEM acknowledges 

that there is some lingering uncertainty regarding 

the impacts of the Deepwater Horizon oil spill. 

However, this uncertainty has diminished as time 

passes and as new data and studies have become 

available. In addition, BOEM has complied with 

NEPA procedures for dealing with incomplete or 

unavailable information. BOEM has made some 

changes to this Multisale EIS in light of this 

comment in order to clarify the nature of the 

incomplete or unavailable information related to the 

impacts of the Deepwater Horizon oil spill on the 

baseline conditions of various resources.

Current baselines are described for all resources 

under their respective “Description of the Affected 

Environment” chapters. Specific to the Trustees’ 

PDARP/PEIS (Deepwater Horizon Natural 

Resource Damage Assessment Trustees, 2016), 

the altered baseline includes individual protected 

species directly affected by this unexpected unique 

catastrophic event. BOEM understands that each 

oil-spill event is unique and that its outcome 

depends on several factors, including time of year 

and location of the release relative to winds, 

currents, land, and sensitive resources, as well as 

specifics of the well and response effort. BOEM 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-39

Commenter Comment ID Comment Response

of the spill. Recent studies demonstrate severe lung 

disease in dolphins; near-record lows of critically 

endangered Kemp's Ridley sea turtle nesting; oil 

dispersants toxic to corals and jellyfish; and a 

"bathtub ring" of oil on the seafloor. Another recent 

study published in April 2016 indicates that the spill 

impacted 19% more coastline that originally 

observed, finding that oil washed up on 1,313 miles 

of coastline along the Gulf of Mexico. In addition, the 

50,000 people involved in cleanup efforts suffer from 

an increased risk of physical and psychological 

injury. Gulf residents are still suffering from 

increased symptoms of depression, anxiety, mental 

illness, and posttraumatic stress.

However, the impacts of the spill are not yet fully 

understood and are still being studied. For example, 

the Natural Resource Damage Assessment, which 

assesses spill impacts to natural resources and 

informs future restoration is still underway. 

Moreover, BOEM has repeatedly admitted in other 

environmental review documents that there are data 

gaps regarding numerous resources in the Gulf of 

Mexico, including wetlands, coastal water quality, 

offshore water quality, air quality, commercial and 

recreational fishing and environmental justice, and 

that the impacts of the Deepwater Horizon oil spill on 

such resources may have changed baseline 

conditions.

Further, BOEM has not yet completed its Section 7 

consultation under the ESA following the Deepwater

Horizon oil spill. BOEM therefore does not have an 

accurate picture of the effects that authorizing more 

offshore oil and gas leasing and drilling (including in 

the very same area where the Deepwater Horizon 

spill occurred) could have on already imperiled

species.

also understands that the severity of impacts from 

an oil spill cannot be predicated on volume alone. 

BOEM has analyzed a low-probability catastrophic 

event (USDOI, BOEM, 2017) in conjunction with its 

analysis of potential effects, as requested by CEQ 

pursuant to its regulation at 40 CFR § 1502.22. A 

low-probability catastrophic spill is, by definition, not 

reasonably certain to occur. Other methods of 

analysis are significantly limited in their applicability 

and availability and they would not provide any 

meaningful or useful information to be used to 

assess the risk of a catastrophic spill occurrence at 

this programmatic level of OCS oil- and gas-related 

activities in the GOM. The return period of a 

catastrophic oil spill in OCS areas is estimated to be 

165 years, with a 95 percent confidence interval 

between 41 years and more than 500 years 

(Ji et al., 2014).

BOEM's produced-water data is collected from the 

Office of Natural Resources Revenue (ONRR). The 

ONRR's “Oil and Gas Operations Report” (OGOR) 

collects produced-water data, which can be found 

on ONRR’s website at http://www.onrr.gov/

ReportPay/production-reporting.htm). The OGOR-B 

report includes a disposition code to indicate how 

the produced water is disposed of (i.e., injected on 

lease, injected or transferred off lease, or disposed 

of). BOEM does not manage USEPA’s data. It is 

likely that data collected in different databases will 

be different. Despite the difference, BOEM 

considers the potential impacts from the offshore 

discharge of produced water to be negligible beyond 

1,000 m (3,281 ft) from the discharge point to 

moderate within 1,000 m (3,281 ft). The 

conclusions reached in this Multisale EIS remain the 

same, regardless of which estimate is used.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-40 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Accordingly, BOEM cannot properly define the 

environmental baseline, and BOEM cannot conduct a 

proper NEPA analysis unless and until these 

significant data gaps are filled. As such, any 

decision by BOEM to allow substantially more 

offshore oil and gas drilling is arbitrary and 

capricious.

In response to the harmful effects of produced 

water, additional language describing how USEPA 

regulates these discharges to prevent unreasonable 

degradation of the receiving waters has been added 

to Chapter 4.2.2.1. 

Regarding wetlands, please refer to the updated 

text in Chapter 4.3. The NRDA studies are 

ongoing, but the Trustees’ PDARP/PEIS has been 

released and analyzed for relevant information. 

With the release of the Trustees’ PDARP/PEIS, our 

understanding of the environmental impacts of the 

Deepwater Horizon explosion, oil spill, and 

response has greatly increased; however, there are 

many ongoing long-term and monitoring studies that 

are not complete. Therefore, our understanding of 

the lasting effects or long-term recovery of the 

system is still incomplete and has data gaps, but the 

information is not essential to a reasoned choice 

among alternatives.

BOEM has revisited the baseline descriptions for 

the land use/coastal infrastructure and social factors 

sections and does not agree that enough evidence 

exists yet to conclusively determine that the 

Deepwater Horizon explosion, oil spill, and 

response has changed the baseline conditions. 

However, some additional clarifying language and 

references have been added to supplement the 

baseline descriptions and the cumulative impacts 

analysis contained in the Draft Multisale EIS.

Sierra Club, 

Devorah 

Ancel, 

Staff Attorney 

SC-10 BOEM makes many decisions about the unique 

characteristics of deepwater drilling as well as other 

site specific decisions at the post lease stage. This 

includes reviews of oil spill response plans and 

exploration and development plans. The Draft EIS 

states that various mitigation stipulations may be 

required on a given lease but that Supplemental 

The OCSLA requires a staged decisionmaking 

process beginning with the Five-Year Program, 

continuing through individual lease sales under the 

Five-Year Program, and ultimately to individual 

postlease activities requiring a permit or approval. 

As stated in Chapters 1 and 2, this Multisale EIS 

discusses all 10 Federal actions, i.e., 10 proposed 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-41

Commenter Comment ID Comment Response

Environmental Impact Statements will not be 

prepared for individual lease sales, thereby 

preventing the public from weighing in on the unique 

risks and areas of concern in a particular lease sale. 

This is especially troubling because BOEM's failure 

to consider the high-temperature/high pressure 

conditions and water depths in the Draft EIS risk 

assessment means that it makes critical decisions 

about the unique and high risk conditions of ultradeepwater drilling at the post-lease stage without any 

public and essential stakeholder participation. As 

described in more detail below, BOEM's area-wide 

lease sale proposal encompasses a variety of 

diverse ecosystems and species habitat, as well as 

high risk landscapes that may require specialized 

protections and mitigation. Absent site specific 

impact analyses and mitigation determinations, 

certain regions may not be given the special

protections they deserve.

The deferral of analysis is particularly troubling given 

that site specific analysis often does not occur in the 

post-lease process as the Draft EIS states. Instead, 

environmental assessments often tier back to the 

leasing analysis. BOEM cannot escape performing 

site specific analyses by claiming it is done at later 

post-lease stages when it claims in those stages that 

the analysis was done at the leasing sale. This 

approach violates BOEM's duties under OCSLA to 

comply with NEPA and the ESA at every stage of the 

offshore oil and gas authorization process and its 

duty to ensure offshore developments are balanced 

with environmental safeguards and protection of the 

human, marine and coastal environments. 

Moreover, BOEM's approach also directly contradicts 

the National Commission on the BP Deepwater 

Horizon Oil Spill and Offshore Drilling's 

("Commission") express recommendation that BOEM 

regionwide oil and gas lease sales, as scheduled 

under the Five-Year Program. The multisale EIS 

approach is intended to focus the NEPA/EIS 

process on the staged OCSLA process for 

decisionmaking, including the proposed lease sales 

and any new issues and information identified since 

a prior stage. It also lessens duplication and saves 

resources when BOEM and BSEE conduct 

postlease reviews.

Pursuant to NEPA, this Multisale EIS analyzes a 

range of alternatives, but NEPA does not require 

carrying all alternatives considered through a full 

analysis of impacts. BOEM has ensured that a 

reasonable range of alternatives to a proposed 

action, within the framework of the Five-Year 

Program, has been considered in this Multisale EIS. 

Chapter 2.2.3 discusses additional alternatives 

considered but eliminated them based on the best 

available information currently available. As noted 

in Chapter 1.3.1.2, any individual lease sale could 

still be scaled back during the prelease sale process 

to offer a smaller area should circumstances 

warrant. Additionally, the issuance of leases does 

not conclude the environmental analysis of planned 

OCS oil- and gas-related activities. Each plan 

throughout the exploration, production, and 

decommissioning processes receives a site-specific 

environmental analysis pursuant to NEPA and the 

OCSLA’s pyramidal structure going from large scale 

to site specific. For more information on BOEM’s 

postlease processes, please refer to Appendix A. 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-42 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

conduct environmental review on a finer geographic 

scale.

BOEM's proposed area-wide lease sale approach in 

the DEIS makes post-lease analyses and decision 

making, and tiered assessments even more 

problematic. The area-wide lease sales combine 

70 million acres from three separate planning areas - the Western Gulf, the Central Gulf and the Eastern Gulf - each with distinct ecological features. For 

example, the Western Region "hosts the northern 

most tropical coral reef system in the United States 

at the Flower Garden Banks, an isolated system of 

predominately encrusting corals atop salt dome 

formations." The system attracts reef fishes and 

large open-water species such as hammerhead and 

whale sharks. The Western Region is also "home to 

some of the most important nesting sites for the 

endangered Kemp's Ridley sea turtle." The Central 

Region is home to a resident population of 

endangered sperm whales, and the Eastern Region 

includes manatee habitat. The Louisiana coastline 

contains a variety of wetlands that make up one of 

the largest deltas in the world. Moreover, the line 

between the Western and Central Regions and the 

Eastern Region follows the De Soto Canyon off the 

coast of Alabama and traces the eastern edge of the 

Loop Current, which effectively divides the Gulf. The 

Gulf's size and variation clearly require greater 

specificity in the size and location of lease sales. By 

combining these diverse regions into a single 

analysis, BOEM violates OCSLA's express 

requirement to prepare a leasing program that 

consists "of a schedule of proposed lease sales 

indicating, as precisely as possible, the size, timing, 

and location of leasing activity." Further, this 

approach has been cited as particularly problematic 

by the Commission, which noted that the area-wide 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-43

Commenter Comment ID Comment Response

leasing approach favors industry at the cost of 

meaningful environmental analysis.

Expressly contradicting the Commission's 

conclusions and directives, as well as statutory 

requirements, BOEM asserts that it is proposing an 

area-wide approach to provide greater flexibility to 

industry and balance agency workload. BOEM does 

not have "carte blanche to wholly disregard a 

statutory requirement out of convenience." Nor can it 

abdicate its statutory duties under OCSLA or NEPA 

to appease industry. The designation lacks the 

precision required by statute and is therefore 

unlawful.

Lone Star 

Chapter of the 

Sierra Club

(LSCSC), 

Cyrus Reed, 

Conservation 

Director

LSCSC-2 Second, we want to state upfront our concerns with 

continued drilling in the Gulf, as contemplated in this 

EIS. Even without future leases, there are existing 

leases for much of the Gulf that will continue to 

operate, and BOEM must consider the impact of 

these existing leases as part of the process of 

looking at its future potential leasing. BOEM has 

already leased over 23 million acres of the Gulf to oil 

companies, and nearly three million acres of the 

Alaskan Arctic. Many of the leases in the Gulf of 

Mexico are relatively new leases, meaning that, by 

BOEM's own admission, production under these 

leases will last up to 70 years. BOEM's analysis 

wholly fails to consider why the OCS areas already 

under lease are not sufficient to supply the nation's 

energy needs while we transition away from dirty 

fossil fuels and toward clean, sustainable energy.

BOEM is responsible for administering the leasing 

program for oil and gas resources on the OCS and 

for developing a 5-year schedule of proposed lease 

sales designed to “best meet national energy needs 

for the five-year period following [the schedule’s] 

approval . . .” (Section 18 of the OCSLA [43 U.S.C. 

§ 1344]). The Five-Year Program is an important 

component of the President’s comprehensive 

energy strategy to allow for safe and responsible 

domestic oil and natural gas production as a means 

to support economic growth and job creation, and 

enhance energy security. As stated in Chapter 1.2 

of the Five-Year Program EIS (USDOI, BOEM, 

2016a), “Offshore oil and gas production represents 

approximately 11 percent of the total national oil and 

gas production. Domestic oil and natural gas 

supplies contribute to meeting domestic demand 

and enhance national economic security. The 

development of an OCS oil and gas lease sale 

schedule for 2017-2022 will facilitate domestic oil 

and gas production to meet this need.” This 

Multisale EIS tiers from the Five-Year Program EIS, 

which provides an analysis of existing and future 

Gulf 

Restoration 

Network, 

Johanna de 

Graffenreid

GRN-2 There are currently enough leases to meet energy 

and market demands.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-44 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Gulf 

Restoration 

Network, 

Howard Page 

GRN-5 One, I would like to ask that we issue no new leases. 

19 percent of the leases are being drilled right now. 

Extracted. That means 81 percent of our present 

capacity isn't even being used. So I would like to see 

a policy of no new leases ... 

leases and their sufficiency to supply the Nation’s 

energy needs.

For the GOM’s regionwide single lease sale 

analysis, all areas currently under lease are taken 

into consideration throughout the environmental 

analyses (cumulative impacts). The cumulative 

impacts analysis considers all of BOEM’s past, 

present, and reasonably foreseeable future actions, 

as well as other non-OCS oil- and gas-related 

activities.

Yolanda 

Ferguson

YF-1 Well, there -- you know, there's been -- we wonder 

about all the leases that are out there that have been 

drilled and left. You know, just have already been 

lease, but are there waiting. Why do we need to get 

new leases if we have all these leases that aren't 

producing wells?

Lone Star 

Chapter of the 

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

LSCSC-8 BOEM has failed to consider the large potential for 

alternative energy development in the Gulf, including 

offshore wind, floating solar, tide and wave 

technology and associated onshore development. 

While BOEM had considered a 50-mile offshore wind 

zone in the Atlantic as part of the programmatic EIS, 

it has failed to consider the validity of a similar zone 

along the Gulf to promote the use of alternative 

energy. While care would be needed to assure 

protection of migratory mammal and bird species in 

the development of offshore wind, solar or wave 

technology, the potential economic development, 

energy production and job creation is enormous and 

should not be undermined for a fuel with such 

significant public health and environmental 

consequences. We know that in Texas, several wind 

companies have been looking at offshore wind at 

least within the state-owned water and they have 

found valid potential. Yet BOEM is not considering 

the potential that we could be impacting future

renewable development by opening up parts of the 

Gulf for oil and gas development.

BOEM determined that an analysis of the potential 

for alternative energy is outside the scope of this 

Multisale EIS for a proposed action. The purpose 

and need identified for this Multisale EIS is to 

provide an analysis of the environmental impacts of 

oil and gas leasing. However, BOEM does 

recognize the need to investigate the potential for 

alternative energy on the Federal OCS, and this is 

addressed in the Five-Year Program EIS (Chapters 

1.4.6.1 and 2.7.4) from which this Multisale EIS 

tiers. BOEM's Office of Renewable Energy is 

responsible for developing an offshore renewable 

energy program in the Gulf of Mexico. Information 

on BOEM’s renewable energy program, OCS 

leases, and renewable energy projects 

(34 proposed or currently in development) is 

available at on BOEM’s website at 

http://www.boem.gov/Renewable-Energy/. 

Per Section 18 of the OCSLA, BOEM is required to 

develop a schedule of oil and gas lease sales on the 

OCS for 5-year periods. Thus, the OCSLA is the 

implementing legislation driving the purpose, and it 

is the law requiring the Secretary of the Interior to 

propose an action. The need is founded in the 

sources of energy consumption in the United States 

that were presented in the Draft Multisale EIS. The 

Cyrus Reed CR-1 So, these are just some observations I am going to 

make -- and I will do written comments – but No. 1 is: 

I feel like one of the alternatives that they didn't look 

at that they could have is the potential of the ocean's 

for alternative energy. And what I mean by that is, 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-45

Commenter Comment ID Comment Response

this is an EIS about oil and gas leasing, but there is 

tremendous potential for offshore wind, we know 

from the studies that have been done in Texas. So, 

they could consider an alternative of having a zone 

set aside for offshore wind. There's other 

alternatives, like wave technology and tidal 

technologies, that they could look at because to me, 

that -- if you are going to do a true EIS, you need to 

look at all the alternatives, not just the oil and gas 

leasing. So, I would like them to consider that in the 

EIS as an alternative, either in lieu of offshore oil and 

gas leasing or at least as a part of it, you know, 

creating a -- say a 50-mile zone in the regions where 

there is sufficient wind to do that, I think would make 

a lot of sense because I think that's the way the world 

is going and I think we are going to eventually 

electrify our grid and we are not going to rely on oil 

and gas so much. You know, we will for a while, but 

not as much as we do today. So, I would like them to 

do that.

proposed action under NEPA is the proposed lease 

sales identified in the Draft Proposed Program, and 

the Draft Multisale EIS determined possible 

environmental impacts of a proposed action in 

comparative form to other lease sale alternatives 

allowable under Section 18 of the OCSLA, including 

the No Action alternative (i.e., no lease sale). Thus, 

the Secretary of the Interior has the ability to choose 

any of the alternatives, including the No Action 

alternative, after weighing possible benefits and 

adverse environmental impacts. The NEPA 

requires that agencies shall propose actions, and 

alternatives to that action, that meet the purpose 

and need. This means that decisions outside the 

scope of Section 18 of the OCSLA cannot be 

considered as reasonable alternatives (e.g., 

renewable energy substitutions and energy 

efficiency measures).

Rachel Walsh RW-2 I also feel that the Bureau of Ocean Management 

fails to realize the great potential the Gulf has for 

alternative and renewable energy development 

including offshore wind, floating solar, tide and wave 

energy and associated onshore development. I think 

those are the types of things that we should be 

pursuing instead if we're serious about combating 

climate change.

Hilton Kelley HK-5 So, we need to do more to help protect our Gulf. We 

need to do more to explore renewable energies in 

ways we could get off of fossil fuels and ways we can 

save our wildlife. Because as we know, a lot of birds 

each year get caught in some of the oil spills 

because they can't differentiate whether or not it's 

water or oil in the water when they land and they are 

being destroyed.

Robert 

Desmarais 

RDS-2 This hearing is intended to discuss the environmental 

impacts of the planned leases. I can do that. The 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-46 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Sullivan Draft Environmental Impact Statement available on 

the website is a rhetorical hodge-podge of deception 

from start to finish. It outlines in detail all possible 

impacts on all possible creatures, and it states that 

impacts on every living creature except human 

beings will be minor or negligible. Only on human 

beings is impact said to be important. It suggests the 

likelihood of an accident is minimal. This poppycock 

is unacceptable in a government document 

purporting to be scientific. We heard this routine 

years ago about the Deepwater Horizon. I am 

delighted at least that the walrus is not on its list of 

potentially impacted creatures. ...AND SO, VOILA! 

As requested, I have commented on the 

environmental impact statement, AND NOW I will 

address the question of whether there should even 

be leases at all....There would be no need to 

evaluate an environmental impact statement, if the 

arrogant perversion of the act of leasing was 

acknowledged The Gulf of Mexico is not for sale. 

The Bureau of Ocean Energy Management does not 

have the moral right to lease it. Our lands, waters 

and air are not mere resources for the petrochemical 

industry. They are the air, water and land of the 

human race....In addition, the President of the United 

States has signed the Paris Accords, which state that 

fossil fuels must be reduced in order to keep the 

Earth's temperatures below 1.5 degrees above pre-

industrial levels, so the Gulf is being offered for lease 

in contradiction of this accord. Because the US has 

signed onto the accord, it is immoral if not illegal for 

these leases to be considered at all. If that moral 

principle is not recognized at this time, the young 

people will force recognition in coming years, furious 

with this generation's greed....This is a moral, not a 

legal, issue. Cleaning the planet is a moral, not 

legal, objective. Industry and government have no 

choice but to change. We have to keep the Earth 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-47

Commenter Comment ID Comment Response

clean for our own survival. We do not need science 

to tell us this, though we have scientists telling us 

this....Right now in the first two weeks of May, we are 

seeing demonstrations around the world demanding 

we break free of fossil fuels. Residing in Louisiana, 

where our federal senators and all representatives 

except Cedric Richmond, deny that man's actions 

have to do with warming the Earth, we may of course 

be discouraged. We may just wonder where the 

denials come from. Then I remember. They come 

from elegant lunches with petrochemical-industry 

lobbyists. The Industry has known for years that 

burning fossil fuels produces climate change, but our 

officials somehow do not know.... We now live in a 

post-Paris world. The treaty was signed on April 20, 

Earth Day, by leaders of 175 countries, including the 

United States. It is a time to proclaim with dear 

voices and demonstrate with strong actions that we 

will create a new Louisiana with clean water, dean 

air, clean soil and clean energy.

Ronald Kardos RK-1 President Obama has concluded that we must move 

toward renewable energy sources and away from 

fossil fuel production and use.

Thank you for your comment. During preparation of 

this Final Multisale EIS, BOEM was working under 

President Obama’s The All-of-the-Above Energy 

Strategy as a Path to Sustainable Economic Growth

(All-of-the-Above Energy Strategy) (The White 

House, 2014), which has three main goals: to 

support economic growth and job creation; to 

enhance energy security; and to deploy low-carbon 

energy technologies and lay the foundation for a 

clean energy future. According to that plan, oil and 

natural gas supplies are integral to meeting national 

energy demand. For more information, please refer 

to The White House’s website (The White House, 

2014).

This plan also aligns with President Trump’s 

America First Energy Plan, which calls for energy 

policies that stimulate our economy, ensure our 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-48 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

security, and protect our health. For more 

information, please refer to The White House’s 

website (The White House, 2017).

Lone Star 

Chapter of the 

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

LSCSC-9 In addition, BOEM has failed to adequately analyze 

special places in the Gulf that deserve special 

protection. In addition to the needs of key species 

like sea turtles, and migratory birds, no leases should 

even be considered in, near or next to any 

topographic high marine ecosystems. Some of these 

topographic highs that should be provided additional 

buffer protection include East Flower Garden Bank, 

West Flower Garden Bank, Horseshoe Bank, Stetson 

Bank, Stetson Ring, Claypile Bank, 32 Fathom Bank, 

Applebaum Bank, Coffee Lump Bank, 28 Fathom 

Bank, McGrail Bank, Bright Bank, Rezak Bank, 

Geyer Bank, Elvers Bank, MacNeil Bank, Sonnier 

Bank, Bouma Bank, Sidner Bank, Parker Bank, 

Alderdice Bank, Jakkula Bank, 29 Fathom Bank and 

Rankin Bank. In particular, the Flower Garden Banks 

National Marine Sanctuary should have a large buffer 

area around any potential lease block. The BP Deep 

Horizon disaster showed what can happen at and 

below the surface when large quantities of oil and 

gas are released. "Russian Roulette" should not be 

played with the long-term health of these important 

topographic high marine ecosystems.

BOEM appreciates your comments and has 

considered them in preparing this Final Multisale 

EIS. Additional information has been added to 

Chapter 2.2.3 regarding an alternative 

encompassing a potential boundary expansion of 

the Flower Garden Banks National Marine 

Sanctuary. Essentially, this Multisale EIS’s 

Alternative D bounds the preferred alternative 

proposed by NOAA in the Draft Flower Garden 

Banks EIS. For more information on critical habitat 

for sea turtles, birds, or marine mammals, refer to 

Chapter 4.9. 

LSCSC-10 While we recognize that there is a separate process 

going on to consider expansion of the Flower Garden 

Banks Sanctuary through a separate process, we 

would strongly insist that no development be 

considered in the area near a potential expansion. 

Indeed, we believe a large buffer area must be 

considered whatever the decision on expansion of 

the Flower Garden area is. As an example, currently 

NOAA is considering five alternatives, with 

Alternative Five encompassing more than 

930 square miles. BOEM should not consider any 

drilling in this large area.
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-49

Commenter Comment ID Comment Response

As NOAA states in the justification of the expansion 

discussion, "Additional exploration in the 

northwestern Gulf of Mexico has identified other 

reefs, banks and associated features that may be 

ecologically linked to FGBNMS and may also be 

highly vulnerable to certain human caused impacts. 

Although many of these areas have some level of 

protection through other designations, inclusion in 

the sanctuary would provide a comprehensive 

management framework to fill in the existing 

regulatory gaps and provide necessary protection to 

these critical habitats."

ConocoPhillips

, 

Richard 

Lunam, 

VP E&P, 

North America 

Exploration

CP-1 Conoco Phillips recommends that the BOEM apply 

the findings of its "Best Available Science" (BAS) 

analysis to operating scenarios that accurately reflect 

actual routine oil and gas activities. The BOEM 

should provide explicit documentation of what 

constitutes BAS, including the actual scientific 

experiments and practices currently in place, as well 

as how it was specifically applied to the MSEIS, 

including any rationale for its selection and use of 

BAS criteria. This can be achieved by the BOEM 

demonstrating its progression through the scientific 

method by clearly communicating its (i) foundation 

for and creation of hypotheses; (ii) experiments that 

test its hypotheses; (iii) detailed analysis and any 

conclusion(s) drawn. The experiments and analysis 

should be conducted using BAS strictly comprised of 

the most recently updated technology(ies) to monitor 

and assess realistic impacts of every day oil and gas 

activities. ConocoPhillips is concerned that the BAS 

that is utilized in the MSEIS process may not be 

applied in realistic settings consistent with standard 

oil and gas industry practices in use today or the 

foreseeable future. For example, in the 2014 Atlantic 

Programmatic Environmental Impact Statement, the 

BOEM purposely developed their study to be 

The Department of the Interior has adopted the 

definition of scientific and scholarly integrity as the 

condition resulting from adherence to professional 

values and practices, when conducting and applying 

the results of science and scholarship, that ensures 

objectivity, clarity, reproducibility, and utility and that 

provides insulation from bias, fabrication, 

falsification, plagiarism, outside interference, 

censorship, and inadequate procedural and 

information security.

For more information on this policy and for contact 

information for BOEM’s Scientific Integrity Officer 

(http://www.doi.gov/scientificintegrity/ScientificIntegrity-Officers.cfm), visit DOI’s webpage on the 

Integrity of Scientific and Scholarly Activities 

(http://www.doi.gov/scientificintegrity/index.cfm). 

The analysis in this Multisale EIS is centered on the 

application of credible scientific research. In the 

vast majority of these references, the methods used 

to conduct the research are explained. The studies 

cited in the references are publicly available and the 

“explicit documentation of what constitutes [best 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-50 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

conservative by modeling its acoustic monitoring 

impact on marine mammal analysis at the highest 

sound levels and always at maximum power and 

operation. Further, the model estimated marine 

mammal population densities affected by the oversimulated acoustics were likely exceeding actual 

population densities. Essentially, the agency 

adopted a worst-case scenario with an extremely low 

probability of occurrence, an approach inconsistent 

with the objectives of the 5 Year Plan and its 

subsequent administration. ConocoPhillips strongly 

advocates an appropriate application of the BAS 

approach and encourages replication of BOEM's 

inclusion of new and updated science as found in 

recent offshore EIS documents, such as that utilized 

in the Chukchi Sea Environmental Studies Program 

for the Alaska OCS. ConocoPhillips is opposed to 

the BOEM utilizing mitigations resulting from (i) the 

use of dated technologies for new studies or the 

reapplication of findings from previous studies that 

used out-of-date technology; and (ii) the use of any 

study outside the parameters of normal conditions 

where oil and gas activities are occurring.

available science] BAS” would be too extensive to 

detail in an EIS. However, in numerous places in 

this Multisale EIS, where it was considered 

important or when BOEM had derived independent 

methods for evaluating a resource, these methods 

are included in the descriptions in the text or specific 

methodologies were summarized, e.g., the 

calculation of OCS oil- and gas-related service 

vessels. BOEM’s subject-matter experts have 

clarified in this Multisale EIS where incomplete or 

unavailable information may be essential to a 

reasoned choice among alternatives, if the 

information could be obtained or, if the costs of 

obtaining it are exorbitant, and that what 

scientifically credible information is available was 

applied using accepted scientific methodologies.

BOEM has used the most relevant, up-to-date, and 

credible science throughout the preparation of this 

Multisale EIS, including throughout the development 

of the oil and gas hydrocarbon forecasts and activity 

scenarios. BOEM has presented a robust range to 

reasonably bound low and high activity levels for 

each alternative for each proposed lease sale. 

BOEM does not expect every proposed lease sale 

to reach the highest high or lowest low of the 

scenario forecasts but that it will fall within the 

reasonable range presented in Tables 3-1 and 3-2. 

BOEM continues to pursue and utilize the most 

relevant, up-to-date, and credible science in 

development of this Final Multisale EIS and 

subsequent NEPA documents.

Renate 

Heurich

RH-8 One concern, one thing that -- I also read that the 

studies that BOEM relied on, eight of the nine studies 

as far as the environmental impact is concerned 

were done by companies tied to the oil industry, and 

so what do you expect? It should be really 

independent studies, you know, not funded by the 

companies who obviously have their own interest.

ConocoPhillips

, 

Richard 

Lunam, 

VP E&P, 

North America 

CP-2 ConocoPhillips supports BOEM's intent to analyze all 

of the Gulf of Mexico regardless of certain areas 

being excluded for 5 Year Plan activity as provided in 

the DPP. It is important to assess all of the Gulf of 

Mexico in the MSEIS as currently excluded areas 

may potentially be available for activity in future Five 

BOEM’s preferred alternative for a proposed action 

states that this alternative would offer for lease all 

available unleased blocks within the WPA, CPA, 

and EPA portions of the proposed lease sale area 

for oil and gas operations (Figure 2-1), with the 

following exceptions:
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-51

Commenter Comment ID Comment Response

Exploration Year OCS Oil and Gas Leasing Programs due to 

increased efforts to emphasize safety and 

environmental awareness leading to fewer incidents. 

Since 2010, industry and federal government 

process improvements focusing on enhanced spill 

prevention and response have significantly 

strengthened the systems that ensure wells are 

drilled safely and with very little environmental 

impact.

(1) whole and portions of blocks deferred by the 

Gulf of Mexico Energy Security Act of 2006 

(discussed in the OCS Regulatory 

Framework white paper [Cameron and 

Matthews, 2016]); 

(2) blocks that are adjacent to or beyond the 

United States’ Exclusive Economic Zone in 

the area known as the northern portion of the 

Eastern Gap; and

(3) whole and partial blocks within the boundary 

of the Flower Garden Banks National Marine 

Sanctuary. (This boundary could be modified 

to encompass any future expansion to the 

Flower Garden Banks National Marine 

Sanctuary by NOAA.)

Therefore, the areas of the EPA that were analyzed 

in this Multisale EIS are those regions not deferred 

by the Gulf of Mexico Energy Security Act and, due 

to early transboundary discussions with Mexico and 

Cuba, the area known as the northern portion of the 

Eastern Gap. To be clear, as of the publication of 

this Multisale EIS, the blocks are not being offered, 

just analyzed should they be included in a future 

lease sale after a Transboundary Agreement has 

been negotiated between the U.S., Mexico, and 

Cuba, and at which time a separate NEPA decision 

would be made.

ConocoPhillips

, 

Richard 

Lunam, 

VP E&P, 

North America 

Exploration

CP-4 In conclusion, ConocoPhillips calls for a fair and 

justifiable MSEIS to help administer the GOM Lease 

Sales so that BOEM maintains access and activity 

levels as provided in the DPP. All portions of the 

Gulf of Mexico that have been ruled inaccessible for 

this 5 Year Plan should be analyzed in accordance 

with NEPA 's standards for potential environmental 

impact in order to provide reasonable foundation for 

Thank you for your comment. The proposed lease 

sale area identified in the Area Identification memo 

was included for analysis for this NEPA document. 

The OCSLA mandates that BOEM reevaluate the 

OCS Oil and Gas Program every 5 years, and any 

potential expansion of the Five-Year Program would 

be evaluated at that stage.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-52 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

consideration in future Five Year OCS Oil & Gas 

Leasing Programs.

Susan 

Feathers

SF-2 Concerns: the overall chart of potential impacts (EIS 

Chart) shows mostly negligible to minor impacts to 

beneficial impacts. Is there undo influence from oil 

and gas industries (money, Congressional pressure) 

that influence outcomes (even if unwarranted)! Just 

a question that, as a citizen, I must ask.

BOEM follows/implements a transparent NEPA 

process to ensure that all stakeholders (i.e., Federal 

and State agencies [comments and consultations], 

Tribes, nongovernment organizations, industry, and 

public comments/concerns) are aware of and are a 

part of the process. There are numerous 

opportunities for stakeholder involvement 

throughout the Bureau of Ocean Energy 

Management’s NEPA process. The NEPA 

documents and analyses incorporate all relevant 

and important input from all stakeholders that was 

received during scoping and public comment 

periods.

While the BOEM considers and evaluates all 

substantive relevant comments from the public, this 

remains a BOEM document meant to inform the 

decisionmaker and the public of reasonably 

foreseeable impacts from a proposed action and its 

alternatives. BOEM employs a team of highly 

trained technical staff of subject-matter experts who 

develop the analyses based on rigorous scientific 

reviews, consultations with other Federal and State 

agencies, expert opinions, and all relevant and 

important stakeholder considerations.

Impacts are avoided and/or reduced through 

BOEM’s multi-step NEPA mitigation process. 

Impacts are mitigated at both the regional level (i.e., 

lease sale) and also at the plan/permit, site-specific 

level.

In addition, to further reduce any appearance of 

conflicts of interest, MMS (BOEM’s predecessor) 

was reorganized into BOEM, BSEE, and ONRR, 

which are three strong, independent agencies. The 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-53

Commenter Comment ID Comment Response

reorganization was designed to remove potential 

conflicts by clarifying and separating missions 

across three agencies and by providing each of the 

new agencies with additional resources necessary 

to fulfill those missions.

Restore 

Mississippi 

Sound, 

Sharon Hayes, 

Director

RMS-6 In addition, the EIS is required to address ecosystem 

services, which are the value to people of nature's 

benefits. Not taking into account how passionately 

people feel -- people on the coast feel about the Gulf 

and its drilling resources, again, grossly understates 

the cost of drilling. There are well-accepted, stated 

preference methods in the literature that would take 

that into account, but the preparers of the EIS chose 

not to use them. Instead using the habitat 

equivalency model, which does not address people's 

preferences. It's only based on restoration costs. It's 

interesting that stated preference or contingent 

valuation models would not be utilized given that the 

economist Dr. Kenneth Arrow pioneered such 

models during Exxon Valdez oil spill and received the 

Nobel Prize in economics for doing so.

Thank you for your comment. In the fall of 2015, a 

joint memorandum (“Incorporating Ecosystem 

Services into Federal Decision Making”) from the 

Executive Branch (i.e., CEQ, Office of Management 

Budget, and Office of Science and Technology 

Policy) was released; it supports the application of 

the ecosystem services approach, when applicable, 

to the Federal Government’s resource management 

responsibilities. This memorandum was followed up 

by a Departmental effort to respond. The 

Department of the Interior’s Office of Policy Analysis 

has marshalled DOI’s agencies by directing a 

coordinated response that is centered on a 

departmental work plan. This work plan calls for the 

formation of a DOI ecosystem services community 

of practice that aims to build DOI’s ecosystem 

services capacities and further its engagement 

through the following: a query into the utility of 

creating department-wide guidance on the 

application of ecosystem services; an investigation 

into the utility and feasibility of DOI’s ecosystem 

services standards; the identification of an 

ecosystem services research agenda; the 

identification of ecosystem services data gaps; the 

vetting and identification of useful ecosystem 

services analytical tools; and a plan to foster 

ecosystem services capacity building in the Federal 

Government.

BOEM’s subject-matter experts recognize the utility 

of the ecosystem services approach in supporting 

natural resource decisionmaking. BOEM is in the 

process of conducting an internal assessment to 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-54 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

identify where this analytical tool is useful (e.g., 

program, scale, and phase of decision process), to 

identify ecosystem services information needs, and 

to assess ecosystem services deficiencies and 

competencies within BOEM. BOEM’s subjectmatter experts believe that an ecosystem services 

approach is likely to be helpful in some cases and 

less so in others. They are working to develop a 

BOEM strategy for identifying appropriate decision 

processes for an ecosystem services approach, 

assessing the necessary requirements and 

adequacy of data, and are cooperating with the 

Office of Policy Analysis to recognize the long-term 

nature of the effort required for BOEM to achieve 

ecosystem services objectives.

Apalachicola 

Riverkeeper

AR-3 The discussion in Section 4.16 regarding Irreversible 

and Irretrievable Commitment of Resources and 4.17 

regarding Relationship Between the Short-term Use 

of Man's Environment and the Maintenance and 

Enhancement of Long-term Productivity provides 

insight to the industry's acceptance of permanent 

losses of a variety of public resources. Taking such 

losses for granted falls short of recognizing that 

many of the impacts and losses considered shortterm are actually long-term - and are for aII practicaI 

purposes, irreversible. Section 4.17 suggests that 

short term use of Man's environment justifies some 

loss of the long term productivity of the Gulf of 

Mexico. It aIso assumes that that loss of productivity 

will eventually come back. Experience has shown 

that the duration and degree of the impacts has been 

underestimated and therefore undervalued, again 

with the effect of minimizing the costs of the impacts 

and overestimating the benefits.

The purpose of this NEPA document is to disclose 

all of the potential issues associated with a 

proposed action so that the decisionmaker has the 

best information available on which to make the 

decision on whether and how to proceed with a 

proposed lease sale. The purpose of Chapters 

4.16 and 4.17 is to detail for the decisionmaker any 

potential irreversible or irretrievable commitments of 

resource and how the short-term decision to offer a 

proposed lease sale could impact the long-term 

productivity of the GOM. In order to achieve this, 

BOEM uses the best available credible scientific 

information.

United States 

Environmental 

Protection 

Agency

USEPA-1 In the Executive Summary, the DEIS identifies the 

affected environment of analysis to encompass 

133 counties and parishes in five states with over 

22.7 million residents. Also, it states the impacts of 

Thank you for your comment. BOEM will address 

each of USEPA’s recommendations separately.

Recommendation 1: BOEM has utilized the 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-55

Commenter Comment ID Comment Response

the proposed action would be immeasurable for 

environmental justice since low-income and minority 

communities are located on-shore, distant from 

Federal OCS oil and gas-related activities. Further, 

BOEM has determined that the proposed action 

would not produce environmental justice impacts, 

since these vulnerable populations are located within 

the larger context of on-shore and State-regulated 

nearshore oil and gas activities that are connected to 

downstream infrastructure over which BOEM has no 

regulatory authority. Table 1 identifies environmental 

justice impacts to be minor.

Recommendation:

EPA recommends utilizing the Promising Practice 

Report (https://www.epa.gov/sites/production/files/20 

16-5/documents/iwg promising practices final 5- 16-

201 6.pdt) to supplement the applicable requirements 

for considering and analyzing environmental justice 

populations.

We recommend the FEIS accurately discuss impacts 

to environmental justice and Tribal populations, 

within, along the boundaries, and near the proposed 

action's operations and activities.

EPA recommends consolidated discussions of direct, 

indirect, and cumulative impacts to EJ and 

Surrounding Communities and proposed mitigation 

thereby making it readily accessible and in layman's 

terminology.

We recommend utilizing EJ tools and methods (i.e. 

EJ Screen, U.S. Census Bureau, and area 

knowledge) in identifying the low income and minority 

population within or near the proposed project 

Promising Practice Report in its analysis and has 

determined that the environmental justice impact 

conclusion will remain the same.

Recommendation 2: A proposed action’s 

operations and activities are offshore (3 mi [5 km] or 

more offshore). There are no environmental justice 

or Tribal populations living within or along the 

boundaries of a proposed action’s operations and 

activities. However BOEM has considered 

neighboring environmental justice communities in 

Chapter 4.13.3.3. 

Recommendation 3: BOEM discusses direct, 

indirect, and cumulative impacts to environmental 

justice and surrounding communities as a facet of 

the social factors analysis; however, BOEM has no 

onshore authority to propose or establish onshore 

mitigations. The language has been modified to be 

clearer to the reader.

Recommendation 4: Neither the environmental 

justice screen nor the U.S. Census Bureau contain 

data regarding low-income and minority populations 

within or near the proposed project’s boundaries 

since those boundaries are 3 mi [5 km] or more 

offshore in the waters of the Gulf of Mexico. The 

operations and activities regulated by BOEM occur 

several miles offshore where people do not live. 

The OSHA governs working conditions on rigs and 

platforms. BOEM has no regulatory authority over 

any onshore activities, including onshore activities 

that are located near low-income and minority 

populations. BOEM has no authority to control the 

actions of onshore facilities. All onshore facilities 

are permitted and regulated by State environmental 

oversight agencies, i.e., USEPA and OSHA. Please 

refer to Chapter 4.14.3.3 for BOEM’s detailed 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-56 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

boundaries, and avoid the use of averaging in 

determining environmental justice population or 

communities.

EPA recommends consideration of public comments 

in the selection of an alternative that minimize any 

disproportionately high and adverse human health or 

environmental impacts on minority and low-income 

populations or individuals.

environmental justice determination.

Recommendation 5: Public comments are eagerly 

sought and considered by BOEM in selecting an 

alternative.

United States 

Environmental 

Protection 

Agency

USEPA-13 The DEIS identifies BOEM initiated formal 

consultation with U.S. Fish and Wildlife Service 

(USFWS). However, the DEIS does not contain a 

final determination on the environmental 

consequences of the alternatives.

Recommendation:

EPA recommends the incorporation of USFWS and 

other State Agencies concurrence on impacts of the 

proposed project, and a commitment for mitigation, if 

applicable.

BOEM and BSEE have submitted Biological 

Assessments to both NMFS and FWS, and are 

actively engaged with them in consultation 

concerning all of our past and reasonably 

foreseeable future activities. Until the abovementioned formal consultation with NMFS is 

complete, BOEM is under an interim consultation 

agreement with NMFS. The NMFS and FWS 

understand the types and levels of activities BOEM 

is engaged in and have not raised concerns with our 

ongoing activities. They are fully informed of the 

potential impacts identified in this Multisale EIS, as 

well as in the Biological Assessments. Copies of 

the interim concurrence letters can be found in 

Appendix K.

United States 

Environmental 

Protection 

Agency

USEPA-16 In Table 1 Alternative Comparison Matrix, 

archaeological resources impacts are identified as 

negligible under all four Alternatives. However, in 

Section 4.13, the DEIS identifies various scenarios 

where the potential impact could range from 

beneficial to major. Further, it states that it is 

impossible to evaluate the potential impact to an 

archaeological site from a project action at the 

programmatic level, and each permitted action during 

post-lease activities would be assessed for sitespecific impacts during the permit application 

process.

Table 1 in the Executive Summary represents the 

expected impacts to an archaeological resource if 

all mitigations, based on up-to-date archaeological 

survey requirements, are implemented and 

followed. It does not represent the range of impacts 

to archaeological resources should an impact occur. 

This convention was chosen for this table because 

the impact levels to different resource categories 

were evaluated in a way that is most appropriate for 

each resource, but it may not be uniform among the 

different resources.

As an early planning effort, BOEM initiated a 

request for comment on the NOI for this Multisale 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-57

Commenter Comment ID Comment Response

Recommendation:

EPA recommends the FEIS includes, as applicable, 

State and Tribal Historic Preservation Officers 

concurrence and incorporate any issues raised by 

the State and Tribal Historic Preservation Officers, as 

applicable, in Louisiana, Texas Mississippi, Alabama, 

and Florida, and how the impacts will be addressed 

and/or mitigated.

EIS via a formal letter to each of the affected Gulf 

Coast States on April 3, 2015. A 30-day comment 

period was provided. The State Historic 

Preservation Officers for Alabama (refer to 

Comment AHC-1), Florida, and Louisiana 

responded via formal letters, all concurring that no 

historic properties will be affected. The Florida 

State Historic Preservation Officer further requested 

to be notified and given the opportunity to comment 

should any cultural resources be identified off the 

Florida coast. BOEM has received no additional 

correspondence concerning any issues raised by 

State and Tribal Historic Preservation Officers 

concerning how the impacts will be addressed 

and/or mitigated.

Topic 3 - Alternatives

American 

Petroleum 

Institute (API),

Andy Radford

API-10 Table 1 on pp. xvi-xvii of the DEIS contains an 

“Alternative Comparison Matrix” comparing the 

impacts of each alternative on all of the major 

environmental receptors analyzed in the DEIS. 

According to the table, for most environmental 

receptors (including live bottoms, fishes and 

invertebrates, air and water quality, protected 

species, and recreational activities), the impacts of 

the proposed lease sales are anticipated to be 

“beneficial” to “moderate.”1 However, the conclusions 

about the degree of impact in the matrix appear to be 

at odds with the conclusions in the environmental 

impact analyses in Chapter 4, many of which 

contemplate impacts greater than those identified in 

the matrix. While it is possible that this can be 

explained by BOEM’s assumption that certain 

mitigation measures will be imposed and obeyed by 

lessees, BOEM should nevertheless explain and 

rectify the apparent discrepancy between the impacts 

identified in Table 1 and those identified in the impact 

analyses contained in Chapter 4. This will help avoid 

confusion and ensure that the public and the 

BOEM has revised Tables 1 and 2-2 to better 

reflect the resource-specific tables and text 

analyses found in Chapter 4, including separation 

of OCS oil- and gas-related and non-OCS oil- and 

gas-related cumulative impacts.

Not all possible mitigating measures can be 

explained at length in this Multisale EIS since they 

are, by necessity, site specific/case dependent. 

There is a site-specific environmental review of 

OCS oil- and gas-related activities that are 

submitted as plans or permits. Conditions of 

approval are applied at that time. Where 

appropriate, each resource chapter describes the 

types of mitigating measures that can be applied at 

the site-specific review level. Commonly applied 

mitigating measures during the postlease process 

are described in Appendix B. Specifically, for 

Chapter 4.4 (Deepwater Benthic Communities), the 

general types of protective measures are identified 

and summarized in the respective subsections titled 

“Historical Protections of Deepwater Benthic 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-58 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

decision-maker fully understand the anticipated 

environmental effects of the proposed lease sales. 

For example, the matrix concludes that the impacts 

to deepwater benthic communities will be “negligible 

to minor” across all alternatives. Yet the impact 

analysis for deepwater benthic communities in 

Chapter 4.4 indicates that the potential impacts to 

benthic communities could be “major” in a number of 

respects unless “mitigation” is applied. See 

Table 4-6 at p. 4-96. Although BOEM discusses 

certain “protective measures” contained in 

nonbinding guidance documents such as Notices to 

Lessees, and pre-existing legal requirements that 

tend to minimize certain impacts to benthic 

communities, BOEM does not appear to point to any 

particular mitigation measure or combination of 

measures that would reduce the nominally potentially 

“major” impacts of the proposed action(s) on benthic 

communities to the “negligible to minor” level 

identified in the matrix at Table 1. In such situations, 

BOEM should clearly identify the mitigation 

measures it proposes to impose on OCS operators to 

achieve the desired impact level or, in the alternative, 

revise the level of anticipated impacts to reflect the 

possibility that the impact could be greater than that 

currently identified in the Alternative Comparison 

Matrix at Table 1.

Communities” and “Historical Protections of Live 

Bottom Habitats.” The range of impact conclusions 

in relation to the application of mitigating measures 

is also discussed on pages 4-20 and 4-21 of the 

Draft Multisale EIS.

Center for 

Biological 

Diversity, Bold 

Louisiana, 

Gulf 

Restoration 

Network, 

Louisiana 

Bucket 

Brigade, 

Radical Arts 

CBD, BL, GRN, 

LBB, RAHC-11

BOEM’s Draft EIS Fails to Analyze a Reasonable 

Range of Alternatives: In the alternatives analysis, an 

agency must “provide sufficient evidence and 

analysis for determining whether to prepare an 

environmental impact statement or a finding of no 

significant impact.” The analysis must “rigorously 

explore and objectively evaluate all reasonable 

alternatives.” While an agency is not obliged to 

consider every alternative to every aspect of a 

proposed action, the agency must “consider such 

alternatives to the proposed action as may partially 

Thank you for your comment. BOEM has ensured 

that a reasonable range of alternatives to a 

proposed action, within the framework of the 

Five-Year Program, has been considered in this 

Multisale EIS. For a description of the alternatives 

considered but not analyzed, refer to Chapter 2.2.3. 

In that chapter, there are discussions on the 

alternatives excluding loggerhead sea turtle critical 

habitat and the De Soto Canyon and an alternative 

that would exclude Mississippi Canyon or other 

sperm whale high-use areas (with additional 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-59

Commenter Comment ID Comment Response

and Healing 

Collective

(CBD, BL, 

GRN, LBB, 

RAHC), 

Kristen 

Monsell,

Staff Attorney

or completely meet the proposals goal.” In its Draft 

EIS, BOEM considered five alternatives: (A) regionwide lease sales in the Gulf of Mexico (the proposed 

alternative); (B) region-wide lease sales excluding 

available unleased blocks in the Western Planning 

Areas; (C) region-wide lease sales excluding 

available unleased blocks in the Central and Eastern 

Planning Areas; (D) Alternatives A, B, or C with the 

option to exclude unleased blocks subject to the 

topographic features, live bottom and/or blocks south 

of Baldwin County, AL lease stipulations; and (E) no 

new lease sales (the purported no action alternative). 

Even if BOEM properly limited its purpose and need 

statement (which it did not), BOEM unreasonably 

ruled out alternatives that would restrict oil and gas 

development, even if they would have met the “need” 

of holding lease sales to further the development of 

OCS oil and gas resources. As such, BOEM failed to 

“rigorously explore” and “objectively evaluate” all 

reasonable alternatives. For example, BOEM failed 

to examine an alternative that would prohibit new oil 

and gas leases in designated critical habitat for the 

Northwest Atlantic loggerhead sea turtle distinct 

population segment. This habitat is essential for the 

survival and recovery of these imperiled sea turtles 

given its importance for several live-stages including 

development, foraging, and cover. BOEM must 

consider such an alternative, particularly in light of its 

acknowledgement that the cumulative impacts of 

ongoing offshore oil and gas activities on the OCS is 

expected to result in a number of chronic and 

sublethal effects on sea turtles that could have 

population-level impacts. BOEM also failed to 

consider an alternative that would prohibit new oil 

and gas leases in the Mississippi Canyon to protect 

sperm whales because biological data does not 

support such an exclusion. However, as BOEM is 

well aware, the Mississippi Canyon is the site of the 

justification added; a full analysis of marine 

mammals, including sperm whales, can be found in 

Chapter 4.9.1), and additional information has been 

added regarding an alternative encompassing a 

potential boundary expansion of the Flower Garden 

Banks National Marine Sanctuary, as well as other 

alternatives. Further, any alternative to delay 

activities is analyzed in this Multisale EIS as 

Alternative E. The No Action alternative is a 

cancellation of a single lease sale, and a new 

decision will be made for the next proposed lease 

sale in the Five-Year Program.

BOEM has discussed climate change in Chapter 

4.2.1 and Appendix C of the Five-Year Program 

EIS, including additional discussions of U.S. and 

global commitments to mitigating climate change.

Please refer to the response to Comment CBD, BL, 

GRN, LBB, RAHC-2 for more information on 

alternatives and fundamental changes to improve 

the management of offshore leasing and drilling 

since publication of the 2011 Commission Report 

and to the response to Comment CBD, BL, GRN, 

LBB, RAHC-5 for more information related to the 

Paris Agreement and BOEM’s treatment of 

downstream greenhouse gas emissions as a result 

of leasing in the Gulf of Mexico.
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-60 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Deepwater Horizon catastrophe. Accordingly, the 

Mississippi Canyon suffered significant exposure to 

oil and toxic dispersants. Given the persistence of oil 

in the marine environment, the Canyon may be 

contaminated for decades. A study of sperm whales 

in the Canyon following the spill found nickel and 

chromium—two genotoxic metals found in Macondo 

oil—that were two to five times higher than the global 

mean for the species. And, as explained above, 

other wildlife is still suffering the impacts of the oil 

spill and cleanup efforts, such as corals, jellyfish, and 

sea turtles. A ban on new leasing in Mississippi 

Canyon would help protect these species from 

further disruption caused by new offshore oil and gas 

activities. BOEM’s cursory dismissal of this 

alternative from further consideration was improper. 

BOEM also failed to consider excluding the De Soto 

Canyon from availability for leasing. The De Soto 

Canyon is important habitat for a variety of species, 

including Bryde’s whales, sperm whale and other 

cetaceans. Virtually all reported sightings of Bryde’s 

whales have occurred within the De Soto Canyon, 

suggesting a highly restricted range. A recent study 

by the National Marine Fisheries Service suggests 

that the population is isolated and evolutionarily 

distinct from all other Bryde’s whales examined to 

date, indicating that the species may be a distinct 

subspecies. Recent abundance estimates put the 

population’s size at fewer than 40 animals, meaning 

it is highly vulnerable to impacts from oil and gas 

activities. Accordingly, BOEM should consider 

excluding this area from its proposal. In addition, 

BOEM failed to examine an alternative that would 

prohibit drilling activities in and around areas where 

ESA-listed corals are found in the Gulf of Mexico. 

This is despite BOEM’s express acknowledgment 

that corals are particularly vulnerable to disturbance 

and that “due to their relatively low population sizes, 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-61

Commenter Comment ID Comment Response

any impacts form accidental events on ESA-listed 

corals would have a magnified effect on each of 

those species.” BOEM also arbitrarily dismissed 

expanding the exclusion zone for the Flower Garden 

Banks National Marine Sanctuary. BOEM stated it 

did not further consider expanding the exclusion area 

because the proposed expansion is still in the early 

planning stages. But BOEM has independent 

authority to restrict the areas where offshore oil and 

gas activities occur under OCSLA. And the fact that 

the National Marine Fisheries Service is even 

considering expanding the Sanctuary indicates that 

the area contains important and biologically diverse 

marine life, including species that are particularly 

vulnerable to oil and gas activities and spills such as 

corals. BOEM should therefore consider such an 

alternative. As described above, oil spills occur as a 

matter of course in the Gulf of Mexico; lease 

stipulations related to avoiding bottom disturbance 

cannot change this reality. BOEM also failed to 

examine alternatives that would otherwise limit 

development and production activities, such as an 

alternative that would limit the number of wells that 

could be drilled under its proposal or an alternative 

that would prohibit the use of particularly dangerous 

drilling activities such as offshore fracking and 

acidizing. BOEM also failed to consider an 

alternative that would end all new offshore oil and 

gas leasing pending a plan to limit warming to 1.5o or 

2oC. BOEM’s failure to consider such an alternative 

is particularly troubling considering recent reports 

finding that ending new offshore leases will lead to 

reductions in global greenhouse gas emissions and 

that BOEM has already leased over 22 million acres 

of the Gulf of Mexico to oil companies. Many of the 

leases in the Gulf of Mexico are relatively new 

leases, meaning that, by BOEM’s own admission, 

activities under these leases will last up to 70 years. 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-62 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

BOEM’s analysis wholly fails to consider why the 

OCS areas already under lease—many of which are 

inactive—are not sufficient to supply the nation’s 

energy needs while we transition away from dirty 

fossil fuels and toward clean energy. BOEM must 

consider this, along with the need and national policy 

to transition to clean energy sources and 

development of renewable energy from the OCS. 

Finally, BOEM failed to consider an alternative that 

would institute a regional citizens’ advisory council in 

the Gulf of Mexico. The Commission recommended 

the formation of such an advisory group in the Gulf of 

Mexico, and that it represent the broad community 

interests in the areas, including the fishing and 

tourism industry, and be funded by oil and gas lease 

holders. The council of stakeholders would provide 

ongoing, independent research and 

recommendations for environmental safeguards of 

offshore drilling and transportation.

Sierra Club, 

Devorah 

Ancel,

Staff Attorney

SC-3 The Range of Alternatives Fails to Incorporate 

Additional Protections for Highly Sensitive 

Ecosystems and Habitat: BOEM’s range of 

alternatives lacks consideration of sensitive 

ecosystems and habitats encompassed in the 

proposed lease area including: designated critical 

habitat for the Northwest Atlantic loggerhead sea 

turtle distinct population segment; sperm whale 

habitat in the Mississippi Canyon, Bryde’s whales, 

sperm whale and other cetacean habitat in De Soto 

Canyon; and habitat for ESA-listed corals found in 

the Gulf’s Western and Central Planning Areas. At a 

minimum, BOEM must consider alternatives that 

prohibit leasing and development in these highly 

sensitive areas, as well as consider an alternative 

that expands the exclusion zone for the Flower 

Garden Banks National Marine Sanctuary.

Lone Star 

Chapter of the 

LSCSC-3 Third, BOEM seems to be offering a false choice. 

The options analyzed under the DEIS seem to be full 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-63

Commenter Comment ID Comment Response

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

leasing, leasing in one of the zones or none 

essentially. There seems to be little consideration of 

very limited zones for drilling, or increased no-drill 

zones. Instead, BOEM is relying on its large 

“Western,” “Central” or “Eastern” zones and little 

ability to limit areas within those areas. While Option 

D offers some variability by adding some restrictions 

on drilling in certain areas, again it is a very limited 

option with no consideration of other options. NEPA 

requires a “detailed statement” of “alternatives to the 

proposed action,” which is considered “the heart of 

the environmental impact statement.” But BOEM’s 

alternatives analysis is seriously lacking. Even if 

BOEM properly limited its purpose and need 

statement (which it did not), BOEM unreasonably 

failed to consider alternatives that would restrict oil 

and gas development, even if they would have met 

the “need” of holding lease sales to further the 

development of OCS oil and gas resources. For 

example, BOEM failed to consider an alternative that 

would prohibit drilling in certain biologically sensitive 

areas, such as critical habitat for imperiled 

loggerhead sea turtles; an alternative that would 

restrict the number of wells to be drilled; or an 

alternative that would end all new offshore oil and 

gas leasing pending a plan to limit warming to 1.5o or 

2oC.

Cyrus Reed CR-10 And I have got some -- you know, I've got a final 

comment. Just that NEPA really does require to look 

at a -- all the alternatives to the proposed action, but, 

again, the Actions A, B, C, D, and E, you know, are 

really just -- I mean, E is different because it's no 

leasing, but the other ones are really just small 

variations. And, so, I really would want them to look 

at the need overall of holding these leases. I would 

want them to look at an alternative that would really 

prohibit drilling in certain sensitive areas and an 

alternative that would restrict the number of wells to 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-64 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

be drilled and how they could meet sort of the, you 

know, the overall Paris accord of keeping global 

warming to below 1.5 or 2 degrees Celsius. How 

does drilling fit into that overall plan and how much 

would be allowed?

Center for 

Biological 

Diversity, Bold 

Louisiana, 

Gulf 

Restoration 

Network, 

Louisiana 

Bucket 

Brigade, 

Radical Arts

and Healing 

Collective

(CBD, BL, 

GRN, LBB, 

RAHC), 

Kristen 

Monsell,

Staff Attorney

CBD, BL, GRN, 

LBB, RAHC-12

BOEM Failed to Adequately Consider the No-Action 

Alternative: Moreover, BOEM’s analysis of 

Alternative E—the “no-action” alternative—is 

inadequate. BOEM repeatedly states that the no 

action alternative means that the lease would not 

occur under the Five-Year Program for 2017-2022, 

but could occur in a future five-year program. Thus, 

according to BOEM, the no-action alternative 

encompasses the same potential impacts as a 

decision to delay the lease sale to a later time. But 

this approach “avoid[s] the task actually facing 

[BOEM]. In assuming that, no matter what, the 

proposed activities would surely occur, [BOEM is] 

neglecting to consider what would be a true ‘no 

action’ alternative.” In addition, in considering the 

cumulative impacts of Alternative E, BOEM simply 

states that the impacts of adopting this alternative will 

“depend on the extent to which the public were to 

interpret it as a signal of a policy change that would 

continue into future lease sales.” This cursory 

statement wholly fails to satisfy the agency’s duty to 

rigorously explore and objectively evaluate the noaction alternative. Further, it ignores the fact that the 

United States has committed, along with more than 

190 other countries, to avoid the worst effects of 

climate change by limiting warming to 2 °C or less, 

and that science tells us that we must limit the supply 

of fossil fuels if we are to meet this commitment. 

This clearly necessitates a change in policy, since 

under a business-as-usual approach, the world 

would warm to over 5 °C by the end of the century.

The OCSLA requires a staged decisionmaking 

process, beginning with the Five-Year Program, 

continuing through individual lease sales under the 

Five-Year Program, and ultimately to individual 

postlease activities requiring a permit or approval. 

At the lease sale stage of the OCSLA process, 

BOEM typically evaluates all individual lease sale 

decisions in one or more GOM planning areas 

under the Five-Year Program in a multisale EIS. As 

stated in Chapters 1 and 2, the multisale approach 

discusses all 10 Federal actions, i.e., 10 regionwide 

oil and gas lease sales, as scheduled under the 

Five-Year Program. The multisale EIS approach is 

intended to focus the NEPA/EIS process on the 

staged OCSLA process for decisionmaking, 

including the proposed lease sales, and any new 

issues and information identified since a prior stage. 

It also lessens duplication and saves resources. 

Though 10 proposed regionwide lease sales are 

encompassed in the Five-Year Program, the impact 

analyses within this Multisale EIS specifically 

address resource impacts associated with holding 

one proposed lease sale, i.e., proposed Lease 

Sale 249. Therefore, the No Action alternative 

associated with the analyzed Federal proposed 

action is the cancellation or delay of a single 

proposed lease sale, i.e., proposed Lease Sale 249. 

A separate decision point and new NEPA analysis 

(e.g., a Determination of NEPA Adequacy, 

Supplemental EIS, or EA, as applicable) will be 

undertaken for the other nine proposed regionwide 

lease sales (e.g., proposed Lease Sale 250) and will 

include any potential differences or updates for a 

Sierra Club, 

Devorah 

SC-4 The DEIS Fails to Properly Consider a “No Action” 

Alternative: BOEM fails to put forward a true no 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-65

Commenter Comment ID Comment Response

Ancel,

Staff Attorney 

action alternative. Alternative E, which BOEM calls 

the “No Action” alternative, only would “cancel a 

single proposed lease sale” rather than all ten 

proposed leased sales that would occur under the 

proposed action in the 2017 to 2022 period. Further, 

in rejecting the “No Action” alternative, BOEM 

assumes that the cancellation of any single proposed 

lease sale in the five year period is simply a 

postponement of that lease sale to a future lease 

sale and therefore any production activity and 

associated potential environmental impacts resulting 

from the cancelled lease sale would simply be 

deferred to a later date. This reasoning disregards 

entirely the fact that any single lease sale or all ten 

proposed lease sales combined are not needed now 

or anytime in the future based on current and 

projected oil and gas market conditions described 

above. Indeed, market projections demonstrate that 

a true “no action” alternative that permanently 

cancels the proposed leases would in fact allow for 

continued production of oil and gas without obligating 

the U.S. to continue oil and gas development the 

Gulf of Mexico well past 2022. Moreover, by framing 

the No Action Alternative as the cancellation (or 

postponement) of only a single lease sale rather than 

cancellation of the full swath of lease sales proposed 

for the five year period, BOEM ignores the full extent 

of damages that could be avoided by a true No 

Action Alternative. Indeed, no new leasing would 

reduce the potential for oil spills and other destructive 

impacts of oil and gas exploration and development; 

avoid the release of billions of tons of greenhouse 

gases and other pollutant discharges to the water 

and air; and avoid additional negative impacts to 

wildlife and local communities already impacted by 

the BP oil spill disaster and subsequent oil spills. 

Without any analysis of the benefits to the marine, 

coastal and human environments of a permanent 

proposed action and any new information available 

at that time.

If a single proposed lease sale would be cancelled, 

under the OCSLA, BOEM would be required to 

consider any proposed lease sales remaining in the 

current Five-Year Program, if applicable, or 

proposed as part of a future Five-Year Program. 

Therefore, a decision to cancel a single proposed 

lease sale will not alter future decisions for 

proposed lease sales in the GOM, as required by 

the OCSLA. The decision point is at the individual 

proposed action or lease sale stage.

By selecting the No Action alternative and avoiding 

those activities associated with a proposed lease 

sale, those potential impacts related to a single 

proposed lease sale would be avoided; however, 

please be advised that a decision to cancel a single 

proposed lease sale would not preclude activity 

related to past lease sales or decisions on future 

lease sales. There are a number of currently leased 

blocks within the proposed lease sale area with 

proposed plans, and BOEM anticipates another 

decision point for the proposed lease sale, which is 

proposed as part of the Five-Year Program. Should 

the No Action alternative be selected, in the interim, 

industry may explore and develop their existing 

portfolio of leaseholds subject to the terms of those 

leases and any conditions of approval for plans or 

permits. An individual decision or a series of 

decisions on proposed lease sales in a given 

planning area may influence industry’s 

decisionmaking or strategy to develop existing 

leases. In this context, the No Action alternative 

does not explicitly presume an identical proposal or 

one that is only delayed into the future. As noted 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-66 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

cancellation of the new leases, BOEM simply 

concludes that any adverse economic impacts to 

companies and federal government revenues of 

cancelling (or postponing) a single lease take 

precedent. This conclusion plays into the 

longstanding culture of appeasing industry interests 

to maximize profits at all costs which has led to the 

disastrous consequences of rampant permitting and 

development of the offshore. Further, the conclusion 

that cancellation of leases will adversely impact 

federal revenues fails to acknowledge the fact that 

even the industry’s desire to invest in the Gulf is 

dwindling. The recent March 2016 lease auction 

garnered a total of only $156 million in bids, the 

fourth lowest total in the Gulf’s Central District since 

1983. Notably, no bids were received for auctions 

blocks in the Eastern Planning Area. BOEM’s 

concerns about declining revenues fail to compare 

the benefits of a few hundred million dollars in 

revenues to the enormous costs associated with a 

single disastrous blow out or the thousands of 

frequently occurring oil spills. Indeed, the costs of 

clean-up and restoration, as well as costs to 

communities and the tourism industry of an oil spill 

disaster, on the order of billions of dollars, dwarf any 

benefits conferred by declining federal government 

revenues. At the very least, BOEM must consider 

and analyze a permanent no lease sale option. 

Given the current state of inactive existing offshore 

oil and gas leases, gas production nationally, and the 

ongoing and potential impacts of drilling activities, a 

true no action alternative that permanently cancels 

lease sales proposed for the 2017-2022 period 

balances oil and gas development with protection of 

the human, marine and coastal environments. In 

fact, it is the only possible option that comports with 

BOEM’s mandate under OCSLA.

above, under the OCSLA, BOEM would be required 

to consider any proposed lease sales remaining in 

the current Five-Year Program, if applicable, or 

proposed as part of a future Five-Year Program. As 

such, each proposed lease sale will have its own 

decision point.

Analyzing a permanent no lease option is outside 

the scope of this Multisale EIS. Cancellation of all 

10 proposed lease sales in the Five-Year Program 

was analyzed in the Five-Year Program EIS 

(USDOI, BOEM, 2016a), from which this Multisale 

EIS is tiered.

Gulf GRN- 1 Gulf Restoration Network is disappointed in the lack 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-67

Commenter Comment ID Comment Response

Restoration 

Network, 

Johanna de 

Graffenreid

of “No Action Alternative” research in the EIS. A 

thorough exploration of a no-action alternative is 

essential to ensuring that all Gulf communities, 

waters, and wetlands are protected.

Stated Preference for an Alternative

American 

Petroleum 

Institute (API),

Andy Radford

API-5 The Multisale DEIS considers five alternatives for the 

proposed lease sales. API strongly supports 

Alternative A (the Preferred Alternative) for the 

10 GOM lease sales proposed to be held from 2017 

through 2022 as described below: Alternative A 

(Preferred) would offer for lease all unleased blocks 

within the proposed WPA, CPA, and EPA portions of 

the proposed lease sale area for oil and gas 

operations, with the following exceptions: (1) whole 

and partial blocks deferred by the Gulf of Mexico 

Energy Security Act of 2006; and (2) blocks that are 

adjacent to or beyond the United States’ Exclusive 

Economic Zone in the area known as the northern 

portion of the Eastern Gap. (3) whole and partial 

blocks within the Flower Garden Banks National 

Marine Sanctuary (i.e., the boundary as of 

publication of this Multisale EIS) API is strongly 

opposed to Alternatives B, C, D, and E for the GOM 

lease sales. The analysis in the DEIS does not 

support the adoption of such restrictive alternatives. 

Adoption of Alternative A is fully consistent with the 

agency’s analysis.

Thank you for your comment. We note that your 

preferred alternative is Alternative A. The Secretary 

of the Interior oversees the OCS oil and gas 

program and is required to balance orderly resource 

development with protection of the human, marine, 

and coastal environments while simultaneously 

ensuring that the public receives an equitable return 

for these resources and that free-market 

competition is maintained. The decision on whether 

and how to proceed with each proposed lease sale 

is under the authority of the Assistant Secretary for 

Land and Minerals Management and will be 

disclosed in the Record of Decision following 

publication of this Final Multisale EIS.

Paul Siegele, 

Chevron

CHEVRON-1 I encourage the InteriorDepartment tofinalize a

2017-2022offshore leasingprogramwithout 

excluding any further areas or imposingfurther

restrictions. Proceedingotherwise would pose

risks to the nation'seconomic andenergy security.

It would alsoreduce revenues tothe USgovernment

and negatively affectthe livelihoods and

communitiesacrosstheGulfCoast.

Eddie Pharr,

Spectrum Geo

SPECTRUM-1 In the Gulf of Mexico, we fully support maintaining 

all ten Gulf of Mexico lease sales without any further 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-68 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

restrictions.

Kellan Lyman KL-1 I believe the best interest of the people of the Gulf is 

to have no new leases for the oil and gas industry 

because the industry has demonstrated that they're 

unable to operate cleanly and has an unacceptable 

level of pollution, which damages Louisiana's natural 

heritage and livelihood. These impacts are 

detrimental to the ecosystem and economy.

Thank you for your comment. We note that your 

preferred alternative is Alternative E. The Secretary 

of the Interior oversees the OCS oil and gas 

program and is required to balance orderly resource 

development with protection of the human, marine, 

and coastal environments while simultaneously 

ensuring that the public receives an equitable return 

for these resources and that free-market 

competition is maintained. The decision on whether 

and how to proceed with each proposed lease sale 

is under the authority of the Assistant Secretary for 

Land and Minerals Management and will be 

disclosed in the Record of Decision following 

publication of this Final Multisale EIS.

Brenda 

Warger

BW-1 I came here today because I would like to say that I 

am in opposition to the sale of new leases for oil and 

drilling in the Gulf because they will deepen the 

climate crisis and reverse the course on President 

Obama's commitment to combat climate change. I 

urge you to halt all new oil and gas lease sales in 

federal water and keep these dirty fossil fuels in the 

ground.

Rachel Walsh RW-1 I believe that we need to have no new leases in the 

Gulf of Mexico. I believe that we need to leave the 

oil and gas in the ground if we're going to effectively 

combat climate change. We need to be pursuing 

renewable energy as opposed to selling new oil and 

gas leases. Climate change is primarily driven by the 

combustion of fossil fuels which poses a severe 

threat to health, welfare, ecosystems, and the 

economy of the United States and the world. The 

Paris Climate Agreement was signed by 197 

countries, including the United States, and it requires 

rapid and robust emission reductions to be effective, 

therefore, it's important to restrict new leases from 

being sold because halting new oil and gas leases off 

our coasts would keep up to 62 billion tons of carbon 

emissions in the ground.

Alabama 

Chapter of the 

Sierra Club, 

Carol AdamsDavis

ACSC-2 Please take action to cancel lease sales for the 

Central Planning Area of the Gulf of Mexico. These 

sales continue the dangerous disconnect between 

the administration's climate goals and the continued 

leasing of federal lands and waters for fossil fuel 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-69

Commenter Comment ID Comment Response

extraction.

Lone Star 

Chapter of the 

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

LSCSC-4 The Lone Star Chapter Believes That the No New 

Leasing -- Option E -- is the Option the 

Administration Should Pursue

No New 

Leases Form 

Letter

NNL-5 That's why BOEM must adopt the no action 

alternative and end new oil and gas leasing in federal 

waters. It's the right policy move and now is the right 

time.

Apalachicola 

Riverkeeper

AR-6 To this end, the “No Action Alternative” should be the 

preferred alternative until the recommended 

precautions are available, improved clean up and 

response are possible, and impacts are better 

understood and/or known. To expand an industry 

that is causing significant impacts in the face of a 

reality where the need for oil and gas is declining and 

being replaced by energy production that does not

result in such short and long term impacts to the 

health and productivity of the Gulf of Mexico is 

inconsistent with protection of the public interest. We 

strongly support the NO Action Alternative.

Sky Yardley SY-1 Every drop of oil extracted has potential to leak. 

Deepwater Horizon, oil trains crashing, methane 

releases in California, other places. ... ·Leave the oil 

and the gas in the ground so we can all live.

Andrea 

Alexander

AA-1 Natural resources like the Gulf of Mexico should NOT 

be bought and controlled by wealthy corporate 

interests, just like government officials should be 

public servants only and should NOT be bought and 

paid for by wealthy corporate interests.

The lands, waters, and wildlife of America really 

belong to us, the people -- if anyone-- but you corrupt 

government officials have robbed us of our heritage, 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-70 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

just like you robbed the Native Americans not so long 

ago. You've handed our priceless forests, parks and 

refuges, wildlife, and marine resources over to 

ruthless, insatiable corporate entities who are 

ravaging, polluting, exhausting, and utterly ruining 

our beautiful planet -- all to satisfy their greed.

I've lived along the Gulf of Mexico my entire life, and I 

am absolutely disgusted by the recklessness of 

drilling and extraction companies. THey have 

decimated and destroyed so much marine life in the 

Gulf, from oysters and shellfish, to dolphins and 

whales, to pelicans and shorebirds, to turtles and so 

many other elements of the food web.

They have decimated the seafood industry and 

injured the tourist industry along the Gulf Coast. 

They have decimated the habitat for so many 

creatures that call this area home and which are 

essential for our survival and our culture. They have 

no regard for all the people, wildlife, and natural 

resources they have displaced and ruined. And now, 

our government, once again, is willing to throw us to 

these wolves. Again.

Governments who hand over the lifeblood of the 

people (which the Gulf of Mexico is to us who live 

here) to these greedy uncaring companies (most of 

whom send their profits to foreign citizens and 

countries) are TRAITORS to their country and 

undeserving to be in power.

Shame on you government criminals. Traitors, every 

one of you who condone these companies that 

exploit what we have and give nothing back in return.

Community 

Advocate

CA-3 I urge BOEM to adopt the no

-action alternative for 

the entire Gulf of Mexico. Further, BOEM should end 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-71

Commenter Comment ID Comment Response

plans for new oil and gas leasing in “ALL’ federal 

waters of the US Outer Continental Shelf.

David Hilfiker DH-1 Please remove all Arctic, Atlantic, and Gulf oil and 

gas leasing from the 2017-2022 Proposed Program.

Diana 

Tomlinson

DT-1 I am writing to demand a termination to all new oil 

and gas leases in federal waters in the Gulf of 

Mexico. The Bureau of Ocean Energy Management 

is considering lease options for five year beginning in 

2017. This would allow drilling over the next 

70 years putting wildlife and coastal communities at 

risk. Each time there is an oil spill thousands of 

endangered organisms are at risk as well as 

recreational and commercial fisheries.

For the past six years, the Gulf of Mexico has been 

on a recovery path from all of the damage sustained 

by the Deepwater Horizon disaster and has a long 

way to go to be as healthy as it once was. Any new 

drilling would lead to more offshore developments 

and accelerate the potential of spills and accidents. 

This is why it is prudent to close off any new drilling 

in the Gulf of Mexico.

Erica 

Heimberg

EH-1 I am writing to demand a termination to all new oil 

and gas leases in federal waters in the Gulf of 

Mexico. The Bureau of Ocean Energy Management 

is considering lease options for five year beginning in 

2017. This would allow drilling over the next 

70 years putting wildlife and coastal communities at 

risk. Each time there is an oil spill thousands of 

endangered organisms are at risk as well as 

recreational and commercial fisheries.

For the past six years, the Gulf of Mexico has been 

on a recovery path from all of the damage sustained 

by the Deepwater Horizon disaster and has a long 

way to go to be as healthy as it once was. Any new 

drilling would lead to more offshore developments 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-72 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

and accelerate the potential of spills and accidents. 

This is why it is prudent to close off any new drilling 

in the Gulf of Mexico.

J ConnCONN-1 I urge the Bureau of Ocean Energy m Management 

to maintain regionwide leasing in the Gulf of Mexico.

James 

Mulcare

JM-1 I am writing to demand a termination to all new oil 

and gas leases in federal waters in the Gulf of 

Mexico. The Bureau of Ocean Energy Management 

is considering lease options for five year beginning in 

2017. This would allow drilling over the next 

70 years putting wildlife and coastal communities at 

risk. Each time there is an oil spill thousands of 

endangered organisms are at risk as well as 

recreational and commercial fisheries.

For the past six years, the Gulf of Mexico has been 

on a recovery path from all of the damage sustained 

by the Deepwater Horizon disaster and has a long 

way to go to be as healthy as it once was. Any new 

drilling would lead to more offshore developments 

and accelerate the potential of spills and accidents. 

This is why it is prudent to close off any new drilling 

in the Gulf of Mexico.

Jane McBride JMB-1 Please end all new offshore oil and gas leasing in 

public waters.

Jason Hannon JH-1 The next 70 years??? We are beyond the "need" for 

fossil fuels. Anything oil can do, hemp can do better 

and sustainably! Which can also enrich the 

ecosystem, rather than pollute it further. Enough is 

enough, no more "Drill Baby, Drill!" As we sit on the 

precipice, we need to reach for the future, rather than 

dragging our feet in the past. Or you can continue to 

show us who bought and paid for you with these 

utterly moronic decisions, and we'll gladly see you 

replaced by whatever means necessary.

Jeff Cobb JC-1 No new oil leases. Humanity has already found 5 times more fossil fuel reserves than we can burn 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-73

Commenter Comment ID Comment Response

and stay under the 1.5 degrees Celsius temperature 

increase signed in the Paris agreement.

Joanna Nasar JN-1 I am writing to demand a termination to all new oil 

and gas leases in federal waters in the Gulf of 

Mexico. The Bureau of Ocean Energy Management 

is considering lease options for five year beginning in 

2017. This would allow drilling over the next 

70 years putting wildlife and coastal communities at 

risk. Each time there is an oil spill thousands of 

endangered organisms are at risk as well as 

recreational and commercial fisheries. For the past 

six years, the Gulf of Mexico has been on a recovery 

path from all of the damage sustained by the 

Deepwater Horizon disaster and has a long way to 

go to be as healthy as it once was. Any new drilling 

would lead to more offshore developments and 

accelerate the potential of spills and accidents. This 

is why it is prudent to close off any new drilling in the 

Gulf of Mexico.

John Kersting JK-1 I'm writing to ask that all new offshore leases for 

drilling be removed from the 2017-2022 Outer 

Continental Shelf Oil and Gas Leasing Program and 

that you use your authority to permanently protect 

the Arctic and Atlantic from all new oil and gas 

leasing, forever. Like the Atlantic Ocean, the Arctic 

should not be opened for drilling, and instead of new 

lease sales in the Gulf of Mexico, we need a plan to 

transition communities to a clean, renewable energy 

economy.

Kim Schultz KS-1 Please, I beg you not to allow further drilling in the 

Gulf of Mexico. I've done my part by writing this 

letter to you. Now it's up to you to be brave and do 

what you know is right in your heart; not your head, 

but your heart.

Leah Gentry LG-1 I ask you to grant no new oil or gas leases in the Gulf 

of Mexico. It has been proven over and over again 

that this is risky business for our environment, for sea 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-74 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

life, for anyone who lives near a coastline, for the 

future well being of all living beings. Leave it in the 

ground. Resources would be far better used to 

enhance the development and use of alternative 

fuels. Please please take no action on new oil and 

gas leases; not today, not ever. The Earth's future is 

hanging in a delicate balance; and part of that 

balance is held in your hands. Please, do the right 

thing and just say no.

Margie 

Vicknair-Pray

MVP-1 Considering the major affronts to the Gulf in recent 

years, including the recent spill by Shell less than 

100 miles south of Port Fourchon, LA, I would hope 

that someone of intelligence and power in your 

agency will have made an assessment that drilling in 

the Gulf of Mexico is killing not only the Gulf, but the Louisiana coastal marshes, 

and eventually the entirety of oceans of the world. 

You can't possibly believe that this is a good thing. 

I'm giving you credit for having some basic 

intelligence and a lack of greed.

Melissa 

Fleming

MF-1 It is imperative that we protect frontline communities 

and marine wildlife from offshore drilling and halt all 

new oil and gas leases in the Gulf.

Michelle Macy MM-1 There should be NO more offshore drilling. I think 

the Valdez disaster and the BP fiasco should serve 

as somber reminders of why not.

Rebecca 

Parsons

RP-3 I strongly urge you to stop all new oil and gas leases, 

and carry out the will of the President and the 

American people.

Ronald Kardos RK-3 The U.S. Department of the Interior, Bureau of 

Ocean Energy Management should not consider the 

sale of more off shore drilling rights in the upcoming 

2017-2022 Gulf of Mexico OCS Oil and Gas Lease 

Sales.

Sally Stevens SS-1 BOEM must therefore adopt the no

-action alternative 

and end new oil and gas leasing in federal waters. 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-75

Commenter Comment ID Comment Response

Such action is necessary to protect our climate, 

oceans, coastal environments and local communities 

from dangerous offshore drilling.

Suzanne 

Cohen

COHEN-1 We cannot protect our coast with all of the drilling 

that is going on now. Please help us protect our 

coast.

Topic 4 – Environmental Issues and Concerns

Climate Change

Center for 

Biological 

Diversity, Bold 

Louisiana, 

Gulf 

Restoration 

Network, 

Louisiana 

Bucket 

Brigade, 

Radical Arts 

and Healing 

Collective

(CBD, BL, 

GRN, LBB, 

RAHC), 

Kristen 

Monsell,

Staff Attorney

CBD, BL, GRN, 

LBB, RAHC-6 

BOEM Failed to Adequately Consider Climate 

Change Impacts on the Ocean and Coastal: 

Environment: In addition to failing to address the 

impacts of consuming the oil and gas extracted 

under its proposal, BOEM failed to adequately 

describe baseline conditions related to climate 

change or consider the impacts of climate change on 

the ocean environment. While BOEM’s analysis 

acknowledges that climate change is occurring and 

incorporates the analysis in the Draft EIS on BOEM’s 

Five Year Program, its analysis is cursory and fails to 

properly disclose the enormity of the problem, or the 

contribution of its proposal to the problem. For 

example, BOEM fails to adequately analyze the 

impacts of ocean acidification over the course of its 

proposal and its proposal’s contribution to these 

significant environmental problems. BOEM also 

failed to adequately consider increased storm 

severity and sea level rise. Greenhouse gas 

pollution is causing the oceans to acidify at an 

alarming rate. The ocean’s absorption of 

anthropogenic carbon dioxide is changing its 

chemistry, lowering its pH and causing ocean 

acidification. Surface ocean pH has already dropped 

by about 0.1 pH units from 8.16 in 1800 to 8.05 

today, resulting in a rise in surface ocean acidity of 

about 30 percent. The pH of the ocean is changing 

rapidly at a rate 100 times anything seen in hundreds 

of millennia, and may drop by another 0.3 or 0.4 

Additional language was included in the analysis of 

impacts to water quality (Chapter 4.2), marine 

mammals (Chapter 4.9.1), deepwater benthic 

communities (Chapter 4.4), and live bottom habitats 

(Chapter 4.6) to address ocean acidification. 

Currently, there is insufficient information on ocean 

acidification, potential effects, and response of 

biota, and any mention would be too speculative for 

this Multisale EIS.

There are many different species of harmful 

phytoplankton and many different types of harmful 

algal blooms, and to speculate as to which types 

would be enhanced or suppressed in the GOM due 

to ocean acidification is unduly speculative and not 

possible at this time. With respect to domoic acid 

and Pseudo-nitzschia blooms in the northern Gulf of 

Mexico, it has been demonstrated that domoic acid 

is capable of entering coastal food webs; and a 

vector species (i.e., the Gulf menhaden) has been 

identified (Del Rio et al., 2010). However, the levels 

of toxicity observed in that study are orders of 

magnitude lower than those of the west coast of the 

United States. A more recent study has identified 

toxicity concentrations in the same magnitude as 

those on the west coast, but note that no pelagic 

animal strandings have occurred (Bargu et al., 

2016). At the present level of understanding, it 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-76 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

(resulting in a 100–150% increase in acidity) by the 

end of this century. If carbon dioxide emissions 

continue unabated, resulting changes in ocean 

acidity could exceed anything experienced in the 

past 300 million years. Even if carbon dioxide 

emissions stopped immediately, the ocean would 

continue to absorb the excess carbon dioxide in the 

atmosphere, resulting in further acidification until the 

planet’s carbon budget returned to equilibrium. A 

primary impact of ocean acidification is that it 

depletes seawater of the carbonate compounds—

aragonite and calcite—that many marine organisms 

need to build shells and skeletons. As a result, 

ocean acidification hinders species such as corals, 

crabs, sea stars, sea urchins, and plankton from 

building the protective armor they need to survive. 

Rising acidity also affects the basic functions of fish, 

squid, invertebrates, and other marine species, 

including detrimental effects on metabolism, 

respiration, and photosynthesis, which can thwart 

their growth and lead to higher mortality. Because of 

its serious impacts to so many species, including 

those at the base of the food chain, ocean 

acidification threatens to disrupt the entire marine 

food web. Ocean acidification also decreases the 

sound absorption of seawater, causing sounds to 

travel further with potential impacts on whales and 

other marine mammals that may be sensitive to the 

noises created by vessel traffic, seismic surveys, 

military sonar, and other noise pollution. In addition, 

ocean acidification has the potential to profoundly 

affect the growth and toxicity of phytoplankton 

associated with harmful algal blooms (“HABs”). 

HABs can cause mortality in marine mammals 

through contamination of food sources. Some 

strains of phytoplankton in HABs produce copious 

amount of domoic acid, a kanic acid analog 

neurotoxin. Exposure to this toxin via food sources 

would be far too speculative for this Multisale EIS to 

assess the impacts of ocean acidification on harmful 

algal blooms in the GOM.

While it is possible that, as a result of climate 

change, both the number and severity of hurricanes 

may increase, the Bureau of Ocean Energy 

Management’s OSRA estimates the risk of oil-spill 

contact to sensitive offshore and onshore 

environmental resources and socioeconomic 

features. Included in this analysis are trajectory 

simulations based on historical surface ocean 

currents and winds, which incorporate periods of 

hurricane conditions. In addition, BSEE provides a 

robust set of regulations relating to hurricane 

preparedness that help lower the risk of oil spills 

occurring and help prevent any loss of life. The 

effects of hurricanes on coastal areas and oil and 

gas structures are discussed in Chapters 3.1.6.1 

and 3.2.1.1 and in the resource sections in 

Chapter 4. The effects of climate change and sealevel rise on coastal areas is discussed in Chapters 

3.3.2.8.1 and 3.3.2.10 and in the resource sections 

in Chapter 4. 

Louisiana’s land loss has been acknowledged in the 

Multisale EIS, but the contribution from the oil and 

gas industry has been more from inshore activities, 

such as the dredging of location canals through 

marshes, as opposed to OCS oil- and gas-related 

activity. Separating the causes of such land loss is 

difficult, but one study estimated that the total of 

direct and indirect impacts from OCS oil- and gasrelated activities from 1955 to 1978 accounted for 

21,863-49,884 ha (54,024-123,266 ac), or 

8-17 percent of Louisiana’s total wetland loss 

(Baumann and Turner, 1990; Turner and Cahoon, 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-77

Commenter Comment ID Comment Response

can affect the brain, causing seizures, provoke organ 

failure, and ultimately death in several marine 

mammal species, from small sea otters, seals, sea 

lions, to large whales. In the past three decades, 

HABs seem to have become more frequent, more 

intense, and more widespread. BOEM also failed to 

consider how the increased frequency of hurricanes 

and other severe weather events and sea level rise 

will impact coastal areas and oil and gas 

infrastructure. As noted by the Environmental 

Protection Agency in finding that greenhouse gases 

endanger public health and welfare: Observed sea 

level rise is already increasing the risk of storm surge 

and flooding in some coastal areas. The conclusion 

in the assessment literature that there is the potential 

for hurricanes to become more intense (and even 

some evidence that Atlantic hurricanes have already 

become more intense) reinforces the judgment that 

coastal communities are now endangered by human 

induced climate change, and may face substantially 

greater risk in the future. Even if there is a low 

probability of raising the destructive power of 

hurricanes, this threat is enough to support a finding 

that coastal communities are endangered by 

greenhouse gas air pollution. In addition, coastal 

areas face other adverse impacts from sea level rise 

such as land loss due to inundation, erosion, wetland 

submergence, and habitat loss. The increased risk 

associated with these adverse impacts also 

endangers public welfare, with an increasing risk of 

greater adverse impacts in the future. In fact, from 

1932 to 2010, coastal Louisiana has lost about 

1.2 million acres, equating to coastal wetlands 

disappearing at a rate of about a football field per 

hour. The oil and gas industry admits that it is 

responsible for at least 36% of the total loss of this 

area, though the Department of the Interior has 

stated that the industry could be responsible for as 

1987).

BOEM provides estimates of the impact of OCS oiland gas-related activity on coastal wetlands and 

beaches in this Multisale EIS based on currently 

available information. It is also important to note 

that the proposed lease sales discussed in this 

Multisale EIS are set for future dates and that, 

currently, the Secretary of the Interior has requested 

the agencies in the Department of the Interior to 

identify potential compensation for projects that are 

being proposed.

Coastal storms, hurricanes, and sea-level rise are 

addressed in the land use/coastal infrastructure and 

social factors chapters based on existing peerreviewed research. Some language and resource 

references have been added to the chapters to 

expand the discussion of these issues.

For additional information on greenhouse gas 

emissions, please refer to the response to Comment 

CBD, BL, GRN, LBB, RAHC-5.
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-78 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

much as 56% of the loss. And scientists say that at 

current rates, coastal erosion and sea level rise will 

lead to nearly all of Southeast Louisiana to be under 

water by 2100. Yet BOEM fails to adequately 

analyze these impacts or how its proposal will 

contribute to these problems. Moreover, while 

BOEM’s analysis admits that hurricanes and other 

extreme weather events can damage pipelines and 

infrastructure resulting in a release of oil, BOEM’s 

analysis fails to analyze how increased storm 

severity in the face of climate change will increase 

the risks of oil spills, accidents and other 

environmental harms associated with offshore oil and 

gas drilling in the Gulf of Mexico. The failure to do so 

violates NEPA.

Sierra Club,

Devorah 

Ancel,

Staff Attorney

SC-9 BOEM Failed to Adequately Consider Climate 

Change Impacts on the Ocean and Coastal 

Environment: In addition to failing to address the 

impacts of consuming the oil and gas extracted 

under its proposal, BOEM’s environmental analysis 

fails to adequately consider the impacts of climate 

change on the ocean environment. While BOEM 

acknowledges that climate change is occurring, its 

analysis of the impacts of that change is cursory, fails 

to properly disclose the enormity of the problem, or 

the contribution of the proposed action to the 

problem. For example, BOEM fails to adequately 

analyze the impacts of ocean acidification over the 

course of its proposal. The ocean’s absorption of 

anthropogenic carbon dioxide is changing its 

chemistry, lowering its pH and causing ocean 

acidification. Surface ocean pH has already dropped 

by about 0.1 pH units from 8.16 in 1800 to 8.05 

today, resulting in a rise in surface ocean acidity of 

about 30 percent. The pH of the ocean is changing 

rapidly at a rate 100 times anything seen in hundreds 

of millennia, and may drop by another 0.3 or 0.4 

(resulting in a 100–150% increase in acidity) by the 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-79

Commenter Comment ID Comment Response

end of this century. If carbon dioxide emissions 

continue unabated, resulting changes in ocean 

acidity could exceed anything experienced in the 

past 300 million years. Increased ocean acidification 

has significant adverse impacts on marine 

organisms. Among many other impacts, increased 

ocean acidity hinders species such as corals, crabs, 

seastars, sea urchins, and plankton from building the 

protective armor they need to survive. Rising acidity 

also affects the basic functions of fish, squid, and 

invertebrates, impeding growth and increasing 

mortality. Ocean acidification threatens to disrupt the 

entire marine food web. BOEM also failed to 

consider how the increased frequency and severity of 

hurricanes and sea level rise will impact coastal 

areas and oil and gas infrastructure. Sea level rise is 

already increasing the risk of storm surge and 

flooding in coastal areas. Coastal communities are 

endangered by the potential for more intense 

hurricanes and weather events caused by human 

induced climate change. The adverse impacts of sea 

level rise, including land loss, erosion, wetland 

submergence and habitat loss, directly threaten Gulf 

of Mexico’s coastal states. Louisiana has lost more 

than one million acres of coastal wetlands over an 

80 year period. The Department of the Interior has 

stated that the industry could be responsible for as 

much as 56% of the loss. And scientists say that at 

current rates, coastal erosion and sea level rise will 

lead to nearly all of southeast Louisiana to be under 

water by 2100. Yet BOEM fails to adequately 

analyze these impacts or how its proposal will 

contribute to these problems. Moreover, the DEIS 

violates NEPA because it fails to analyze how 

increased storm severity in the face of climate 

change will increase the risks of oil spills, accidents 

and other environmental harms associated with 

offshore oil and gas drilling and infrastructure in the 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-80 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Gulf of Mexico.

Cyrus Reed CR-2 I am also -- you know, I have gained an 

understanding that it's in the programmatic EIS 

where they do all the climate change analysis. That 

being said, I feel like this EIS should at least 

acknowledge that, you know, climate change is real 

and that further oil and gas leasing and oil and gas 

drilling will lead to more, not less, impacts on climate 

change and I feel like it should be addressed in the 

EIS, and it would be a reason to say we -- you know, 

alternatively we don't want to do more oil and gas 

drilling because of those issues.

Brenda 

Warger

BW-3 And finally my last statement I guess is that I'm in 

opposition additionally because while BOEM's EIS 

acknowledges that climate change is occurring, it 

fails to properly disclose the enormity of the problem 

and the contribution of expanded off shore oil drilling 

in the Gulf would have to the problem and that's all I 

have to say.

Kim Ross KR-3 Also the other problem with methane leaks impact 

climate change and that's probably the number one 

issue with the Environmental Impact Statement is 

that it doesn't address this document which intends 

to have lease sales over the next five years but that 

impacts the next 50 plus years. That climate change 

is not adequately addressed from that perspective for 

we know that in the next 50 to 100 years we'll be 

seeing major impacts from sea level rise and other 

things so climate change is not adequately 

addressed in the Impact – Environmental Impact 

Statement.

Renate 

Heurich

RH-6 We have other parts of the world, like the Arctic and 

the Middle East. The Arctic is heating up extremely 

fast with permafrost melting and increased sea level 

rise, which is especially a problem here for us in New 

Orleans.· Sea level rise is going to continue for 

hundreds of years scientists tell us.· And it is -- we 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-81

Commenter Comment ID Comment Response

already see a lot of melting happening of glaciers in 

the Arctic. ... Also, what -- so those are like huge 

impacts that are mentioned, but not really weighed. 

You know, the severity of it was not really evaluated 

sufficiently, I think.

Rebecca 

Parsons

RP-1 Your proposal will undermine the Paris Agreement to 

limit global warming to 2 degrees C.

Your proposal will undermine President Obama's 

commitment to take action on climate change.

Lone Star 

Chapter of the 

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

LSCSC-13 BOEM’s Draft EIS fails to adequately describe 

baseline conditions related to climate change or 

consider the impacts of climate change on the ocean 

environment. While BOEM acknowledges that 

climate change is occurring, its analysis is cursory 

and fails to properly disclose the enormity of the 

problem, or the contribution of expanded offshore oil 

drilling in the Gulf of Mexico, to the problem. For 

example, BOEM fails to adequately analyze the 

impacts of ocean acidification over the course of its 

Proposal, and its Proposal’s contribution to these 

significant environmental problems. BOEM admits 

that hurricanes and other extreme weather events 

can damage offshore oil and gas pipelines and 

infrastructure resulting in spills, but fails to analyze 

how increased storm severity in the face of climate 

change will increase the risks of oil spills, accidents 

and other environmental harms associated with 

offshore oil and gas drilling in the Gulf of Mexico. 

The failure to do so violates NEPA.

This Multisale EIS tiers from the Five-Year Program 

EIS, which describes the baseline conditions due to 

climate change. Additional information has been 

provided in Chapter 4.1 (Air Quality) of this 

Multisale EIS as well. In regards to ocean 

acidification, additional language was included in 

the analysis of impacts to water quality (Chapter 

4.2), marine mammals (Chapter 4.9.1), deepwater 

benthic communities (Chapter 4.4), and live bottom 

habitats (Chapter 4.6) to address ocean 

acidification. Currently, there is insufficient 

information on ocean acidification, potential effects, 

and response of biota, and any mention would be 

too speculative for this Multisale EIS.

While it is possible that, as a result of climate 

change, both the number and severity of hurricanes 

may increase, the Bureau of Ocean Energy 

Management’s OSRA estimates the risk of oil-spill 

contact to sensitive offshore and onshore 

environmental resources and socioeconomic 

features. Included in this analysis are trajectory 

simulations based on historical surface ocean 

currents and winds, which incorporate periods of 

hurricane conditions. In addition, BSEE provides a 

robust set of regulations relating to hurricane 

preparedness that help lower the risk of oil spills 

Lone Star 

Chapter of the 

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

LSCSC-15 BOEM must develop a climate change ecological 

resilience and resistance plan (CCERRP), assessing 

the full biological and ecological elements in the Gulf 

of Mexico and the affects that climate change has 

had and will have on them. A CCERRP would assist 

plants, animals and ecosystems to adapt to climate 

change and would require monitoring of changes and 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-82 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

mitigation measure effectiveness. occurring and that help prevent any loss of life. The 

effects of hurricanes on coastal areas and oil and 

gas structures are discussed in Chapters 3.1.6.1 

and 3.2.1.1 and in the resource sections in 

Chapter 4. 

Your suggestion of creating a climate change 

ecological resilience and resistance plan will be 

considered for implementation as BOEM policy.

Katrina Dubytz KD-3 And then we strongly believe that BOEM must 

develop a climate change ecological resilience and 

resistance plan to assess the full biological and 

ecological elements in the Gulf, and thus assist and 

manage the deeply important plants, animals and 

ecosystems as they adapt to climate change.

Harriett Myers HM-2 We need to be reducing our use of oil rather than drill 

in unsafe places. Due to climate change we also 

need to reduce use of oil.

This Multisale EIS tiers from the Five-Year Program 

EIS, which describes the baseline conditions due to 

climate change. Additional information has been 

provided in Chapter 4.1 (Air Quality) of this 

Multisale EIS as well.

Cyrus Reed CR-6 I do wonder if they have really analyzed -- you know, 

we have seen the climate change, we've seen -- not 

that there haven't been hurricanes always, but we've 

seen more intense hurricanes recently. So, I wonder 

if they have really examined the fact that if it's true 

that those storms are happening more often and 

becoming more intense, what that means for the 

infrastructure in the likelihood of spilling. I am not 

sure that they have analyzed that adequately. So, I 

would like them to do that.

Chapter 3.2.1.1.1 (Trends in Reported Spill 

Volumes and Numbers) reports the total number 

and volume of oil spills reported to USCG from 

various sources, including barges, tanks, pipelines, 

and platforms. The analysis reported in Etkin 

(2009) not only reinforces the fact that hurricanes 

are the most common cause of spills from both 

platforms and pipelines but it also reports that 

structural failures (e.g., corrosion) also account for a 

significant percentage of the total volume of spilled 

oil from offshore pipelines.

While it is possible that, as a result of climate 

change, both the number and severity of hurricanes 

may increase, the Bureau of Ocean Energy 

Management’s OSRA estimates the risk of oil-spill 

contact to sensitive offshore and onshore 

environmental resources and socioeconomic 

features. Included in this analysis are trajectory 

simulations based on historical surface ocean 

currents and winds, which incorporate periods of 

hurricane conditions. In addition, BSEE provides a 

robust set of regulations relating to hurricane 

preparedness that help lower the risk of oil spills 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-83

Commenter Comment ID Comment Response

occurring and that help prevent any loss of life.

Leon Soil and 

Water 

Conservation 

District 

Supervisory 

Board in Leon 

County, 

Florida, Brian 

Lee 

LSWCDSB-1 And as such, my issues with the BOEM's EIS have to 

do largely with concepts that are going to potentially 

affect the ground water in Leon County, because 

continuing to develop and use fossil fuels is going to 

contribute to ocean acidification. When ocean 

acidification occurs, then salt water intrusion occurs 

through Florida's karst geology, which can then 

contaminate our actual drinking water supply in 

Florida.

BOEM has received many comments regarding the 

causal relationships between the combustion of 

fossil fuels, the increasing carbon dioxide (CO2) 

concentrations in the atmosphere, and the resulting 

ocean acidification. These relationships are now 

well-established in the scientific community and are 

acknowledged by BOEM. The consequences and 

impacts of ocean acidification on marine organisms 

are not yet well understood, and this is now an 

active area of research. National priorities 

regarding ocean acidification were summarized in 

the recent National Research Council report, Sea 

Change: 2015-2025 Decadal Survey of Ocean 

Sciences (NRC, 2015). One area of concern is that 

ocean acidification may make it difficult for marine 

organisms to build hard calcium carbonate shells. 

The same process would be expected to slowly 

dissolve calcium carbonate formations. However, 

these theories have not yet been empirically 

demonstrated since changes in ocean acidification 

are measured in hundredths or thousandths of a

standard pH unit.

Groundwater in Leon County is derived from the 

Floridan Aquifer, a thick (up to 3,000 ft [914 m]) 

sequence of carbonate rocks, which encompasses 

the entire state of Florida and is one of the most 

productive aquifers in the world. Similar to other 

aquifers, the Floridan is currently affected by 

declining water levels and saltwater intrusion from 

overpumping and excessive water use. Salt water 

may enter the aquifer offshore where the Floridan 

Aquifer outcrops on the seafloor or it may originate 

from the Lower Floridan formation, which contains 

salt water. Additional information regarding the 

Floridan Aquifer can be found in the Floridan Aquifer 

System Groundwater Availability Study by USGS 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-84 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

(2016).

Ocean acidification is not the cause of karst 

formations in Florida. Fresh water within the 

Floridan Aquifer is located at a higher elevation than 

sea level because fresh water floats on salt water. 

Therefore, it is not expected that ocean acidification 

exacerbates saltwater intrusion into the Floridan 

Aquifer.

Alabama 

Chapter of the 

Sierra Club, 

Carol AdamsDavis

ACSC-1 I would like to request a moratorium on new federal 

oil leases until the climate impacts of the federal oil 

leasing program are taken into account.

In the Five-Year Program EIS, BOEM compares 

greenhouse gas emissions from direct OCS 

emissions to those that could occur from energy 

substitutes that would presumably replace OCS 

production in the absence of a new OCS Program 

and comparable demand levels. Downstream 

greenhouse gases have been quantified. Please 

refer to the Five-Year Program EIS for additional 

information about how BOEM evaluates greenhouse 

gas emissions and climate change. This Multisale 

EIS tiers from the Five-Year Program EIS and has 

included additional information on greenhouse gas 

and downstream emissions information that may 

result from a Gulf of Mexico oil and gas lease sale in 

Chapter 4.1.

Jane McBride JMB-2 Climate change is not a theoretical possibility in the 

future-it is happening now, and we must do all that 

we can to mitigate the disastrous consequences. 

Moreover, the United States should view climate 

change, not as a burden to our economy, but as an 

ECONOMIC OPPORTUNITY for the United States to 

regain its former position as a world leader in 

technology and innovation. No other country in the 

world is in denial about climate change science the 

way (half of) our country is, and the rest of the world 

is begging us to get serious about working with them 

to find solutions to prevent the worst scenarios from 

coming to fruition. Instead of drilling/fracking away at 

our limited oil and gas resources (which are finite 

BOEM determined that an analysis of alternative 

uses is outside the scope of this Multisale EIS for a 

proposed action. The purpose and need identified 

in Chapter 1 is to provide an analysis of the 

environmental impacts of oil and gas leasing.

Per Section 18 of the OCSLA, BOEM is required to 

develop a schedule of oil and gas lease sales on the 

OCS for 5-year periods. Thus, the OCSLA is the 

implementing legislation driving the purpose, and it 

is the law requiring the Secretary of the Interior to 

propose an action. The proposed action under 

NEPA is the proposed lease sales identified in the 

Draft Proposed Program, and the Draft Multisale 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-85

Commenter Comment ID Comment Response

anyway), we should be working to achieve energy 

independence through development of renewable, 

efficient, clean energy technologies that we can then 

SELL TO THE REST OF THE WORLD.

EIS determined possible environmental impacts of 

the proposed action in comparative form to other 

lease sale alternatives allowable under Section 18 

of the OCSLA, including the No Action Alternative 

(i.e., no lease sale). The NEPA requires that 

agencies shall propose actions, and alternatives to 

that action, that meet the purpose and need. This 

means that decisions outside the scope of 

Section 18 of the OCSLA cannot be considered as 

reasonable alternatives (e.g., alternative uses of the 

ocean).

Additionally, over the next 20 years, the U.S. Dept. 

of Energy’s Energy Information Administration 

expects the U.S. to rely on more oil and natural gas 

to meet its energy demands, even as alternative 

sources of energy provide an increasing share of 

U.S. energy needs. Since the U.S. is expected to 

continue to rely on oil and natural gas to meet its 

energy needs, the proposed action would contribute 

to meeting that domestic demand. The OCS is a 

major long-term supplier of crude oil and natural 

gas, and the Gulf of Mexico OCS region has the 

greatest resource potential of the four OCS regions 

in the United States. Additional information 

pertaining to climate change and greenhouse gas 

emissions has been added to Chapter 4.1.

John Kersting JK-3 If the estimated oil and gas reserves on the Outer 

Continental Shelf are extracted and burned, more 

than 60 billion tons of carbon dioxide emissions 

would be released, negating the positive efforts by 

the Obama administration to lower emissions from 

coal plants and vehicles.

Additional information regarding downstream 

emissions of greenhouse gases is included in 

Chapter 4.1 (Air Quality).

Greenhouse Gas

Steps 

Coalition, 

Jennifer 

STEPS-3 By BOEM's own accounts the expansion will lead to 

444 percent more greenhouse gas emissions than 

the level the U. S. committed to be -- committed to in 

order to prevent runaway climate change. Despite 

BOEM recognizes the importance of climate change 

in its NEPA analyses and considers many facets of 

the potential effects of climate change in its 

decisionmaking with respect to oil and gas leasing, 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-86 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Crosslin, 

Community 

Organizer

this, however, BOEM concludes no threats to climate 

change and minimizes the impact the industry 

currently has on the people living on the coast, 

ignoring the environmental and health impacts and 

the threats to other important industries such as 

fishing and tourism, reporting only the benefit of an 

anticipated increase in offshore drilling jobs created 

by the expansion.

whether in the Five-Year Program or lease sale 

analyses. In the Five-Year Program EIS, BOEM 

compares greenhouse gas emissions from direct 

OCS emissions to those that could occur from 

energy substitutes that would presumably replace 

OCS production in the absence of a new OCS 

Program and comparable demand levels. 

Downstream greenhouse gases have been 

quantified. Please refer to the Five-Year Program 

EIS for additional information about how BOEM 

evaluates greenhouse gas emissions and climate 

change. BOEM expects that reducing OCS oil and 

gas consumption in the U.S. and the associated 

emissions from limiting OCS leasing would largely 

be offset by substitutes from other energy sources, 

either within the United States or elsewhere. BOEM 

has considered a no action alternative (i.e., 

cancellation of a proposed lease sale); however, 

that does not necessarily equate to zero 

downstream greenhouse gas emissions from oil and 

gas unless energy demand or supply changes 

drastically or cost-competitive clean energy sources 

are substituted.

This Multisale EIS tiers from the Five-Year Program 

EIS and has included a summary of the greenhouse 

gas and downstream emissions information that 

may result from a Gulf of Mexico oil and gas lease 

sale in Chapter 4.1. 

Sierra Club,

Devorah 

Ancel, 

Staff Attorney

SC-8 BOEM Failed to Consider Downstream Greenhouse 

Gas Emissions: BOEM’s Draft EIS fails to consider 

the greenhouse gas emissions that would be emitted 

by refining, transporting and burning the oil and gas 

to be extracted under its proposal. In evaluating the 

environmental impacts of the proposed action, NEPA 

requires BOEM to consider and describe the direct 

and indirect impacts. These impacts are distinct from 

one another. Direct effects are “caused by the action 

and occur at the same time and place.” Indirect 

effects are caused by the action but, “are later in time 

or farther removed in distance, but are still 

reasonably foreseeable. Indirect effects may include 

growth inducing effects and other effects related to 

induced changes in the pattern of land use, 

population density or growth rate, and related effects 

on air and water and other natural systems, including 

ecosystems.” Downstream greenhouse gas 

emissions are precisely the kind of indirect effects 

that BOEM must consider in analyzing the impacts of 

its leasing proposal. Indeed, guidance from the 

Council on Environmental Quality instructs agencies 

that “[e]missions from activities that have a 

reasonably close causal relationship to the federal 

action, such as those that may occur . . . as a 

consequence of the agency action (often referred to 

as downstream emissions) should be accounted for 

in the NEPA analysis.” As it described, “[f]or 

example, a particular NEPA analysis for a proposed 

open pit mine could include the reasonably 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-87

Commenter Comment ID Comment Response

foreseeable effects of various components of the 

mining process, such as . . . refining or processing 

the resource, and using the resource . . . as the 

direct and indirect effects of phases of a single 

proposed action.” BOEM estimates that its proposal 

could result in the development and production of up 

to an estimated 9.5 billion barrels of oil equivalent. It 

is possible even more oil will be developed given 

BOEM’s estimates that put all undiscovered 

technically recoverable resources in the Gulf of 

Mexico at 73 billion barrels of oil equivalent. Using 

EPA’s carbon equivalent calculator, this means that 

BOEM’s proposal could result in up to roughly 4.1 to 

31.4 billion metric tons of greenhouse gas emissions 

from consumption of the oil. But BOEM wholly failed 

to consider the impacts of these emissions or how 

allowing offshore oil and gas leases in federal waters 

will impact our ability to limit warming below 

2 degrees Celsius consistent with goals of and 

obligations under the Paris Agreement. There is only 

a finite amount of carbon dioxide (“CO2”) that can be 

released into the atmosphere without rendering the 

goal of meeting the 1.5°C (or even a 2°C) target 

virtually impossible. Unleased OCS areas alone 

would consume between 11.6% and 13.8% of that 

global budget. Continued leasing of these fossil fuels 

is incompatible with any reasonable domestic and 

international path to limiting warming to 1.5°C or 

even 2°C. Conversely, keeping fossil fuels in the 

ground by ending new offshore leases will help limit 

warming by reducing greenhouse gas emissions. 

BOEM violates NEPA by ignoring the impacts of 

refining and consuming the oil and gas to be 

extracted under the proposal. This omission makes 

it impossible to know how BOEM’s proposal can 

possibly be consistent with the Paris Agreement and 

efforts to limit warming to 1.5°C or even 2°C to avert 

the worst impacts of climate change.
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-88 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Lone Star 

Chapter of the 

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

LSCSC-5 Climate change, driven primarily by the combustion 

of fossil fuels, poses a severe and immediate threat 

to the health, welfare, ecosystems and economy of 

the United States and the world. In recognition of 

these threats, the Paris Agreement—adopted by 

197 countries, including the United States—codifies 

the international, scientific consensus that climate 

change is an “urgent and potentially irreversible 

threat to human societies and the planet and thus 

requires the widest possible cooperation by all 

countries.” The Agreement commits the signatories 

to hold global average temperature “to well below 

2°C above pre-industrial levels and to pursue efforts 

to limit the temperature increase to 1.5°C above pre-

industrial levels.” This requires rapid and robust 

emissions reductions. Halting new oil and gas 

leases off our coasts would keep up to 62 billion tons 

of carbon emissions in the ground—the pollution 

equivalent of more than 16,000 coal-fired power 

plants. BOEM’s proposal to lease over 70 million 

acres of the Gulf of Mexico so that oil and gas 

companies can drill up to 9.5 billion barrels of oil 

equivalent over the next 70 years will deepen the 

climate crisis and reverse course on President 

Obama’s commitment to combat climate change. 

We urge you to halt all new oil and gas lease sales in 

federal waters, and keep these dirty fossil fuels in the 

ground.

Lone Star 

Chapter of the 

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

LSCSC-12 This EIS also fails to consider downstream 

greenhouse gas emissions. Downstream 

greenhouse gas emissions are precisely the kind of 

indirect effects that BOEM must consider in 

analyzing the impacts of its Proposal under NEPA. 

But BOEM’s Draft EIS wholly fails to quantify the 

greenhouse gas emissions from burning the oil and 

gas to be extracted under its Proposal or consider 

the climate impacts of such emissions. In fact, much 

of this gas and oil will be refined directly in the Gulf 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-89

Commenter Comment ID Comment Response

Area. Moreover, because BOEM ignores these 

impacts, BOEM also fails to discuss how its Proposal 

can possibly be consistent with the Paris Agreement 

and efforts to limit warming to 1.5°C or even 2°C to 

avert the worst impacts of climate change. These 

failures violate NEPA. BOEM has failed to 

adequately assess both nitrogen oxide and volatile 

organic compounds and their role in ground-level 

ozone formation in gulf communities that result from 

the upstream, proposed drilling and downstream 

uses of the products that would emerge from the 

ocean floor. Nitrogen oxide and volatile organic 

compound emissions that cause ozone in areas like 

Houston, Galveston and Beaumont can not and 

should not be ignored in this draft multi-sale EIS. 

Specifically, the oil that would come out of the Gulf 

would most likely be refined in areas like Beaumont, 

Port Arthur, Harris County, Nueces County, as well 

as areas along the coast of Louisiana. To ignore 

these downstream impacts and downstream 

communities is a major failure of this EIS. BOEM 

has underestimated the amount of climate change 

gases and their environmental impacts on human 

and natural landscapes. Past, present and future 

foreseeable actions and their impacts should be 

analyzed and considered in an EIS. Thus, past 

emissions that have led to the present level of 

greenhouse gases from drilling and associated 

activities should be part of the EIS since they impact 

our present and future course.

No New 

Leases Form 

Letter

NNL-3 The agency's refusal to consider or disclose impacts 

from consuming and burning the oil and gas 

extracted under its proposal is also morally and 

legally unjustifiable. BOEM cannot ignore the 

harmful climate effects of its proposal, or whether it's 

consistent with the Paris Agreement and efforts to 

limit global warming to 1.5 or 2 degrees Celsius.

Cyrus Reed CR-5 I'm not sure that this EIS really looks precisely at the 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-90 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

downstream impacts of oil and gas leasing and -- I 

mean that both for Greenhouse gas emissions, which 

I know is supposedly covered in the other EIS, but 

also for just other air emissions. So, if you drill oil 

and gas, you are going to have to either pipe it or 

ship it and it's probably coming here to Beaumont or 

Port Arthur or Louisiana to be refined and there are 

going to be impacts and those should be -- I guess 

my argument is: We shouldn't just look at the oil and 

gas drilling and its era impacts right there at the drill 

rig but also downstream, you know, where it's 

actually refined. So, I feel like that should be 

covered in this area.

Katrina Dubytz KD-2 And then we have reviewed the environmental 

impact statement, everyone on our team at Rethink, 

and it really fails to address the impacts of 

downstream greenhouse gas emissions in 

downstream communities. So, again, people in the 

local area who would be seriously affected by these 

issues are not getting the appropriate attention that 

they should be in this analysis.

Well Stimulation

Center for 

Biological 

Diversity, Bold 

Louisiana, 

Gulf 

Restoration 

Network, 

Louisiana 

Bucket 

Brigade, 

Radical Arts 

and Healing 

Collective

(CBD, BL, 

GRN, LBB, 

RAHC), 

CBD, BL, GRN, 

LBB, RAHC-9 

BOEM Failed to Take a Hard Look at the Direct, 

Indirect and Cumulative Impacts from Offshore 

Fracking and Acidizing: BOEM acknowledges that 

oil companies use offshore fracking and other well 

stimulation treatments in the Gulf of Mexico. 

Offshore fracking and acidizing cause environmental 

damages beyond those of conventional offshore oil 

and gas development by producing water and air 

pollution, increasing the risk of earthquakes and oil 

spills, and prolonging the life of aging infrastructure 

and our use of dirty fossil fuels. But BOEM either 

wholly fails to address the impacts that could occur 

from these dangerous practices in its Draft EIS, or 

provides a woefully inadequate analysis. Water 

contamination is a significant risk of fracking because 

of the hundreds of chemicals used in fracking fluid. 

Thank you for your comment. Language has been 

added to Chapter 4.2 (Water Quality) to provide 

more detail on operational discharges and wastes, 

including those from hydraulic fracturing.

To BOEM’s knowledge, there have been no 

reported or documented seismic events linked to 

OCS well stimulation activities in the GOM. The 

onshore operations associated with the occurrence 

of increased seismic activity tend to use much 

higher volumes of water and proppants and create 

much more expansive fractures in the formation to 

stimulate the flow of natural gas or oil. The primary 

impact-producing factor of concern related to well 

stimulation activities in the Gulf of Mexico OCS 

would be discharges of well treatment, completion, 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-91

Commenter Comment ID Comment Response

Kristen 

Monsell, 

Staff Attorney

For example, a peer-reviewed study that examined 

fracking fluid products determined that more than 

75% of the chemicals could affect the skin, eyes, and 

other sensory organs, and the respiratory and 

gastrointestinal systems; approximately 40 to 50% 

could affect the brain/nervous system, immune 

system, cardiovascular system, and the kidneys; 

37% could affect the endocrine system; and 25% 

could cause cancer and mutations. In addition to 

posing a significant health and safety risk to humans, 

fracking chemicals can kill or harm a wide variety of 

marine life. Scientific research has indicated that 

40% of the chemicals used in fracking can harm 

aquatic animals and other wildlife. Another recent 

study found that oil companies use dozens of 

extremely hazardous chemicals to acidize wells. 

Specifically, the study found that almost 200 different 

chemicals have been used and that at least 28 of 

these substances are F-graded hazardous 

chemicals—carcinogens, mutagens, reproductive 

toxins, developmental toxins, endocrine disruptors or 

high acute toxicity chemicals. Hydrofluoric acid, for 

example, is acutely toxic, and exposure to fumes or 

very short-term contact with its liquid form can cause 

severe burns. The study notes that acidizing 

chemicals can make up as much as 18 percent of the 

fluid used in these procedures. Further, each 

acidization can use as much as hundreds of 

thousands of pounds of some chemicals. This raises 

serious concerns as many of the hundreds of active 

offshore platforms in the Gulf discharge all or a 

portion of their produced water, including chemicals 

used in fracking and acidizing, into the ocean. While 

BOEM does not analyze the impacts of fracking 

wastewater discharges, it dismisses the import of 

produced water discharges generally because the 

discharge is regulated by Clean Water Act permits 

issued by EPA. But, as explained above, BOEM 

and workover fluids, which are discussed in 

Chapters 3.1.5.1, 3.1.3.1, and 4.2. The potential 

effects of produced waters (including well treatment, 

completion, and workover fluids) on other 

resources, such as deepwater benthic communities 

(Chapter 4.4.2), live bottom habitats (Chapter 4.6), 

and protected species (Chapter 4.9), have also 

been analyzed and are expected to be negligible 

due to the assumed compliance with all permitting 

requirements and existing regulations.

As indicated in the references provided, many of the 

risks identified are possible to mitigate with 

increased engineering controls. The BSEE's new 

Drilling Safety Rule significantly improves drilling 

safety by strengthening requirements. In 2012, 

BSEE published a final drilling safety rule and 

addressed some key recommendations made after 

the Deepwater Horizon explosion, oil spill, and 

response; however, in this final rule, BSEE closes 

gaps in existing requirements, addresses additional 

Deepwater Horizon recommendations, and updates 

BSEE’s regulations to reflect industry’s best

practices. Operators must demonstrate that they 

are prepared to deal with the potential for a blowout 

and worst-case discharge, and permit applications 

for drilling projects must meet new standards for 

well-design, casing, and cementing, and be 

independently certified by a professional engineer. 

More information on the new applicable regulations 

and standards for both shallow-water and 

deepwater drilling operations can be found on 

BSEE’s website at http://www.bsee.gov/AboutBSEE/BSEE-History/Reforms/Reforms/. 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-92 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

grossly underestimates the amount of produced 

water being discharged. Moreover, BOEM ignores 

the fact that the permit contains no real limit on the 

quantity of fracking or acidizing chemicals that can 

be discharged. Moreover, an agency cannot excuse 

itself from its NEPA hard look duty because a “facility 

operates pursuant to a. . . permit” or because the 

impacts have been discussed in a non-NEPA 

document. When not dumped directly into the 

ocean, wastewater from well stimulation is injected 

into the seafloor or transported onshore and injected 

there. This disposal method can result in leaks and 

contamination through the loss of well casing 

integrity. Studies have shown that 30% of offshore 

oil wells in the Gulf of Mexico experienced well 

casing damage in the first five years after drilling, and 

damage increased over time to 50% after 20 years. 

Well stimulation can increase the risk of well casing 

damage. For example, a recent scientific study 

found that older wells can become pathways for fluid 

migration, and that the high injection pressures used 

in fracking can “increase this risk significantly.” For 

this same reason, fracking can also increase the risk 

of oil spills. This disposal method can also result in 

the contamination of drinking water. But BOEM 

ignores these impacts. In addition, new studies have 

drawn a strong connection between the recent rise in 

fracking wastewater injection and increased 

earthquake rates. For example, the USGS has 

recognized that wastewater disposal from fracking is 

a “contributing factor” to the six-fold increase in the 

number of earthquakes in Oklahoma. Another recent 

study also found that wastewater injection is 

responsible for the dramatic rise in the number of 

earthquakes in Colorado and New Mexico since 

2001. Wastewater injection has been scientifically 

linked to earthquakes of magnitude three and greater in at least six states: Arkansas, Colorado, Ohio, 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-93

Commenter Comment ID Comment Response

Oklahoma, Texas, and New Mexico. And a recent 

study attributed wastewater injection from fracking 

operations to earthquakes in California. But it is not 

just wastewater injection that can lead to 

earthquakes. The practice of fracking itself has been 

found to contribute directly to seismic events. Even if 

the earthquakes that fracking directly generates are 

small, fracking could be contributing to increased 

stress in faults that leaves those faults more 

susceptible to otherwise naturally triggered 

earthquakes of a greater magnitude. BOEM’s Draft 

EIS ignores these impacts as well. The failure to 

take a hard look at the impacts of offshore fracking 

and acidizing violates NEPA.

United States 

Environmental 

Protection 

Agency

USEPA-3 The DEIS notes reliance on Boehm et al. (2001) for 

information relating to well stimulation activities in 

offshore drilling/production in the Gulf of Mexico 

(GOM). This study discusses the completion, 

stimulation, and workover chemicals that are used in 

the GOM. See p.3-64. The Boehm et al. (2001) 

study outlines a wide variety of chemicals used 

during the oil and gas extraction process. EPA notes 

that BOEM is proposing to update this study and has 

included a proposal to update the study in the 2015-

2017 Study Development Plan.

Recommendation:

EPA recommends the inclusion of trend information 

pertaining to the volumes of well stimulation fluids 

used in well development, any available information 

on the formulation of these fluids, fate and transport, 

and other updated outcomes and issues relating to 

the Boehm study.

We thank USEPA for their interest in BOEM’s 

proposed study to update the information in Boehm 

et al. (2001). BOEM invited a member of USEPA 

headquarters’ staff to participate in the technical 

evaluation of the proposals and in the kickoff 

meeting for the newly awarded update and 

expansion of the study. Upon completion of the 

study, BOEM fully intends to include information 

from the study, as well as a reference to the new 

study, in our future NEPA documents.

John Young JY-1 At least no new leases and/or permitting until the 

Bureau of Ocean Energy Management and Bureau 

of Safety and Environmental Enforcement fully reveal 

all the offshore drilling and fracking they’ve already 

Cancelling all future lease sales and all activities 

under existing lease sales is not before the agency 

with this decision and is outside the scope of this 

Multisale EIS. To the extent that you are requesting 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-94 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

approved, comes clean about how they quietly 

approved such operations, and put fully funded and 

staffed and transparent rules and procedures in 

place to adequately monitor. shut down. remediate, 

and punish violations.

cancellation of this proposed lease sale, we 

acknowledge your preference for Alternative E.

The BSEE's new Drilling Safety Rule significantly 

improves drilling safety by strengthening 

requirements. In 2012, BSEE published a final 

drilling safety rule and addressed some key 

recommendations made after the Deepwater 

Horizon explosion, oil spill, and response; however, 

in this final rule, BSEE closes gaps in existing 

requirements, addresses additional Deepwater 

Horizon recommendations, and updates BSEE’s 

regulations to reflect industry’s best practices. 

Operators must demonstrate that they are prepared 

to deal with the potential for a blowout and worstcase discharge, and permit applications for drilling 

projects must meet new standards for well-design, 

casing, and cementing, and be independently 

certified by a professional engineer. More 

information on the new applicable regulations and 

standards for both shallow-water and deepwater 

drilling operations can be found on BSEE’s website 

at http://www.bsee.gov/About-BSEE/BSEEHistory/Reforms/Reforms/.

Renewable Energy and Alternative Uses of the OCS

Steps 

Coalition, 

Jennifer 

Crosslin, 

Community 

Organizer

STEPS-4 These jobs could easily also be created and likely in 

more numbers by expanding development in offshore 

wind, floating solar, tide and wave technology, and 

associated onshore development. We could, should, 

and absolutely have to break free from fossil fuels by 

stopping the expansion of the oil and gas industry 

and investing in renewables.

Thank you for your comment. The Secretary of the 

Interior oversees the OCS oil and gas program and 

is required to balance orderly resource development 

with protection of the human, marine, and coastal 

environments while simultaneously ensuring that the 

public receives an equitable return for these 

resources and that free-market competition is 

maintained. The decision on whether and how to 

proceed with each proposed lease sale is under the 

authority of the Assistant Secretary for Land and 

Minerals Management and will be disclosed in the 

Record of Decision following publication of this Final 

Multisale EIS.

Gulf 

Restoration 

Network, 

Howard Page 

GRN-12 The Bureau of Energy Management needs to focus 

much more on locating offshore wind resources in 

the Gulf of Mexico. Economics should not be the 

only factor. Offshore wind is viable in the Gulf of 

Mexico. It needs to be part of a diverse energy mix, 

and it certainly needs to be part of a strategy to deal 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-95

Commenter Comment ID Comment Response

with climate change.

BOEM determined that an analysis of alternative 

uses is outside the scope of this Multisale EIS for a 

proposed action. The purpose and need identified 

for this Multisale EIS is to provide an analysis of the 

environmental impacts of oil and gas leasing.

Per Section 18 of the OCSLA, BOEM is required to 

develop a schedule of oil and gas lease sales on the 

OCS for 5-year periods. Thus, the OCSLA is the 

implementing legislation driving the purpose, and it 

is the law requiring the Secretary of the Interior to 

propose an action. The proposed action under 

NEPA is the proposed lease sales identified in the 

Draft Proposed Program, and the Draft Multisale 

EIS determined possible environmental impacts of a 

proposed action in comparative form to other lease 

sale alternatives allowable under Section 18 of the 

OCSLA, including the No Action alternative (i.e., no 

lease sale). The NEPA requires that agencies shall 

propose actions, and alternatives to that action, that 

meet the purpose and need. This means that 

decisions outside the scope of Section 18 of the 

OCSLA cannot be considered as reasonable 

alternatives (e.g., alternative uses of the ocean).

Lone Star 

Chapter of the 

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

LSCSC-7 BOEM has failed to consider alternative uses of the 

ocean that would also support the economic 

development of the Gulf without the adverse impacts 

of oil and gas leasing. First, the significant role of 

tourism, fishing and other recreational uses of the 

ocean are undervalued and the impact that oil and 

gas drilling has on these other ocean uses are not 

adequately considered.

Hilton Kelley HK-6 There are a lot of negative things that are happening 

with all the oil drilling going on in the Gulf of Mexico 

and we think that we should get some reprieve from 

additional oil rigs being -- well, oil rigs out in the Gulf 

and the sale of the Gulf of Mexico. So, that is my 

statement. I am against oil drilling in the Gulf of 

Mexico and we need to look at renewable 

alternatives.

Brenna Landis BL-2 And really we need to be looking at responsibly 

transitioning. Not right away cutting it off, because 

that's unrealistic, but a responsible transition to 

renewable energy.

Restore 

Mississippi 

Sound, 

Sharon Hayes, 

Director

RMS-7 Finally, the decision to adopt the preferred approach, 

which is to lease sale 10 sites for oil and gas 

development, seems illogical. It is based on the 

finding that alternatives to drilling would end up 

costing much more in terms of environmental and 

social costs. This is a result of the assumption that if 

the sites were not drilled, the alternatives would be 

additional imports with spills from transporting that oil 

and coal-fired and other electricity would need to be 

generated. These methods of providing energy are 

associated with a much higher costs than drilling for 

oil. The environmental costs also do not accrue to 

the Gulf. They accrue elsewhere. I also have a 

problem with the assumption that the energy mix that 

they assume for the alternative no-sale, no-drill 

options would stay the same. So no additional 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-96 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

reliance on renewables. They only -- they only 

assume 2 percent of energy consumption would 

come from renewables. However, renewable 

sources of energy consumption have grown almost 

50 percent from 2006 to 2015. And that's from 

6 percent to 10 percent of the energy con -- of 

energy consumed. And it's projected to be 

15 percent in 2022.

Bruce Melton BM-1 There is an alternative missing. The concept is a 

carbon neutral fossil fuel extraction alternative. 

Direct air capture of carbon dioxide is $10 per ton 

using waste heat with Global Thermostat's new 

industrial scale pilot process. Captured C02 can be 

re-injected into fractured oil shale and sequestered in 

far greater quantities than previously assumed, while 

enhancing formation production (which will also need 

to be carbon neutral production as well creating a 

somewhat endless loop.) Tao and Clarens estimate 

the Marcellus Shale alone can hold 10 to 18 

Gigatons of C02 through 2030, or half the C02 

emissions from all US stationary sources during this 

period.

Rebecca 

Parsons

RP-2 It is stunning that your intent is to promote the "same 

old" methods of energy production, when everything 

points to the disasters that will cause. Renewable 

energy innovation and production are proceeding at 

a fast rate - your efforts will be better spent in 

supporting and increasing renewables. Issue 

offshore wind farm leases instead. The dirty 

Industrial Age is over.

Natural Stressors

Restore

Mississippi 

Sound, 

Sharon Hayes, 

Director

RMS-3 The potential impact of storms on oil discharges is 

not considered in the EIS as well is problematic since 

millions of gallons were spilled from pipes in the Gulf 

during Katrina and Rita, and almost 200 platforms 

were either destroyed or badly damaged.

While it is possible that, as a result of climate 

change, both the number and severity of hurricanes 

may increase, the Bureau of Ocean Energy 

Management’s OSRA estimates the risk of oil-spill 

contact to sensitive offshore and onshore 

environmental resources and socioeconomic 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-97

Commenter Comment ID Comment Response

Apalachicola 

Riverkeeper

AR-2 In section 3.2, BOEM states that 47% of spills and 

accidents are due to hurricanes. Hurricanes are a 

prevalent and known reoccurring event in nature and 

as such should be planned for in a risk analysis. The 

statistic demonstrates that these incidents are not 

able to be planned for or that when the total cost of 

safe operations are considered, the analysis may not 

justify operations to recover the oil. At a minimum, 

hurricanes should be well planned for and those cost 

of planning and implementing prevention of such 

losses must be incorporated into costs for justifying 

and maintaining production. Design and construction 

of oil and gas facilities that provide a high level of 

certainty that failures due to hurricanes, such as the 

Taylor Energy leak, do not occur should be 

mandatory. Costs associated with a high level of 

certainty must be understood and planned for as part 

of implementation by the industry before permits and 

leases are considered.

features. Included in this analysis are trajectory 

simulations based on historical surface ocean 

currents and winds, which incorporate periods of 

hurricane conditions. In addition, BSEE provides a 

robust set of regulations relating to hurricane 

preparedness that help lower the risk of oil spills 

occurring and that help prevent any loss of life. The 

effects of hurricanes on coastal areas and oil and 

gas structures are discussed in Chapters 3.1.6.1 

and 3.2.1.1 and in the resource sections in 

Chapter 4. The effects of climate change and sealevel rise on coastal areas is discussed in Chapters 

3.3.2.8.1 and 3.3.2.10 and in the resource sections 

in Chapter 4. 

Additionally, Chapter 3.2.1.1.1 (Trends in Reported 

Spill Volumes and Numbers) reports the total 

number and volume of oil spills reported to USCG 

from various sources, including barges, tanks, 

pipelines, and platforms. The analysis reported in 

Etkin (2009) not only reinforces the fact that 

hurricanes are the most common cause of spills 

from both platforms and pipelines but it also reports 

that structural failures (e.g., corrosion) also account 

for a significant percentage of the total volume of 

spilled oil from offshore pipelines.

Brenna Landis BL-1 We also have a dead zone that we know of from 

runoff from farms all along the Mississippi River that 

comes into our Gulf of Mexico. So any oil spill would 

exacerbate the effect of that dead zone on our 

marine life and plant life in the Gulf.

The hypoxic zone in the Gulf of Mexico is described 

in Chapter 3.3.2.12. The resource chapters in 

Chapter 4 considered this seasonal occurrence in 

the analysis of potential impacts. Please refer to 

Chapters 4.2, 4.5, 4.6.1, 4.6.2, and 4.9.1.

Air Quality

American 

Petroleum 

Institute (API),

Andy Radford

API-16 The DEIS air quality assessment suffers from a lack 

of specificity regarding the basis and criteria for 

establishing impact levels. The document does not 

include a tabulation of the emissions associated with 

the assessed lease sale scenario, or the 

corresponding lease block location. The document 

As stated in Chapter 2.1, “this Multisale EIS 

addresses 10 proposed regionwide oil and gas 

lease sales encompassing all three planning areas 

in the U.S. portion of the Gulf of Mexico OCS.” 

Since the OCSLA requires individual decisions to be 

made for each lease sale, “the analyses contained 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-98 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

also fails to clearly establish where air quality 

impacts should be assessed, in many cases 

describing impact locations as “over the OCS and 

adjacent onshore areas.” A description of offshore 

impacts is irrelevant because the OCSLA limits the 

authority of the Department of the Interior to impacts 

that threaten onshore compliance with the National 

Ambient Air Quality Standards (NAAQS).

in this Multisale EIS examines impacts from a single 

regionwide proposed lease sale.” Therefore, the air 

quality analysis and scenario data are not based on 

a single lease block location.

As stated in Chapter 2.4.1, air emissions from OCS 

oil and gas development and non-OCS oil- and gasrelated activities, as well as air emissions from 

associated activities that take place as a result of a 

proposed action, are discussed. Additionally, it is 

stated, “since the primary NAAQS are designed to 

protect human health, BOEM focuses the impact of 

these activities on the States, where there are 

permanent human populations.” While the OCSLA 

may limit BOEM’s ability to regulate certain activities 

or potential indirect impacts outside of BOEM’s 

jurisdiction, NEPA requires Federal agencies to 

identify and analyze the potential direct, indirect, 

and cumulative impacts of a proposed action and its 

alternatives. Therefore, BOEM discusses the 

impacts to onshore air quality in this analysis. Any 

mistaken references to offshore impacts have been 

removed.

As stated in Chapter 4, “the impact level 

conclusions reached in each resource area consider 

the applicable impact-producing factors, the level of 

activity, and geographic area of each alternative.” 

BOEM lists the definition of the impact levels used 

and specifically mentions the data from the Year 

2011 Gulfwide Emissions Inventory Study as the 

source for assessing the impact-producing factors 

(Wilson et al., 2014).

American 

Petroleum 

Institute (API),

Andy Radford

API-17 Specificity is also lacking when BOEM uses nonqualifiers to describe what should be documented as 

qualitative or quantitative results. For example, 

terms such as "slight impact", "slight effect", and 

"very small" should be well defined to help clarify how 

BOEM has revisited the air quality impact analysis, 

and all nonqualifiers have been replaced with 

qualitative or quantitative results as appropriate.
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-99

Commenter Comment ID Comment Response

these impacts contribute to the impact analysis. It is 

not clear how such qualifiers lead to determination of 

impact levels. API recommends that BOEM provide 

clarification in regards to what the terms represent 

and how these statements result in determination of 

a particular impact level: “The incremental 

contribution of a lease sale would have "slight 

impacts" on coastal nonattainment areas”; “The lease 

sales would have a "very small" impact on visibility 

impairment”

American 

Petroleum 

Institute (API), 

Andy Radford

API-18 The lack of specificity seen in the DEIS is common 

among BOEM NEPA analyses, but it is not uniform. 

Three lease sale EISs – covering lease sales 225, 

226, 235, 238, 241, 246, 247, and 248 – estimate 

onshore criteria pollutant concentrations by assigning 

representative emissions to a representative lease 

block. Because this DEIS serves in support of the 

Multisale and Lease Sale 249 (taking place in 2017), 

it is not clear why this level of detail is not presented. 

In fact, in several places the DEIS air quality 

assessment alludes to this type of detailed analysis 

being conducted but does not include the specific 

results (page 4-27, for example, claims that an 

estimated emission inventory was compiled but does 

not present it). However, for 1-hr nitrogen oxides 

(NOx), a specific result seems to be provided. On 

p. 4-27, the DEIS claims that the 1-hour nitrogen 

dioxide (NO2) standard has not been violated by any 

post-lease air quality modelling and, importantly, that 

the current regulations, reporting, and on-going 

monitoring will ensure that the NO2 NAAQS is not 

violated.

BOEM recently received an updated model with 

revised criteria pollutants and standards. This 

information and the results have been added to 

Chapter 4.4 of this Final Multisale EIS. The air 

quality modeling results show that all averaging 

times for NO2, SO2, CO, and PM10, and the 24-hour 

PM2.5 are below the NAAQS. There was one 

monitoring site with annual PM2.5 current year 

design value concentration above the NAAQS (in

Harris County [Houston], Texas) but reduced to 

below the NAAQS in the future year.

Additionally, as noted in Comment USEPA-9, 

BOEM has coordinated with USEPA prior to 

publication of this Final Multisale EIS to address 

additional comments. Also, specifically for 

USEPA-10, BOEM has begun a study to analyze 

the issue of fugitive emissions, the results of which 

could provide practical mitigations.

United States 

Environmental 

Protection 

Agency

USEPA-9 In Table 1 Alternative Comparison Matrix, air quality 

impacts are identified as minor for all four 

Alternatives. However, in Section 4.1.2 

Environmental Consequences relating to Air Quality, 

the DEIS discussed the incomplete and unavailable 

information needed to assess the impacts from OCS 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-100 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

oil and gas-related activities. It also states that the 

air modeling study results that are necessary to 

determine if lease sale emissions adversely impact 

the State/seaward boundary or the shoreline are 

unavailable. Further, the DEIS identifies that a 

contract exists to obtain information and the results 

should be available in the future EIS documents. 

Thus, there is inadequate information to assess 

impacts to air quality.

EPA's previous air quality impact comments on the 

BOEM lease sale EISs have focused generally on 

mitigation, greenhouse gas emissions, cumulative 

impacts, emissions above the significant impact 

level, and on the air quality offshore modeling 

analysis performed by BOEM.

EPA notes that BOEM is updating the off-shore air 

quality inventory and impact modeling to substantiate 

its NEPA decisions and that modeling results will be 

available after the release of this DEIS. EPA plans to

coordinate with BOEM on review of modeling results 

between the issuance periods of the DEIS and FEIS 

and will provide additional comments on air quality 

during the review of the FEIS.

United States 

Environmental 

Protection 

Agency

USEPA-10

In Section 3.1.8.6 Greenhouse Gases, the DEIS dos 

not quantify GHG emissions and does not include a 

qualitative discussion of climate change impacts 

associated with the OCS and non-OCS oil- and gas-

related operations and activities. On page 4-12, 

Table 4-1 identifies GHG impacts as minor for 

Alternatives A, B, C and D. On page 4-34, EPA 

notes that BOEM is updating air quality inventory and 

impact modeling to substantiate its NEPA decisions, 

and that modeling results will be available after the 

release of this DEIS. EPA plans to coordinate with 

BOEM on review of modeling results between the 

issuance periods of the DEIS and FEIS and will 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-101

Commenter Comment ID Comment Response

provide additional comments on air quality during the 

review of the FEIS.

Recommendation:

EPA recommends the FEIS estimate the direct and 

indirect GHG emissions caused by the proposed 

project and its alternatives, including a discussion of 

the incremental impacts of the estimated GHGs and 

an analysis of reasonable alternatives and/or 

practicable mitigation measures to reduce project 

related GHG emissions.

We recommend considering climate adaptation 

measures based on how future climate scenarios 

may impact the project in the FEIS. The National 

Climate Assessment (NCA), released by the U.S. 

Global Change Resource Program, contains 

scenarios for regions and sectors, including energy 

and transportation. Using NCA or other peer 

reviewed climate scenarios to inform alternatives 

analysis and possible changes to the proposal can 

improve resilience and preparedness for climate 

change.

American 

Petroleum 

Institute (API),

Andy Radford

API-19 In addition, the disparity between the conclusions of 

this document and the 5-Year Program DPEIS is 

confusing. This DEIS concludes air quality impacts 

are "minor", while the DPEIS concludes the air 

quality impacts of the 5-year program in the GOM will 

be “moderate”. Our review shows similar analyses in 

both documents concerning potential impacts to 

onshore areas. That is, dispersion and mitigation 

have proven effective in reducing any threat 

(Wheeler 2008, DEIS at p. 4-27). This has been the 

consistent conclusion of multiple EIS's and modeling 

studies conducted by BOEM and its predecessors. 

API believes the DEIS analysis is correct based on 

the analysis presented. API recommends that BOEM 

The Five-Year Program EIS is a national program 

EIS covering the Alaska, Pacific, and Gulf of Mexico 

regions. In that EIS, the analysis of impacts covers 

the entire proposed program for the given program 

area. For the Gulf of Mexico region that means the 

analysis covers the cumulative impacts of all 

10 proposed regionwide lease sales. The impact 

analysis in this Multisale EIS covers a single 

proposed lease sale of the 10 proposed lease sales 

in the Five-Year Program EIS. Therefore, the 

scales of impacts can differ between the two 

documents. Additionally, BOEM has provided more 

detailed information and modeling results, and the 

text in Chapter 4.1 has been revised.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-102 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

clarify in each document why the disparity exists and 

that the 5-year Program PEIS include a distinction of 

impact by region, in which case would reflect the 

Multisale DEIS conclusion of “minor” for the GOM.

American 

Petroleum 

Institute (API),

Andy Radford

API-20 Pages 4-20 and 4-21: The scales in Figures 4-3 

through 4-6 are misleading. For a common pollutant, 

the binned scales for non-platform and platform 

sources are inconsistent.

Thank you for your comment. These figures have 

been removed and updated figures can be found in 

Appendix H. 

American 

Petroleum 

Institute (API),

Andy Radford

API-21 Page 4-25: “The OCS emissions... would resemble 

past emissions inventories and are indicated in 

Figures 4-9 and 4-10.” – Figures 4-9 and 4-10 show 

Gulfwide emission figures, not emission figures for a 

single lease sale. API recommends that BOEM 

provide additional clarity by stating the figures of 

OCS cumulative emissions or make it clear that the 

distribution of emissions across various platform 

sources would be expected to be similar.

The Gulfwide Emissions Inventories include 

platform source emissions that are collected from 

operators and lessees with leases in the Gulf of 

Mexico OCS that are west of 87.5° W. latitude. 

Figures 4-2 and 4-3 of the Final Multisale EIS 

represent emissions from the Year 2011 Gulfwide 

Emissions Inventory (Wilson et al., 2014). These 

emissions are not OCS cumulative emissions and, 

therefore, resemble past emission inventories.

American 

Petroleum 

Institute (API),

Andy Radford

API-22 Page 4-25: “Platform and well emission were 

calculated using the integration of projected well and 

platform activities over time.” – If this sentence 

describes the 2011 Gulfwide Emission Inventory, that 

should be stated.

The recommended change has been made to the 

text.

American 

Petroleum 

Institute (API),

Andy Radford

API-23 Page 4-27: “Potential impacts resulting from all of 

the above routine activities based on Year 2008 and 

Year 2011 OCS emission inventories, post-lease 

1-hour NOx modeling, and past studies are projected 

to be minor.” Please provide reasoning for the 

“minor impact” determination and improve the clarity 

of this section.

Every tool (i.e., past studies, Year 2008 and Year 

2011 emission inventories, and postlease 1-hour

NOx modeling) used to assess the impacts from 

routine activities found concentrations to be less 

than the maximum allowable increase or less than 

the NAAQS values, or found that a reduction in 

emissions had been achieved through mitigation. 

Based on those findings, the impact analysis for 

routine activities for this Multisale EIS demonstrates 

a minor impact (most impacts on the affected 

resource could be avoided with proper mitigation; if 

impacts occur, the affected resource would recover 

completely without mitigation once the impacting 

stressor is eliminated), as defined in Chapter 4.1 of 

the Draft and Final Multisale EISs.
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-103

Commenter Comment ID Comment Response

Lone Star 

Chapter of the 

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

LSCSC-16 BOEM has failed to adequately assess the impact of 

methane leaks from the upstream, proposed drilling 

and downstream use of these products, and its 

impact on both climate change and other public 

health impacts (such as ozone formation). At a 

minimum, if any drilling is ultimately authorized, 

BOEM must require robust VOC and methane leak 

detection and repair programs.

BOEM awarded a study, “Fugitive Emissions 

Update in the Outer Continental Shelf: Component 

Amounts and Counts,” to update fugitive emission 

factors, component counts, and stream 

compositions for both shallow-water and deepwater 

oil and gas facilities in the Gulf of Mexico OCS.

Updated fugitive emission factors for methane 

developed in this study will assist industry 

compliance with this greenhouse gas reporting 

requirement. Additionally, the Government 

Accountability Office (GAO) has published 

Opportunities Exist to Capture Vented and Flared 

Natural Gas, Which Would Increase Royalty 

Payments and Reduce Greenhouse Gases”

(GAO-11-34) and is seeking to reduce methane 

losses by requiring the installation of control 

technology on platforms to simultaneously improve 

royalty revenue streams and reduce greenhouse 

gas emissions (U.S. Governmental Accountability 

Office, 2010). The updated information is not 

essential at this time because BOEM’s postlease 

plan approvals assess emissions and require air 

quality dispersion modeling to assess VOCs and 

GOADS reports to compare data to review for 

compliance by BSEE. As more information 

becomes available, BOEM and BSEE can impose 

mitigations.

Kim Ross KR-2 So, you know, proposed leases can have an impact 

on methane leaks in the drilling, obviously. So 

methane leaks can lead to greater public health 

impacts and also can lead to greater marine life 

health impacts.

Cyrus Reed CR-7 I kind of mentioned this before, but, yeah, I do want 

them to look at the -- in terms of air emissions, the 

nitrogen oxide and volatile organic compounds, 

because we do have an issue in Texas -- Houston, in 

particular -- but it's been a problem in Beaumont and 

Port Arthur, at least in the past, of ground level ozone 

in the summer. So, I want to make sure that any oil 

and gas leases we're doing aren't going to affect 

ozone because that affects kids and the elderly, in 

particular.

New information has been added to Chapter 4.1; 

this information includes the latest updated Gulfwide 

Emissions Inventory, modeling scenarios, and 

meteorological conditions. It also includes an 

analysis of the potential impacts of ozone across the 

Gulf of Mexico and coastal states.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-104 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Kim Ross KR-1 First from an air quality perspective the 

Environmental Impact Statement fails to adequately 

address nitrogen oxide and other volatile organic 

compounds that are found in ground level ozone 

formation which, and those would result from 

proposed leases so they fail to consider the harm 

that could potentially be impacted on both marine life 

and also the public health of Gulf communities.

Renate 

Heurich

RH-4 Plus, we always have leakage. I've seen so many 

pictures of leaks in the Gulf from oil production. Gas 

is leaking all of the time, and methane is a very 

powerful greenhouse gas. It's, in the shorter term, 

80 times more powerful than CO2, so we absolutely 

need to curb that.

BOEM is currently unaware of any issues related to 

the decommissioning of offshore wells, including 

plugging, sealing, and abandonment. A review of 

spill data reported to both USCG and BSEE provide 

no information showing that abandoned wells are 

currently leaking. This issue is independent from 

the leaking wells from the Taylor Energy platform 

that was lost during Hurricane Ivan and which is 

located in Mississippi Canyon Block 20. Additional 

information regarding this issue has been 

incorporated into this Final Multisale EIS. Please 

refer to the response to Comment LSCSC-16 for 

more information on fugitive emissions.

Kim Ross KR-4 And then finally BOEM and BSEE insist that oil and 

gas activities are regulated in that there have been 

changes from since the Deep Water Horizon 

Macondo oil spill. Several federal studies do find that 

those changes are still lacking and so we need to 

make sure that there's actual changes before we go 

forward with any of these sales so I would 

recommend if possible to select I think it's Alternative 

E, which is to do nothing. To let's avoid lease sales 

and let's make these changes and reconsider in 

another, at another time and if not, then definitely 

these other issues around air quality and methane 

need to be taken into account.

A description of the air emissions’ regulations and 

jurisdiction, and fugitive emissions can be found in 

Chapter 3.1.8. Please refer to Chapter 4.1 for the 

impacts of a proposed action to air quality.

Coastal Habitats

State of 

Louisiana 

LADNR-2 Further, the DEIS fails to adequately quantify and 

assess secondary, indirect, and cumulative impacts 

The text has been edited to revise the discussion 

and increase the estimate for the incremental 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-105

Commenter Comment ID Comment Response

Department of 

Natural 

Resources

(LADNR),

Don Haydel,

Acting 

Administrator

Interagency 

Affairs/Field

of OCS oil and gas activities to Louisiana’s coastal 

resources. One example, which OCM has raised 

numerous times in commenting on earlier BOEM 

actions, is the effect of OCS supply vessels on 

channel widening. BOEM does make estimates of 

these potential land losses in several ways 

throughout the DEIS, which is a positive step. 

However, these estimates are done on a regional 

basis even though most of the impacts will be in 

Louisiana due to the state’s central role in supporting 

the offshore oil and gas industry. BOEM then 

reaches the conclusion that the impacts are small 

enough to be ignored, even though the values of land 

loss are cumulatively significant:

In the section on Navigation Channels, land loss 

under the Preferred Alternative is estimated to be 

0.99 to 12.4 acres per year, Gulf-wide, based on 

OCS-related vessel traffic and average rates of 

channel widening. Over the 50-year span of 

development due to these lease sales, this amounts 

to 49.5 to 620 acres (DEIS Table 3-6, Pg. 3-49).

Elsewhere, BOEM estimates that indirect impacts 

from wake erosion and saltwater intrusion will result 

in the loss of 831 acres per year, Gulf-wide, of which 

less than 2 percent is due to OCS-related traffic. 

1 percent of 831 acres per year is 8.31 acres per 

year, which over 50 years totals 415.5 acres (DEIS 

pg. 4-59).

Yet elsewhere, the Louisiana Comprehensive Master 

Plan is cited as projecting wetland losses in 

Louisiana at 1,750 square miles over the next 

50 years. BOEM’s estimate that OCS oil- and gasrelated vessel traffic would contribute approximately 

one percent to this land loss over the next 70 years 

works out to 175 square miles, or 112,000 acres 

impacts to wetlands from OCS oil- and gas-related 

activity as a result of a single proposed lease sale 

from negligible to minor to moderate. This is 

because BOEM agrees with Louisiana to the extent 

that the Draft Multisale EIS underestimated the 

incremental impacts because BOEM estimates that 

“land loss due to a proposed action range from 28 to 

350 ha (~70 to 860 ac) over 70 years. Cumulative 

analyses are also included in order to put the 

incremental contribution of a proposed lease sale in 

context of the other types of activities (i.e., past, 

present, and reasonably foreseeable) that have the 

potential to cause impacts similar to those analyzed, 

including impacts from the overall OCS Program. 

Many of the impacts to environmental resources 

that are identified in the cumulative analysis of this 

Multisale EIS (and many previous NEPA 

documents) have occurred over many years, much 

of it prior to the enactment of important laws to 

protect the environment and prior to the bulk of OCS 

oil- and gas-related activities. BOEM has no 

authority to provide compensatory mitigation to the 

State of Louisiana in the same manner as an 

applicant for a Louisiana Coastal Use permit. 

BOEM is not an “applicant” for its OCS lease sale 

activity, as it does not propose specific Federal 

development projects in any States’ coastal zone.

While Federal law does not provide for 

compensatory mitigation in this case per se, the 

Government has provided funding through other 

means in recognition of these ongoing impacts. The 

Coastal Impact Assistance Program (CIAP) was 

established by The Energy Policy Act of 2005 

(Public Law 109-58). The CIAP authorizes funds 

from OCS oil and gas revenues to be distributed to 

OCS oil- and gas-producing states for the 

conservation, protection, and preservation of coastal 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-106 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

(DEIS pg. 4-65). BOEM concludes that “Because of 

the small incremental increase in cumulative impacts 

to coastal wetlands associate with OCS oil- and gasrelated vessel traffic ... impacts are expected to be 

minor.” ( DEIS pg. 4-66), and “ ...only negligible 

impacts related to vessel traffic would result from the 

proposed action” (DEIS pg. 4-58) (emphasis in the 

original).

However these estimates are calculated, these are 

NOT minor or negligible losses of wetlands. OCM, 

through its Coastal Use Permitting Program requires 

all Coastal Use Permit applicants to mitigate for 

wetland losses, even those losses that are less than 

0.1 acre. The requirement to offset unavoidable 

cumulative losses is not dependent on the scale of 

the proposed activity; lost habitat value is lost habitat 

value. BOEM’s characterization of these losses as 

minor or negligible is a continued abrogation of its 

responsibilities under the National Environmental 

Policy Act, Outer Continental Shelf Lands Act, 

Coastal Zone Management Act, Executive Orders, 

and the Department of the Interior’s policies, all of 

which make clear that the Federal agency 

responsible for an activity is also responsible for 

mitigating for the direct, indirect, secondary and 

cumulative impacts.

Further, these estimates are merely for the five-year 

program under consideration, and do not address the 

impacts to Louisiana of OCS lease sale activities 

dating back to 1954.

areas including wetlands. In recent years, 

Louisiana has received over $1 billion in offshore 

8(g) revenues, over $0.5 billion dollars in CIAP 

funds, and stands to receive more offshore revenue 

shares in coming years from the Gulf of Mexico 

Energy Security Act of 2006 (Public Law 109-432).

In answer to the specific comments from page 2 of 

your letter regarding the regional nature of BOEM’s 

analyses, the Draft Multisale EIS chapter on coastal 

habitats devotes substantial discussion to 

Louisiana’s coastal ecosystem and even 

acknowledges that Louisiana “currently accounts for 

about 90 percent of the total coastal wetland loss in 

the continental U.S.” and that “Port Fourchon 

currently services approximately 90 percent of all 

deepwater rigs and platforms in the GOM.” 

However, a proposed action involves proposed 

lease sales that affect the entire GOM, and thus 

regional estimates are appropriate.

BOEM’s responses to the bulleted items in your 

letter are below and are in the order of the bullets in 

your letter.

1. Agreed, based on Table 3-6 of the Draft 

Multisale EIS.

2. The Draft Multisale EIS says that a proposed 

action accounts for less than 2 percent of the 

total traffic (page 3-46). Half of the OCS 

traffic would be from Port Fourchon, which 

has an armored channel, thus reducing 

erosion rates (Kaiser, 2015).

3. Please note that 1 percent of 1,750 mi2 is 

17.5 mi2

, or 11,200 ac (4,532 ha).

BOEM has revisited the impact conclusions for 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-107

Commenter Comment ID Comment Response

vessel traffic. The text has been revised to increase 

the estimate of impacts of OCS oil- and gas-related 

activity to wetlands. BOEM has also updated its 

impact conclusion definitions.

Charles 

Mackey Clark

CMC-1 Two Blocks of Central Planning Area (CPA) closest 

to Horn Island are quite close to that barrier island – 

2 miles or so. For this pristine island, that represents 

an environmental and aesthetic threat.

Thank you for your comment. Federal OCS waters 

begin 3 nmi (3.5 mi; 5.6 km) off the coast of 

Mississippi. BOEM analyzed the potential visual 

impacts of OCS oil- and gas-related activities on 

Horn and Petit Bois Islands in Chapter 4.12. BOEM 

acknowledges that OCS structures could negatively 

impact the viewshed near these islands. However, 

BOEM has determined that these impacts would be 

negligible to minor because of the locations and 

types of structures that are forecasted to arise from 

the alternatives. In addition, BOEM has issued an 

ITL regarding the subsequent review processes that 

will occur prior to any activities on leases within the 

first 12 mi (19 km) of Federal waters near the Gulf 

Islands National Seashore.

Gulf Coast 

Group of the 

Mississippi 

Sierra Club, 

Steve 

Shepard, 

Chair

GCGMSC-2 I am very upset to be living through the Shell Oil spill. 

It's one spill on top of another. We should stop that. 

And in a more specific way, just looking at your 

Central Planning Area, I object to the fact that 

Mississippi has open for leasing waters all the way 

essentially to the barrier islands. I know it's probably 

three miles outside the barrier islands. But there is a 

push to establish drilling rigs close to Mississippi 

waters and also to Mobile Bay. I think we should do 

the same thing that Baldwin County has, which is a 

moratorium near shore.

Hilton Kelley HK-2 We have some concerns about land erosion due to 

oil coming into the wetlands, killing the vegetation, 

and also helping to erode the land due to the lack of 

vegetation holding up the land together. There's a 

serious erosion in sea-level rise in the wetlands as 

well.

Thank you for your comment. Please refer to 

Chapter 4.3.1 for the analysis of oil and gas 

development impacts on wetlands.

Hilton Kelley HK-4 And, also, we want to reclaim our beaches. I 

remember as a kid growing up here in Southeast 

Texas walking on McFaddin Beach and one time I 

stepped in this soft spot and it was just all gooey and 

all of a sudden, my leg just went all the way down in 

it up to the knee and it was nothing but tar and the 

sand had somewhat covered it over. I never went 

back to that beach and our beaches have, basically, 

been -- particularly McFaddin Beach -- have been 

destroyed because of the tar balls that wash up 

almost annually.

Thank you for your comment. Please refer to 

Chapter 4.3.2 for the analysis of oil and gas 

development impacts on coastal barrier beaches 

and associated dunes.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-108 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

United States 

Environmental 

Protection 

Agency

USEPA-5 On pages 4-81 and 4-82 under the Vessel Traffic and 

Dredging Section, the DEIS identifies the waves 

generated by boats, ships, barges, and other vessels 

erode unprotected shorelines and accelerate erosion 

in coastal barrier beaches already affected by natural 

erosion processes. Also, it states that the existing 

armored navigation channels minimize or eliminate 

the potential for shoreline erosion from vessel traffic. 

The DEIS identifies the impact of erosion of coastal 

barrier beaches and associated dunes from vessel 

traffic to be negligible, and maintenance dredging to 

be minor.

Recommendation:

EPA recommends the FEIS provide specifics on 

existing navigation channels which are

armored and not armored in order to fully evaluate 

impacts from vessel traffic and

dredging.

This Final Multisale EIS has been revised to state 

that impacts to coastal barrier beaches and dunes 

from dredging would be minor (revised from 

negligible); however, the vessel traffic itself would 

not cause much beach erosion because <2 percent 

of the vessel traffic is related to a proposed action 

and because many of the passes (where navigation 

channels cross the beaches) used for the OCS are 

armored.

BOEM used an estimate from Thatcher et al. (2011) 

that 30 percent of the channels were armored. That 

study, funded by BOEMRE (BOEM’s predecessor), 

examined the extent of armoring and the type of 

substrate along the lengths of 17 navigation canals 

in the GOM.

United States 

Environmental 

Protection 

Agency

USEPA-8 In Section 4.3.1.2 Disposal of OCS-Related Wastes, 

Trash, and Debris and Section 4.3.2.2 Environmental 

Consequences, the DEIS states that "BOEM and 

BSEE have addressed the marine debris issue by 

imposing marine debris awareness and prevention 

measures on the oil and gas industry through NTL 

2015-BSEE-GOE, which provides guidance to the 

industry operators regarding dumping trash and 

debris into the marine environment and informs 

operators of regulations set by other regulatory 

agencies (i.e., the USEPA and USCG). Because of 

the mitigations and awareness, OCS oil- and gasrelated trash and debris from a proposed action 

would result in negligible impacts to estuarine 

habitat."

In the absence of data to substantiate the 

BOEM acknowledges the fact that debris from OCS 

oil- and gas-related activities contributes to the 

debris found on coastal beaches. For example, the 

Draft Multisale EIS states that the offshore oil and 

gas industry was shown to contribute 13 percent of 

the debris found at the Padre Island National 

Seashore (Miller et al., 1995). However, this debris 

does not alter beach profiles, species composition 

and abundance, or ecological function beyond a 

minor extent.
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-109

Commenter Comment ID Comment Response

effectiveness of these measures, it is unclear how 

the basis of negligible impact was determined. The 

impacts of trash and debris on aquatic ecosystems, 

particularly with regard to micro-plastics are being 

studied more intensely, and plastic is now found 

throughout the world's oceans.

Recommendation:

EPA recommends analyzing trend data on oil and 

gas-related debris washing up on beaches to support 

the qualitative evaluation. Amounts of vessel and 

platform litter released to the ocean were estimated 

as far back as at least thirty years ago by such 

organizations as the National Academy of Sciences, 

the Marine Mammal Commission, NOAA and others. 

More recent studies and beach debris catalogs are 

available for comparison and trend analysis.

Biologically Sensitive Areas

Cyrus Reed CR-4 I do recognize that Alternative D seems to open up 

the potential to protect the areas with topographic 

special features. I am not a, you know, biologist. So, I 

am going off memory here. But topographic, I guess, 

high features in the ocean floor.

And, so, I would absolutely -- if oil and gas drilling is 

going to be done, all of those areas -- and you know 

I've got a list of them that I copied from the East 

Flower Garden Bank, West Flower Garden Bank, 

Horseshoe Bank. There's, you know, 30 or so of 

them, and I won't read them all, but, yeah, I do 

believe, at the very least, should be protected 

because we know from the BP Deep Horizon 

Disaster, you know, what can happen when there are 

oil and gas released and how that can impact these 

places. So, keeping drilling out of those areas would 

be very important.

Thank you for your comment. We note that your 

preferred alternative is Alternative D. The Secretary 

of the Interior oversees the OCS oil and gas 

program and is required to balance orderly resource 

development with protection of the human, marine, 

and coastal environments while simultaneously 

ensuring that the public receives an equitable return 

for these resources and that free-market 

competition is maintained. The decision on whether 

and how to proceed with each proposed lease sale 

is under the authority of the Assistant Secretary for 

Land and Minerals Management and will be 

disclosed in the Record of Decision following 

publication of this Final Multisale EIS. Additionally, 

under all of the alternatives, BOEM has determined 

that these areas would be protected through 

application of the Topographic Features Stipulation

and the Live Bottom (Pinnacle Trend) Stipulation for 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-110 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

each proposed lease sale.

Apalachicola 

Riverkeeper

AR-4 BOEM considers the Gulf of Mexico as a Class II, 

moderately productive ecosystem, but then states 

that the long term productivity is stressed. The 

assumptions do not provide a scenario that will 

improve the short or long term productivity back to or 

closer to its natural level of productivity. The Gulf of 

Mexico Restoration Council has established 

programs and projects to improve the Gulf of Mexico 

back toward its more natural productivity. It is not 

logical to consider vast numbers of additional acres 

for oil and gas leases knowing the risk of impacts are 

high; both short- and long-term when this action is in 

conflict with the Council’s objective. A consistent 

assessment of goals should be undertaken.

The purpose of this Multisale EIS under NEPA is to 

disclose the impacts of oil and gas leasing on the 

physical, biological, and human environment. This 

way, the Assistant Secretary for Land and Minerals 

Management can make an informed decision on 

whether and how to hold a lease sale. Through our 

cumulative impacts analysis, BOEM has identified 

multiple stressors in the GOM, many of which are 

outside of BOEM’s jurisdiction. Therefore, it is 

outside the scope of this Multisale EIS to return the 

GOM back to its natural levels of productivity. 

Throughout our analysis, BOEM has provided 

protections wherever possible to protect sensitive 

habitats and resources as we fulfill our mission to 

“manage the mineral resources located on the 

Nation’s Outer Continental Shelf in an 

environmentally sound and safe manner.” The Gulf 

of Mexico Restoration Council is a separate entity 

with a separate mission from that of BOEM. 

However, BOEM is committed to working with all 

stakeholders in the GOM region to ensure that 

stressors under BOEM’s jurisdiction are mitigated if 

possible, with the goal that the GOM remains a 

productive ecosystem.

Fish and Invertebrates

American 

Petroleum 

Institute (API),

Andy Radford

API-24 It is at times difficult to link conclusions with the 

information presented in the DEIS. This is in part 

due to information that is presumably found in 

associated documents. While this is intended to 

facilitate brevity, it makes it difficult to identify the 

studies supporting findings. For instance, the 

potential impacts of a very large accidental release 

on Gulf resources are assessed in a separate 

document, Essential Fish Habitat Assessment for the 

Gulf of Mexico. However, it is unclear how the 

analysis from that white paper informed the DEIS. 

Furthermore, the lack of a clear linkage between the 

The information in Chapter 3.1.5.1.6 (Cooling 

Water) incorrectly indicated that Chapter 4.7 would 

provide more detail on the entrainment of eggs and 

larvae. Chapter 3.1.5.1.6 has been revised to 

remove this reference and clarify that a negligible 

impact is expected.

The potential magnitude of impact for each of the 

identified impact-producing factors is provided in a 

summary table at the beginning of each resource 

section in Chapter 4 to help the reader quickly 

identify the level of potential impacts. The impact-
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-111

Commenter Comment ID Comment Response

conclusion and supporting evidence makes it difficult 

to follow the identification of an issue and the impact 

determination of the respective issue. For instance, 

entrainment of fish eggs and larvae is identified as an 

issue early on, but is later identified as not an 

important issue. Moderate impacts to fish and 

invertebrates are associated with cumulative 

impacts. However, the moderate cumulative impacts 

due to sound and fisheries are based on an unknown 

amount of future impact due to activities unrelated to 

the OCS lease block that could range from negligible 

to moderate (i.e., population level impacts but which 

are not long-term). Given that this conclusion is 

extremely broad and is based on unknowns, API 

recommends that BOEM prepare a summary table 

and impact scores should better reflect the level of 

uncertainty and a predicted contribution from the 

OCS activities.

level definitions and the analyses supporting these 

conclusions are discussed therein.

The table summarizing cumulative impacts 

distinguishes between OCS oil- and gas-related 

activities and non-OCS oil- and gas-related activities 

to mirror the discussion of these topics. Although 

many factors affect the levels of shipping, 

commercial fishing, recreational fishing, and other 

activities that generate impact-producing factors, it 

is not necessary to predict activity levels in order to 

reasonably assume that these activities would 

continue to occur and generate impact-producing 

factors. The analysis includes reasonably 

foreseeable aggregated activities and associated 

impact-producing factors, but it does not attempt to 

address the multiple individual aspects of the many 

human activities occurring in the marine 

environment, which would be speculative and would 

not benefit the overall analysis.

American 

Petroleum 

Institute (API),

Andy Radford

API-25 Page 4-185: Four impact producing factors were 

examined, including anthropogenic sound, bottom 

disturbing activity, habitat modification and oil spills. 

Notable exceptions were that magnitude of the 

potential impacts from all sounds combined (i.e., 

vessel traffic, exploratory drilling, geophysical 

activities, and offshore construction) would be minor 

for the Alternatives considered. Not included were 

produced water discharges and impingement and 

entrainment (from cooling water intake structures on 

the facility). The DEIS states impingement and 

entrainment were not considered based on limited 

exposure and/or response expected. The analysis 

showing that these factors are a limited exposure is 

not presented, even though two papers that support 

the analysis were mentioned on page 3-66 (i.e., LGL 

Ecological Research Associates Inc., 2009 and LGL 

Ecological Research Associates Inc., 20014), and 

Chapter 3.1.5.6 has been revised to clarify the 

potential extent of impingement and entrainment, 

and a discussion of effluents has been included in 

the analysis in Chapter 4.2.2.1 (Water Quality, 

“Routine Activities”).
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-112 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

the reader is referred to Chapter 4-7 for “[m]ore 

information on the specifics regarding potential 

impacts to fisheries...”. Effluents and potential 

constituents of some effluents and the potential 

impacts from cumulative discharges over the 50 year 

lease period should be discussed to substantiate 

their omission.

American 

Petroleum 

Institute (API),

Andy Radford

API-26 Section 4-7 (p 4-184) - Why are surface waters only 

considered for icthyoplankton? On p. 4-187 only one 

life history category is considered (icththyoplankton). 

Concentration areas for fish eggs and larvae are 

described, particularly locations influenced by the 

Mississippi River. If these concentration points are 

widely distributed throughout the lease areas, this 

should be specified as Section 4.7.2 on p. 4-191 and 

4.7.2.1 on page 4-202 indicate that the analysis 

assumes a non-random, even distribution of fish and 

invertebrates; otherwise the potential impacts to 

concentrations of eggs and larvae in portions of the 

Gulf should be discussed for each Alternative. API 

suggests that BOEM provide clarification as to why 

surface waters were only considered in the context of 

oil and gas impacts and non-oil and gas impacts.

Chapter 4.7 has been revised to clarify that surface 

waters were considered with respect to coastal 

pelagics, epipelagics, and ichthyoplankton. 

Additional explanation of hydrographic features was 

included to Chapter 4.7 to clarify how and where 

eggs and larvae may become concentrated relative 

to other surface waters in the Gulf of Mexico. 

Chapter 4.7 states that distribution is generally 

associated with particular water column or other 

habitat characteristics. However, fishes and 

invertebrates are assumed to be broadly distributed 

within the range of preferred habitat particular to a 

species.

American 

Petroleum 

Institute (API),

Andy Radford

API-27 Page 4-200: For impacts due to OCS activities, the 

DEIS relies on the resource agencies to limit 

potential impacts from commercial and recreational 

fisheries. However, for cumulative impacts, the DEIS 

indicates that moderate impacts might be expected 

for areas/species that are overfished. The DEIS 

should be consistent in the role of resource agencies. 

In addition, the expression of impacts as moderate 

should clearly state that this is due to non-OCS 

impacts. Furthermore the offset from habitat/fish 

biomass that is provided by the presence of OCS 

structures in the Gulf should be mentioned.

BOEM does not have the authority to manage fish 

populations in the GOM; therefore, we rely on and 

work with other Federal agencies to maintain 

healthy populations of fishes in the GOM. For more 

detail, please refer to the discussion in the 

“Non-OCS Oil- and Gas-Related Activities” section.

BOEM appreciates the observation that cumulative 

fisheries impacts result from activities other than 

OCS oil- and gas-related activities. Including the 

impact-producing factors’ explanation and analysis 

in the “Non-OCS Oil- and Gas-Related Activities” 

section should sufficiently highlight the fact that 

these fishing impacts are not due to OCS oil- and 

gas-related activities.
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-113

Commenter Comment ID Comment Response

With respect to infrastructure as habitat, no “offset” 

is associated with OCS oil- and gas-related 

infrastructure. Although the distribution of species 

has been associated with some infrastructure, the 

comment appears to attribute a production-specific 

benefit, which has been theorized. Although BOEM 

acknowledges the use of these temporary structures 

as habitat by several species of fishes and 

invertebrates, BOEM also recognizes that the 

structures must be decommissioned and removed 

during the 50-year analysis period. Furthermore, 

any specific habitat benefit has not been 

determined, and stock assessments have not 

identified any biomass increases associated with 

OCS oil- and gas-related infrastructure; for BOEM to 

do so would be speculation.

American 

Petroleum 

Institute (API),

Andy Radford

API-28 Pages 4-201 and 202: States that there could be 

moderate impacts due to unknowns only if the 

“impact-producing factor affects habitat or 

populations to an extent that would be expected to 

exceed natural variation in population abundance or 

distribution but not result in a long-term decline.” 

This is the definition of moderate impacts. This 

should be caveated with the probability that OCS 

lease options would contribute to that potential 

moderate impact (e.g,. although the contribution of 

OCS lease activities are predicted to be negligible to 

minor).

The definition was prepared with respect to potential 

impacts to fishes and invertebrates and not only as 

a consequence of OCS oil- and gas-related activity. 

Therefore, the probability that a specific level of 

impact could be caused by specific activities is not 

relevant.

Birds and Protected Birds

American 

Petroleum 

Institute (API),

Andy Radford

API-29 As with the previous sections, it is difficult to link 

conclusions with underlying data. This is in part due 

to information that is presumably found in associated 

documents. API recommends that BOEM considers 

using a table as described at the beginning of this 

section to more clearly link conclusions with the data. 

Moderate to major impacts for birds are associated 

with cumulative impacts. However, the higher impact 

Thank you for your comment. The information 

referenced on page 4-218 of the Draft Multisale EIS 

was incorrect and BOEM has corrected it in the 

Final Multisale EIS. The comment is not correct 

about the derivation of the higher impact (major) on 

page 4-220 of the Draft Multisale EIS. The text 

there states, “The incremental cumulative impacts of 

a proposed action to non-OCS oil- and gas-related 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-114 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

rating is primarily due to non-OCS factors such as 

West Nile virus, predation by cats, and wetland 

subsidence (Page 4-220), whereas the potential 

impacts from the Deepwater Horizon, non-OCS oil 

and gas related factors and the minimization of OCS 

oil and gas-related impacts through lease stipulations 

and regulations were considered to be negligible 

(Page 4-218). Given that this conclusion is 

extremely broad and is based primarily on non-OCS 

related oil and gas activity impacts, the summary 

table and impact scores should better reflect the level 

of uncertainty and a predicted contribution (or lack 

thereof) from the OCS activities.

anthropogenic events and natural processes are 

considered major, but only because of the impact of 

non-native diseases.” The text in the Final Multisale 

EIS has been clarified, but the impact levels for 

cumulative OCS oil- and gas-related impactproducing factors in Table 4-11 are correct, as are 

the impact levels for non-OCS oil and gas-related 

impact-producing factors.

American 

Petroleum 

Institute (API),

Andy Radford

API-30 Page 4-306 “Impacts to protected species were 

deemed negligible to moderate if a protected bird 

species changes it normal migratory behavior due to 

artificial lighting”. API recommends that BOEM 

provide more scientific justification and references to 

better explain this moderate rating should be better 

explained or suggest that BOEM down-rate to minor.

Thank you for your comment. Please refer to the 

impact criteria as defined in Chapter 4.9 (Protected 

Species). Moderate impacts are expected if acute 

behavioral changes occur due to an anthropogenic 

stimulus, including artificial lighting. Nocturnal 

circulating events can have negative impacts to the 

health of migratory birds (refer to Chapter 4.8

[Birds] for more details). Of the protected bird 

species considered, the piping plover and red knot 

would be the most likely impacted by artificial 

lighting on OCS structures due to their migratory 

behavior and offshore foraging.

Lone Star 

Chapter of the 

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

LSCSC-11 The EIS does look at potential impacts on important 

species like turtles and migratory birds. However, 

the impacts are severely understated, particularly 

with regards to the impacts of major spills.

BOEM has determined that the analysis in this 

Multisale EIS is centered on the best available and 

credible scientific information. BOEM’s subjectmatter experts are experts in their fields and 

conducted extensive scientific and literature reviews 

to ensure their analyses and impact conclusions are 

fully supported by the best available and credible 

scientific information. BOEM’s subject-matter 

experts have clarified in this Multisale EIS where 

incomplete or unavailable information may be 

essential to a reasoned choice among alternatives, 

if the information could be obtained or, if the costs of 

obtaining it are exorbitant, and that what 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-115

Commenter Comment ID Comment Response

scientifically credible information is available was 

applied using accepted scientific methodologies.

BOEM’s analysis of oil-spill risk, which is detailed in 

Chapter 3.2.1, includes detailed discussions of 

offshore spills <1,000 bbl and ≥1,000 bbl, and 

coastal spills. As described in Chapter 3.2.1.4.2

(Trajectory Modeling for Offshore Spills ≥1,000 bbl), 

the Bureau of Ocean Energy Management’s OSRA 

model simulates the trajectory of thousands of spills 

throughout the Gulf of Mexico OCS and calculates 

the probability of these spills being transported and 

contacting specified geographic areas and features. 

Using these assumptions, BOEM’s subject-matter 

experts then evaluated the potential impacts to the 

resource, including birds and sea turtles. While 

there are always some judgment calls that must be 

made when developing forecasts for a scenario and 

the potential resulting impacts, BOEM believes this 

is a reasonable approach and that it would tend to 

be conservative in probably overestimating impacts 

rather than underestimating them.

Each alternative single lease sale scenario is based 

on (1) recent trends in the amount and location of 

leasing, exploration, and development activity; 

(2) estimates of undiscovered, unleased, 

economically recoverable oil and gas resources in 

each water-depth category and each planning area; 

(3) existing offshore and onshore oil and/or gas 

infrastructure; (4) published data and information; 

(5) industry information; and (6) oil and gas 

technologies and the economic considerations and 

environmental constraints of these technologies. 

Due to the inherent uncertainties associated with an 

assessment of undiscovered resources, probabilistic 

techniques were employed to develop the 

reasonably foreseeable postlease activities 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-116 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

scenario, and the results are reported as a range of 

values corresponding to probabilities of occurrence. 

BOEM used the aforementioned categories to 

develop a low-activity scenario and a high-activity 

scenario. The activity level associated with a 

proposed lease sale is expected to vary based on a 

number of factors, including the price of oil, 

resource potential, cost of development, and 

resource availability (e.g., drill rig availability). 

BOEM feels the developed ranges provide a 

reasonable expectation of oil and gas production 

and associated activity anticipated from a single 

proposed lease sale.

Marine Mammals

American 

Petroleum 

Institute (API),

Andy Radford

API-31 The Impact Producing Factors section (Section 

3.1.2.1 p. 3-10) provides a reasonable, but brief, 

summary of geological and geophysical (G&G) 

operations with references to the Atlantic G&G PEIS 

and a GoM G&G PEIS currently being developed. 

Although an exhaustive review of G&G activities may 

not be necessary, it would be appropriate from 

BOEM to provide a greater level of detail in this EIS, 

especially descriptions that are relevant to recent 

survey activities in the GoM. More importantly, the 

text in this DEIS only describes the activities 

themselves and does not review available 

information on the mechanisms of potential impacts 

to relevant species. Such information for marine 

mammals is not present in this section nor is it 

present in the Impact Analysis section (4.9.1.2). A 

more detailed review and analysis of potential 

impacts from G&G activities resulting from lease 

sales are warranted, even if such analyses are, or 

will be, available in other NEPA documents. API 

recommends that BOEM consider adding this level of 

detail before the Multisale EIS is finalized in June 

2017 and before the Lease Sale 249.

BOEM appreciates the substantive content of this 

comment and has revisited the summary of G&G 

operations in Chapter 4.9.1 (Marine Mammals). 

This chapter has been revised to further clarify the 

potential impacts to marine mammal species that 

may result from G&G activities and the information 

that is currently available.

Further, an explanation of why BOEM would include 

the Atlantic OCS Proposed Geological and 

Geophysical Activities: Mid-Atlantic and South 

Atlantic Planning Areas, Final Programmatic 

Environmental Impact Statement by reference has 

been provided. 

Also, in regards to Comment API-38, BOEM has 

revised Chapter 4.9.1.2 to clarify that the 

referenced technical paper, “National Standards for 

a Protected Species Observer Program” (Baker 

et al., 2013) is not a regulatory document. 

Additional language has also been added 

throughout this chapter to consider the new 

information from a recent proposal to list the GOM 

American API-38 Section 4.9.1.2 (p. 4-241) The section describing Bryde's whale as endangered in this analysis. 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-117

Commenter Comment ID Comment Response

Petroleum 

Institute (API),

Andy Radford

potential impacts from G&G Activities is extremely 

brief. Several primary literature sources are 

referenced, but there is little to no summary of them. 

There is no real analysis of the mechanism of impact 

from G&G survey sounds or justification for why 

those impacts would results in negligible to moderate 

impacts. As BOEM has stated in public documents 

(i.e. August 2014 BOEM Science Note), “there is no 

documented scientific evidence of noise from air 

guns used in G&G seismic activities adversely 

affecting marine mammal populations or coastal 

communities.” References to additional information 

available in other NEPA documents are insufficient 

justification especially when that other document was 

prepared for Atlantic OCS planning areas. Also, this 

section references a technical paper “National 

Standards for a Protected Species Observer 

Program” (Baker et al. 2013) as if it has the force of 

regulation. This is not true as implementation of 

those standards in the form of regulations has not yet 

occurred. API recommends that BOEM make this 

clarification in the Final EIS and continues to 

document potential impacts, or lack thereof, in the 

final Multisale EIS and future GOM NEPA 

documents.

Other revisions to the text can be found throughout 

Chapter 4.9.1.2. 

American 

Petroleum 

Institute (API),

Andy Radford

API-32 The marine mammal population estimates provided 

in Table 4-14 are appropriately taken from the NMFS 

Stock Assessment Reports (Waring et al. 2014). 

Recently released habitat-based density and 

population estimates (Roberts et al. 2016) are not 

included in the table or in the following text 

describing individual species. Excluding them from 

the table is appropriate, although some discussion of 

those estimates would be appropriate to add to the 

text of the following section, especially for 

consistency with other BOEM NEPA and MMPA 

related documents currently in production or review. 

Along with the population estimates, the Potential 

BOEM appreciates the substantive content of this 

comment and has revisited Chapter 4.9.1 (Marine 

Mammals). This chapter has been revised to further 

clarify the use of NMFS’ Stock Assessment Reports 

(Waring et al., 2014) and potential biological 

removal (PBR) estimates to help determine how a 

proposed activity may impact a marine mammal 

stock. Further, this chapter has provided the 

impact-producing factors that are evaluated when 

calculating the PBR estimate of a marine mammal 

stock (including annual human-caused mortality and 

serious injury) and the role that PBR estimates may 

play in the management of marine mammal stocks. 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-118 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Biological Removal (PBR) estimates are provided 

and the calculation of PBR is described in the text. 

However, the PBR estimates are not referred to later 

in this section and it is unclear what the purpose of 

their inclusion is. The use of PBR for an effects 

analysis from offshore oil and gas activities is 

inconsistent with the purpose for which PBR is 

calculated (assessing impacts of mortalities from 

incidental fisheries takes). API recommends that 

BOEM clarify what the purpose is for including PBR 

estimates, as well as an explanation and justification 

for why NMFS Stock Assessment Reports were used 

versus habitat-based density and population 

estimates.

Because the mentioned study by Roberts et al. 

(2016) on habitat-based density and population 

estimates of marine mammals in the Gulf of Mexico 

has recently been finalized, BOEM has added some 

discussion of this study in its analysis of marine 

mammals in Chapter 4.9.1.1. 

American 

Petroleum 

Institute (API),

Andy Radford

API-33 The resultant expected impacts are described as 

ranges for marine mammals. For example, the 

expected impacts from transportation range from 

negligible to major. It is unclear why different 

subsections use different examples. Based on the 

examples provided, the impact level determination 

appears to be based primarily on the population 

estimate of the species concerned. However, using 

the three impacts above, it is unclear why two are 

ranked as Negligible to Major, whereas the other is 

ranked as Negligible to Moderate (Table 4-13, 

p. 4-227). There is insufficient justification for the 

upper level limit of Major for "Marine Trash and 

Debris" and "Transportation (vessel strikes)" impacts, 

while the upper level limit is moderate for 

"Decommissioning (explosive severance)" impacts. 

Any impact-producing factor that could result in 

serious injury or mortality could be classified as 

either major or moderate depending on the species 

involved. In the subsection on decommissioning 

(p. 4-246), the EIS further states: "Therefore, 

depending on the population estimate of any given 

species, explosive severance methods could have a 

major impact." So it is unclear why this factor was 

BOEM appreciates the substantive content of this 

comment and has revisited the requested impact 

determinations in Chapter 4.9.1 (Marine Mammals). 

Impact determinations have been given further 

clarification. Furthermore, the supporting protected 

species chapter (Chapter 4.9) has been revisited to 

clarify how impact-producing factors may affect a 

protected species differently, depending on its 

population size. Revisions to Chapter 4.9

(Protected Species) will apply to all protected 

species described in this Multisale EIS.
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-119

Commenter Comment ID Comment Response

given an upper limit impact level of moderate. The 

difference cannot be accounted for by mitigation 

because all three of these activities have regulated 

mitigations. Are the respective mitigations for vessel 

strikes (i.e., NTL 2012-JOINT-G01, Vessel Strike 

Avoidance and Injured/Dead Protected Species 

Reporting) and marine trash and debris (i.e., NTL 

2012-BSEE-G01, Marine Trash and Debris 

Awareness and Elimination) less effective than those 

for decommissioning (i.e., NTL 2010-BSEE-G05, 

Decommissioning Guidance for Wells and 

Platforms)? In all three cases, the EIS suggests that 

with mitigation "the reasonably foreseeable" impact 

would be Negligible. API recommends that BOEM 

consider our recommendations regarding clarification 

of certain aspects of the cumulative impacts analysis 

and “impact-producing factors”.

American 

Petroleum 

Institute (API),

Andy Radford

API-34 Thorough descriptions of the two ESA listed species 

(Sperm whale and West Indian manatee) are 

provided, but descriptions of the remaining 

19 species of marine mammals are grouped by 

taxonomic family and are very limited. At this high 

taxonomic level, only the most basic feeding habits 

and distributional information is provided. No 

information about what is known about current 

impacts from oil and gas activities in the GOM is 

presented, nor are the descriptions adequate to 

evaluate the likelihood of activities on future leases 

causing additional impacts. The subsequent text in 

this section does not provide any actual analysis of 

potential impacts to specific species and such 

information is not presented in the Impact Producing 

Factors section (3.1) either. While politically and 

practically convenient, using the U.S EEZ limits to 

define the southern extent of the NGOM (in terms of 

how populations and ranges are managed) is not 

functionally appropriate. Most of the species either 

travel to, or rely on seasonal resources from, other 

BOEM appreciates the substantive content of this 

comment and has revisited Chapter 4.9.1 (Marine 

Mammals). This chapter has been revised to clarify 

the limited amount of spatial information available 

for wide-ranging oceanic marine mammal stocks in 

the Gulf of Mexico region (including south of the 

U.S. Exclusive Economic Zone limits) and how the 

most credible peer-reviewed science was used to 

evaluate potential impacts from past, present, and 

reasonably foreseeable OCS energy-related 

activities to these marine mammal stocks. 

Additional language has also been added 

throughout Chapter 4.9.1 to consider the new 

information from a recent proposal to list the GOM 

Bryde's whale as endangered in this analysis.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-120 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

parts of the GOM.

American 

Petroleum 

Institute (API),

Andy Radford

API-35 When comparing potential impacts from the 

Alternatives, the first paragraph states that “While the 

WPA is a smaller area with less projected activity 

than is proposed for the CPA/EPA (refer to Chapter 

3), marine mammal species are widely distributed 

throughout the planning areas. As such, activities 

isolated to specific planning areas pose similar 

potential impacts to populations as do activities 

occurring in all planning areas. Therefore, because 

of the diversity and wide distribution of species in the 

Area of Interest, the level of impacts would be the 

same for Alternatives A, B, C, and D”. Even though 

marine mammal species are widely distributed and 

often highly mobile (especially deep-water species), 

because Alternatives B and C would exclude very 

large areas of the GOM from leasing it is hard to 

justify that potential impacts from those alternatives 

would be just as great as under Alternatives A or D. 

It seems only logical that impacts may be reduced if 

new leasing-related activities were not to occur over 

such large areas. This same argument is present in 

the first paragraph of section 4.9.1.2.1 on page 

4-265. API recommends that BOEM specifically 

provide further justification to support this conclusion 

and if the evidence exists to make the distinction 

between Alternatives. As stated in previous 

comments, API also recommends that BOEM 

provide additional clarity and explanations in more 

comprehensive form that shows potential impacts to 

all species in the GOM to provide clear linkages 

between findings and determination of impacts 

(individual and cumulative).

BOEM appreciates the substantive content of this 

comment and has revisited the alternatives 

discussion in Chapter 4.9.1 (Marine Mammals). 

Further clarification and justification has been added 

to explain how an impact-producing factor may 

potentially affect a marine mammal stock regardless 

of the geographic location of where the potential 

impact-producing factor may occur.

American 

Petroleum 

Institute (API),

Andy Radford

API-36 Section 4.9.1.1 – This section provides very specific 

examples of the different individual impact levels to 

marine mammals when discussing the various 

impact-producing factors. These are noted below by 

species. What is not clear is how these individual 

Thank you for your comment. BOEM has revised 

Chapter 4.9.1.1 to clarify and reference all 

information used for impact determinations and 

refers the reader to Chapter 4.9 (Protected 

Species) for further clarification on how population 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-121

Commenter Comment ID Comment Response

levels and factors are weighed in the level 

determinations and there is often not clear data or 

references provided to support the likelihood of such 

impacts occurring the GOM.

estimates are analyzed when making these 

determinations.

American 

Petroleum 

Institute (API),

Andy Radford

API-37 Table 4-14 (p. 4-229) – The table provides the “best 

available” population estimates for marine mammal 

species in the northern Gulf of Mexico. The source 

of these estimates is NMFS stock assessment 

reports (Waring et al. 2014). However, NMFS has 

stated the agency’s acceptance of the use of Roberts 

et al. (2016) habitat-based cetacean density models 

as the more recent and best estimates of population. 

Conflicting datasets could result in differences in 

agencies’ metrics (e.g., take estimates, PBR, etc.). 

Furthermore, discrepancies in the ranges of different 

population metrics could inadvertently inflate a 

qualitative impact level analysis if BOEM is 

considering a particular metric that may or may not 

be calculated using a different population estimate 

(e.g. Roberts et al. versus Waring et al.). The 

agencies’ need to agree on estimates of populations 

and stocks in order to adequately assess impact 

levels and factors that will lead to aligned decisionmaking and are mutually supported by the best 

available science.

BOEM appreciates the substantive content of this 

comment and has revisited Chapter 4.9.1.1. 

Because the mentioned study by Roberts et al. 

(2016) on habitat-based density and population 

estimates of marine mammals in the Gulf of Mexico 

has recently been finalized, BOEM has added some 

discussion of this study in its analysis of marine 

mammals in Chapter 4.9.1.1. Although BOEM 

analyzes the potential impacts of OCS oil- and gasrelated and non-OCS oil- and gas-related activities 

associated with a proposed lease sale and a 

proposed lease sale’s incremental contribution to 

the cumulative impacts to marine mammals, NMFS 

is responsible for managing marine mammal stocks 

in waters under U.S. jurisdiction under the MMPA.

American 

Petroleum 

Institute (API),

Andy Radford

API-39 Section 4.9.1.2 (p. 4-241) – “Marine mammals can 

become entangled in some types pf lines associated 

with G&G (Geological and Geophysical) activities.” 

References are needed.

Thank you for your comment. BOEM has revisited 

Chapter 4.9.1.2 to clarify all information leading to 

impact determinations and has cited supporting 

literature.

American 

Petroleum 

Institute (API),

Andy Radford

API-40 Section 4.9.1.2 (p. 4-241) – Transportation – The 

analysis of impact from Transportation, primarily the 

potential impacts from vessel strikes, includes very 

little GOM specific vessel-strike information except in 

the case of manatees and possibly sperm whale. 

The text references NTL 2012-JOINT-G01 which 

requires operators to report observations of injured or 

dead protected species. API recommends that 

BOEM summarize the results from these reports so 

Thank you for your recommendation. There are no 

reports of vessel strikes to marine mammals or sea 

turtles since the NTL was written. Therefore, there 

are no trends that would change the conclusions 

found in this Multisale EIS.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-122 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

the current level of impact from O&G activities could 

be understood and the relative impacts from future 

years placed into context.

American 

Petroleum 

Institute (API),

Andy Radford

API-41 Section 4.9.1.2 (p.4-241) Transportation cont. – The 

last two sentences of the first paragraph, which are: 

"Nowacek and Wells (2001) found that bottlenose 

dolphins had longer interbreath intervals during boat 

approaches compared with control periods (no boats 

present within 100 m [328 ft]) in a study conducted in 

Sarasota Bay, Florida. They also found that 

dolphins' decreased interanimal distance, changed 

heading, and increased swimming speed significantly 

more often in response to an approaching vessel 

than during control periods.” These are very specific 

statements that appear only peripherally related to 

the topic at hand. The implication seems to be that 

ship presence can cause behavioral reactions, but 

BOEM does not state this explicitly or explain why 

those statements are made. API recommends that 

BOEM clarify why these statements are included.

BOEM appreciates the substantive content of this 

comment and has revisited Chapter 4.9.1.2 to 

further clarify the results of the referenced study and 

its relevance to impact determinations.

American 

Petroleum 

Institute (API),

Andy Radford

API-42 Section 4.9.1 (p. 4-246) - "For example, if a group of 

pantropical spotted dolphins (population estimate of 

50,880 individuals) were not detected prior to a 

detonation and experienced physical injuries or 

mortalities, it would have a localized and irreversible 

impact on that group of individuals, but it would not 

diminish the continued viability of the population." 

BOEM needs to explicitly state what a group size is 

to support the conclusion stated. Again, this relates 

back to the mixed use of population estimates 

between agencies and the more important 

determination is the ratio between group and 

population that indicates the impact (or no impact) to 

the population.

BOEM appreciates the substantive content of this 

comment and has revisited the hypothetical 

example used in the “Decommissioning” section of 

Chapter 4.9.1.2. The hypothetical group of 

pantropical spotted dolphins was explicitly defined 

with a hypothetical number of individuals, and the 

relevance of this hypothetical example to impact 

determinations was clarified.

Please refer to the response for Comment API-37 

concerning the mixed use of population estimates 

between agencies.

American 

Petroleum 

Institute (API),

Andy Radford

API-43 Section 4.9.1 (p. 4-229 Table 4-14) – West Indian 

Manatee (Population Estimate - 6063, PBR – 

Undetermined). How was this NGOM population 

estimate of 6,063 derived – does it include animals 

Thank you for your comment. BOEM has revisited 

Table 4-14 in Chapter 4.9.1 and has added the 

source of the West Indian manatee population 

estimate and has described the spatial and temporal 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-123

Commenter Comment ID Comment Response

that live on the East coast of Florida? It is not clear 

in this document. API recommends that BOEM 

include in-text references to clarify the sources for 

the estimates.

bounds of this estimate.

American 

Petroleum 

Institute (API),

Andy Radford

API-44 Section 4.9.1 (p. 4-236) – Description of Sirenia. For 

practical purposes, this species should be divided 

into the two sub-species; Florida manatee and 

Antillean manatee. The cooler NGOM winters are 

considered a barrier contributing to the genetic 

isolation between these two populations (USFWS).

BOEM appreciates this comment and has revisited 

Chapter 4.9.1. This chapter has been revised to 

distinguish the two subspecies of West Indian 

manatee and their spatial distribution.

American 

Petroleum 

Institute (API),

Andy Radford

API-45 Section 4.9.1.1 (p. 4-231)– “The NMFS considers 

sperm whales in the GOM as a distinct stock in the 

Marine Mammal Stock Assessment Report (Waring 

et al. 2014), and research supports this distinction 

from the Atlantic and Caribbean stocks...” The 

NGOM sperm whale population is not an isolated 

genetic stock. While not a common occurrence, 

there is some evidence that adult male NGOM sperm 

whales travel seasonally through the Florida straits 

into the NW Atlantic Ocean. One adult male travelled 

to the North Atlantic and then back into the Gulf after 

about two months. From Engelhaupt et al. (2009) in 

NOAA 2012, it states that “[a]nalysis of biparentally 

inherited nuclear DNA showed no significant 

difference between whales sampled in the Gulf and 

those from the other areas of the North Atlantic, 

indicating that mature males move in and out of the 

Gulf.” It is also documented that the spatial 

distribution of GOM sperm whales is correlated with 

mesoscale oceanic physical circulation features 

(Biggs et al. 2005). Features include Loop Current 

and its eddies, which can locally increase primary 

production and prey availability. While the Loop 

Current exhibits long-term circulation trend, it also 

exhibits significant yearly interannual seasonal 

variability in the number of eddies shed (Chang and 

Oey, 2012 and Hall, 2012) and the movement and 

persistence of those eddies moving westward across 

BOEM appreciates the substantive content of this 

comment and has revisited Chapter 4.9.1.1. This 

chapter has been revised to clarify why NMFS 

considers sperm whales in the Gulf of Mexico a 

distinct stock and the movement of sperm whales in 

regards to the impact-range levels and potential 

impacts that broad movement might have, or lack 

thereof, on determining impacts from OCS oil- and 

gas-related and non-OCS oil- and gas-related 

activities, including, but not limited to, ship strikes 

(documented by NOAA’s Office of Protected 

Resources species’ website [Waring et al., 2016]) 

and physical oceanographic circulation features.

While the specific references cited in this comment 

may not have been used in this analysis, BOEM has 

considered that hydrographic features (e.g., the 

Loop Current and eddies) may impact movement 

patterns of sperm whales inhabiting Gulf of Mexico 

waters in its analysis. “Seasonal aerial surveys 

confirmed that sperm whales sightings are more 

common during summer (Mullin et al., 1991 and 

1994a; Mullin and Hoggard, 2000; Mullin and 

Fulling, 2004), but this may be an artifact of 

movement patterns of sperm whales associated 

with reproductive behavior, hydrographic features, 

or other environmental or seasonal factors.”
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-124 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

the central to western GOM OCS and shelf (Sturges 

and Leben, 2000). Loop Current and its eddies are a 

natural mechanism that could naturally change 

sperm whale distribution, which is not included as an 

additional non-oil and gas factor. API recommends 

that BOEM consider the movement of sperm whales 

in the final GOM Multisale EIS and document 

movement in regards to the impact range levels and 

potential impacts that broad movement might have, 

or lack thereof, on determining impacts from oil and 

gas and non-oil and gas factors, including, but not 

limited to, ship strikes (documented by NOAA Office 

of Protected Resources species webpage) and 

physical oceanographic circulation features.

BOEM has also considered that site fidelity, as well 

as habitat use, differs among male and female 

sperm whales in its analysis. “Females and 

juveniles form pods that are found mainly at tropical 

and temperate latitudes (between 50°N. and 50°S. 

latitude), while the solitary adult males can be found 

at higher latitudes (between 75°N. and 75°S. 

latitude) (Reeves and Whitehead, 1997).” “Sperm 

whales are present year-round in the GOM, with 

females generally having significant site fidelity and 

with males and females exhibiting significant 

differences in habitat usage (Jochens et al., 2008).”

American 

Petroleum 

Institute (API),

Andy Radford

API-46 Section 4.9.1.2 (p. 4-242) – Vessel Strikes are 

mentioned multiple times throughout this document 

as a source for human-activity related mortality. 

Aside from manatee collisions with vessels in coastal 

regions, are marine mammal-vessel interactions an 

issue for the offshore NGOM regions? Collisions 

with vessels are a main cause of North Atlantic right 

whale mortality but North Atlantic right whales are not 

considered as a NGOM species in this report. As 

previously mentioned in regards to sperm whales, 

API recommends that BOEM include citations from 

known ship strike mortality of cetaceans in the GOM.

BOEM appreciates the substantive content of this 

comment and has revisited Chapter 4.9.1.2. The 

chapter has been revised to include information 

related to vessel strikes of marine mammals in the 

Gulf of Mexico.

Sea Turtles

American 

Petroleum 

Institute (API),

Andy Radford

API-47 Section 4.9.2.1 (p. 4-268) – “Loggerhead turtles have 

been primarily sighted in waters over the continental 

shelf although many surface sightings of this species 

have also been made over the outer slope beyond 

the 1000-m isobaths” and Section 4.9.2.1 Page 4-

269 – “Subadult and adult loggerheads are primarily 

coastal...” These two statements appear to be in 

disagreement. Is it the very young turtles that are 

sighted over the OCS and beyond? What is the 

definition of “coastal” here? API recommends that 

BOEM include a definition of “coastal” in the context 

Thank you for your comment. The first sentence 

refers to loggerhead sea turtles in general. The 

second sentence refers to the subadult and adult 

age classes. The habitat for juvenile turtles is 

described as follows: “Developmental habitat for 

small juveniles is in the open ocean. Offshore, they 

reside for months in the oceanic zone in Sargassum 

floats, generally along the Loop Current and the 

west coast of Florida.”
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-125

Commenter Comment ID Comment Response

to the discussion noted here. We further suggest 

that the definition of “coastal” be written in the 

context of water depth and region designations 

throughout the Multisale EIS and DPEIS to maintain 

consistency in terminology.

American 

Petroleum 

Institute (API),

Andy Radford

API-48 Section 4.9.2.1 p. 4-271) – “In the GOM, 

juvenile/subadult Kemp’s Ridleys occupy shallow, 

coastal regions.” API recommends that BOEM 

include references to this statement.

Thank you for your comment. This reference is 

included in the previous paragraph: “Ogren (1989) 

suggests that the Gulf Coast, from Port Aransas, 

Texas, through Cedar Key, Florida, represents the 

primary habitat for subadult Kemp’s ridleys in the 

northern GOM. Juvenile/subadult Kemp's ridleys 

have been found along the Eastern Seaboard of the 

U.S. (Epperly et al., 2007) and in the GOM.” 

Changes have been made to the text to clarify the 

language and references.

American 

Petroleum 

Institute (API),

Andy Radford

API-49 Section 4.9.2.1 (p. 4-272) – “Green sea turtle mating 

occurs in the waters off the nesting beaches. Each 

female deposits 1-7 clutches (usually 2-3) during the 

breeding season at 12- to 14-day intervals. Mean 

clutch size is highly variable among populations but 

averages about 110 eggs.” Is the above information 

attributed to Balazs 1983? If so, API recommends 

that BOEM it needs to be properly cited in the text 

and clarify exactly what the reference, if not from 

Balazs 1983 refers to. The Balazs reference 

represents life history data for the Hawaiian Islands 

Region – not the NGOM. Further, Balazs 1983 is 

dated and does not represent current conditions.

Thank you for your comment. This Final Multisale 

EIS has been updated to include referenced 

material for the Gulf of Mexico from Hart et al. 

(2013).

American 

Petroleum 

Institute (API),

Andy Radford

API-50 It would be better for BOEM to refer to Hart et al 

2013 for green turtles in the Dry Tortugas (Southern 

GOM), which states that, “The nesting season for 

green sea turtles lasts throughout the summer but is 

most concentrated in June and July. During nesting 

season, females nest at roughly 2-week intervals, 

producing an average of five nests or “clutches.” 

Each clutch contains an average of 135 eggs, which 

will hatch after incubating for about 2 months

Thank you for your comment. Hart et al. (2013) has 

been included in this Final Multisale EIS regarding 

green sea turtles in the Gulf of Mexico as it contains 

current and relevant information since the Dry 

Tortugas is considered to be in the northern Gulf of 

Mexico.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-126 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

American 

Petroleum 

Institute (API),

Andy Radford

API-51 Section 4.9.2.1 (p. 4-276) – “Schwartz (1988) 

reported numerous loggerhead hatchling during 

commercial trawling for Sargassum in the Atlantic.” 

Are there any NGOM relevant references for this 

distribution? Or does this imply that the same green 

turtle hatchlings found offshore in the Atlantic Ocean 

are also found at later stages in the NGOM – this is 

important to know and API recommends that BOEM 

make this clear in the final EIS.

Thank you for your comment. The referenced study 

was used to show the association of turtles with 

Sargassum. Please refer to the following sentence 

as stated in the Multisale EIS: “Witherington et al. 

(2012) conducted a study on juvenile turtle use of 

Sargassum habitats and further supported that 

these drifting communities are important areas for 

young sea turtles (84% of 1,884 turtles were 

observed within 1 m [3 ft] of floating Sargassum).” 

This reference is related to a study conducted along 

the eastern and Gulf Coasts of Florida, and it further 

shows the link between sea turtles and floating 

Sargassum.

American 

Petroleum 

Institute (API),

Andy Radford

API-52 Section 4.9.2.2 (p. 4-278) – “Stranding data for the 

U.S. Gulf and Atlantic Coasts, Puerto Rico, and the 

U.S Virgin Islands show that, between 1986 and 

1993, about 9 percent of living and dead stranded 

sea turtles had boat strike injuries (Lutcavage et al. 

1997 ). Given the limitations of the baseline 

ecological data, it is important to discern the differing 

levels of threats in the difference environments – API 

recommends that BOEM review NGOM-only records 

and better clarify the potential non-oil and gas 

impacts that could be threats to sea turtles.

Thank you for your comment. BOEM only used the 

Gulf of Mexico information from the stranding data. 

The non-OCS oil- and gas-related impacts are 

discussed in the “Description of the Affected 

Environment” chapter for each species and in the 

“Non-OCS Oil- and Gas-Related Impacts” section in 

the “Cumulative Impacts” chapter for sea turtles 

(i.e., Chapter 4.9.2).

American 

Petroleum 

Institute (API),

Andy Radford

API-53 Section 4.9.2.2 (p. 4-279) –Transportation - “Given 

the scope, timing, and transitory nature of a 

proposed action and with this established mitigation, 

the impacts to sea turtles from vessel collisions are 

expected to be negligible; however, if the collisions 

occur, impacts could be moderate.” This statement 

is confusing. API recommends that BOEM clarify by 

answering the following questions:, How many 

collisions would constitute a moderate impact? A 

moderate impact to which species? Moderate in 

terms of the damage to a particular animal or 

population? – The DEIS describes the expected low 

risk of vessel-turtle collision and a history of no 

recorded vessel-turtle collisions in the GOM; but the

Thank you for your comment. The impact criteria 

are defined in Chapter 4.9 (Protected Species). 

The impact from vessel collisions are expected to 

be negligible since vessel collisions are not likely to 

occur due to established mitigation. The impact 

would be moderate if any sea turtle sustains impact 

from a vessel collision due to the endangered or 

threatened status of each species of sea turtles in 

the GOM.
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-127

Commenter Comment ID Comment Response

degree of risk is lost in the impact analysis.

Infrastructure

United States 

Environmental 

Protection 

Agency

USEPA-6 On page 3-4, the DEIS states pipeline capacities are 

unknown. On pages 3-38 and 3-42, it

identifies a mature pipeline network exists in the 

GOM to transport oil and gas production from the 

OCS to shore, and projects that the majority of new 

pipelines would connect to the existing pipeline 

infrastructure. Additionally, on page 3-35, the DEIS 

projects that the number of pipeline removals or 

relocations would increase region-wide as the 

existing pipeline infrastructure ages.

EPA recommends the EIS incorporate specifics on 

the age, condition, and likely need to replace or 

rebuild these existing pipelines due to the increased

activity from the proposed action and the assessment 

of negligible impact.

Please refer to Chapter 3.1.3.3.1 for more 

information on pipelines and Chapter 3.1.6.1 for 

information on pipeline age. The typical life span of 

a pipeline has been estimated to be 20-40 years, 

but with current preventative measures, including 

using corrosion resistant or corrosion-inert 

materials, that lifetime has been substantially 

increased. Pipeline routes are inspected at time 

intervals and methods prescribed by BSEE’s 

Regional Supervisor of Field Operations. When 

pipelines are protected by rectifiers or anodes for 

which the initial cathodic protection system either 

cannot be calculated or calculations indicate a life 

expectancy of less than 20 years, the pipelines are 

inspected annually (30 CFR § 250.1005(b)). As 

platforms and sections of pipelines are 

decommissioned, additional pipeline may be 

installed to reroute transport to shore. Occasionally, 

pipeline segments may require replacement, 

especially on risers near the surface where 

corrosion potential is the highest. As new platforms 

are built on new leases, pipelines are forecasted to 

be built to attach these new production structures to 

the existing matrix of pipelines. While the current 

capacity of pipelines can be calculated, the future 

capacity cannot be forecasted as it will depend on 

the size and location of the reservoirs discovered. If 

the current matrix of pipelines has the capacity to 

transport oil from new leases, BOEM expects 

industry would choose to tie into the existing matrix.

United States 

Environmental 

Protection 

Agency

USEPA-12 The DEIS discusses the proposed action's OCS and 

non-OCS oil- and gas-related construction and 

operations.

Recommendation:

Environmental issues associated with offshore oil 

and gas operations in Federal waters are governed 

by BSEE’s regulations at 30 CFR § 250.107; Safety 

and Environmental Management Systems’ (SEMS) 

regulations at 30 CFR § 250.1910; and the NPDES 

at 40 CFR part 122. Offshore oil and gas 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-128 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

EPA recommends the FEIS identify projected solid 

and hazardous waste types and volumes, and 

expected storage, disposal, and management plans, 

and appropriate mitigation to minimize the generation 

of hazardous waste (i.e., hazardous waste

minimization).

operations are specifically excluded from regulation 

under the Resource Conservation and Recovery Act 

(USEPA, Office of Solid Waste, 2002). Generally, 

however, oil and gas wastes are not considered 

hazardous.

Produced water, the largest waste stream from 

offshore oil and gas operations, may be discharged 

to the ocean in accordance with USEPA Regions 4 

and 6 NPDES permits. Spent chemicals used in 

well treatment, completion, and workover (WTCW) 

fluids may be commingled and discharged with 

produced water. Therefore, these waste streams 

are discharged to the ocean, and a management 

plan or waste minimization is not required as would 

be performed under the Resource Conservation and 

Recovery Act.

Solid wastes such as trash/debris, used oil, 

washwater, and other chemical product wastes are 

taken to shore for disposal or recycling. Onshore 

disposal/recycling of these wastes are usually 

included in the EP and DOCD in Table 2: Waste 

and Surplus Estimated to be Transported and/or 

Disposed of Onshore.” Please refer to the second 

link at http://www.boem.gov/Water-QualitySpreadsheets/. Waste going to shore is not 

considered hazardous; therefore, the material is 

transported under a Bill of Lading.

Additionally, NTL 2015-BSEE-G03, “Marine Trash 

and Debris Awareness and Elimination,” presents 

BSEE’s policy regarding marine debris prevention.

“The discharge of garbage and debris has been the 

subject of strict laws, such as MARPOL-Annex V 

and the Marine Debris Act, 33 U.S.C. 1951 et seq., 

and regulations imposed by various agencies 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-129

Commenter Comment ID Comment Response

including the United States Coast Guard and the 

Environmental Protection Agency. Since oil and 

gas operations in the Gulf of Mexico may contribute 

to this problem, 30 CFR 250.300(a) and (b)(6) 

prohibit you from discharging containers and other 

materials into the marine environment, and 30 CFR 

250.300(c) and (d) require you to make durable 

identification markings on skid-mounted equipment, 

portable containers, spools or reels, and drums, and 

to record and report such items when lost overboard 

to the District Manager through facility daily 

operations reports.”

Please refer to Chapter 3.1.5 for more information.

United States 

Environmental 

Protection 

Agency

USEPA-14 In Table 1 Alternative Comparison Matrix, land use 

and coastal infrastructure impacts are identified as 

major for all Alternatives. In Section 3.1.7 Coastal 

Infrastructure, the DEIS describes the potential need 

for new facility construction and for expansions at 

existing facilities, and transportation services 

involving both onshore and offshore activities. On

page 4-378 and 4-379, it discusses that railways and 

major interstates are critical to the success of service 

bases and port facilities. It is unclear the extent and 

magnitude of transportation and traffic impacts.

Recommendation:

EPA recommends the FEIS clarify transportation and 

traffic impacts and identify any committed mitigation.

Table 1 in the Executive Summary and Table 2-2

(Alternative Comparison Matrix) has been updated 

to more clearly convey the expected incremental 

contribution from a proposed action to the overall 

cumulative effects to land use and coastal 

infrastructure. Lease sales would serve mostly to 

maintain ongoing activity levels associated with the 

2012-2017 Five-Year Program. Industry would 

more or less maintain its current usage of 

infrastructure. Only after several cancelled lease 

sales (or where there is limited leasing) would we 

expect to see a noticeable difference in activities.

Additional references and clarifying language has 

been added to Chapter 4 to better address 

transportation and traffic impacts. However, BOEM 

does not have the authority to require mitigations for 

onshore transportation. That would fall under the 

U.S. Department of Transportation and the Statelevel Departments of Transportation.

Socioeconomics

State of 

Louisiana 

LADNR-1 Though there has been some gradual improvement 

over the years in the attention paid to Louisiana’s 

Thank you for your comment. BOEM continually 

attempts to improve its model predictions, and 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-130 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Department of 

Natural 

Resources

(LADNR),

Don Haydel,

Acting 

Administrator

Interagency 

Affairs/Field

concerns, this DEIS again falls short in that there is 

inadequate effort made to confirm that model 

predictions used in the environmental and 

socioeconomic analyses, are reliable indicators of 

actual outcomes.

comparing historical predictions to realized 

outcomes is an important method for doing so. 

BOEM’s model predictions generally consist of 

(1) scenarios for oil and gas exploration, 

development, and production and (2) predictions of 

outcomes (such as economic variables and oil 

spills) that are based on those scenarios. Both of 

these components attempt to incorporate analyses 

of the historical accuracy of predictions, although 

BOEM will examine whether improvements can be 

made. However, there are limits to this approach 

given the limits of the available data and the fact 

that the oil and gas industry continually evolves.

OffshoreAlaba

ma.com, 

Steve Russell

OAL-1 Opening up new areas for exploration will create 

hundreds of local jobs at a time when Mobile 

County's unemployment rate is 7.0 % (March 2016). 

Continuing with this process of not delaying, 

restricting or prohibiting the 2017-2022 Gulf of 

Mexico lease sales will have 2 major benefits for 

Mobile County: First, expend capital investment and 

capital investment means more county and state 

sales and property taxes and school taxes on 

equipment and machinery; Secondly, put hundreds 

of local people to work boosting household incomes: 

we know through surveys that the average annual 

wage for oil & gas workers in Mobile County exceeds 

$60,000, significantly higher than the $42,097

(October 2015, ADOL) average annual earnings in 

Mobile County. Higher paying jobs means more 

taxes and it also means that their families spend 

more money in the community on all kind of goods 

and services, benefiting even more people and 

putting money in their pockets. Finalizing a multisale 

EIS that allows Gulf lease sales to proceed without 

any further exclusions or restrictions is important to 

sustaining the health of the Mobile economy.

Thank you for your comment. BOEM appreciates 

the detailed information in your comment and 

acknowledges the importance of the direct, indirect, 

and induced impacts of OCS oil- and gas-related 

activities on the coastal economies. Additional 

emphasis language has been added to the social 

factors chapter to underline this importance to 

coastal communities. BOEM analyzes the 

beneficial economic impacts of the alternatives in 

Chapter 4.14.2. 

Consumer 

Energy 

CEA-1 Make no mistake; the Gulf of Mexico is an energy 

powerhouse for Texas, the Gulf Coast region, and 

Thank you for your comment. BOEM presents data 

regarding the beneficial impacts of the alternatives 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-131

Commenter Comment ID Comment Response

Alliance

(CEA),

Brent 

Greenfield

the entire country, supplying nearly 20% of the 

nation's crude oil. It is also an economic 

powerhouse. In FY 2014 alone, Gulf of Mexico oil 

and gas activity supported 651,000 jobs, generated 

over $64 billion in Gross Domestic Product and 

provided over $7 billion in revenue to the federal 

government.

in Chapter 4.14.2.

Consumer 

Energy 

Alliance

(CEA),

Brent 

Greenfield

CEA-2 Contrary to assertions by a small but vocal group of 

anti-energy groups, we can protect our environment 

AND meet our energy needs. As but one example, 

CEA notes the draft EIS recognition of this reality in 

its conclusion that Gulf lease sale activity would 

include beneficial impacts for commercial and 

recreational fishing and recreational resources.

Thank you for your comment.

Cyrus Reed CR-3 I recognize that the EIS does talk about the role of 

tourism, fishing, and other recreational uses of the 

ocean, but I am not sure it's fully valued in the way 

that it should be, again, as an alternative kind of use 

of the ocean, along with oil and gas leasing.

Thank you for your comment. BOEM discusses the 

potential conflicts (along with the positive 

interactions) of OCS oil- and gas-related activities 

with tourism, fishing, and recreational uses in 

Chapters 4.10, 4.11, and 4.12.

Rachel Walsh RW-3 I also feel that the Bureau of Ocean Management 

fails to consider the alternative values and uses that 

the Gulf of Mexico provides such as the significant 

values it provides to the tourism and fishing 

industries, and I feel these would be greatly 

depreciated by oil and gas drilling, further oil and gas 

drilling in the Gulf of Mexico.

Thank you for your comment. BOEM analyzes the 

impacts of oil and gas production on a number of 

important habitats, resources, and socioeconomic 

entities. For specific information on commercial 

fisheries, recreational fishing, and tourism, refer to 

Chapters 4.10, 4.11, and 4.12, respectively.

Environmental Justice

Center for 

Biological 

Diversity, Bold 

Louisiana, 

Gulf 

Restoration 

Network, 

Louisiana 

Bucket 

Brigade, 

CBD, BL, GRN, 

LBB, RAHC-13

BOEM Failed to Adequately Consider Environmental 

Justice Issues and Failed to Quantify the Social and 

Environmental Costs of its Proposal: BOEM’s 

proposal raises significant environmental justice 

issues. But BOEM’s Draft EIS fails to adequately 

address these significant impacts, or adequately 

analyze the social and environmental costs of its 

proposal. As BOEM is well aware, on February 11, 

1994, President Clinton issued Executive Order 

12898, “Federal Actions to Address Environmental 

BOEM appreciates the extensive detail in this 

comment, acknowledges that some additional 

detail/clarification could improve this Multisale EIS, 

and has taken steps to address each component of 

the comment with the following revisions to the 

social factors chapter: 

• additions to the description of BOEM’s 

outreach efforts to help expand participation 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-132 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Radical Arts 

and Healing 

Collective

(CBD, BL, 

GRN, LBB, 

RAHC), 

Kristen 

Monsell, 

Staff Attorney

Justice in Minority Populations and Low Income 

Populations.” The Executive Order makes it the 

responsibility of each Federal agency to “make 

achieving environmental justice part of its mission in 

identify and addressing, as appropriate, 

disproportionately high and adverse human health or 

environmental effects of its programs, policies, and 

activities on minority populations and low-income 

populations.” Accompanying this order was a 

Presidential Memorandum stating that “each Federal 

agency shall analyze the environmental effects, 

including human health, economic and social effects, 

of Federal actions, including effects on minority 

communities and low-income communities, when 

such analysis is required by [NEPA].” The CEQ has 

also issued guidance on incorporating environmental 

justice considerations in the NEPA process. The 

guidance states in part: Early and meaningful public 

participation in the federal agency decision making 

process is a paramount goal of NEPA. CEQ’s 

regulations require agencies to make diligent efforts 

to involve the public throughout the NEPA process. 

Participation of low-income populations, minority 

populations, or tribal populations may require 

adaptive or innovative approaches to overcome 

linguistic, institutional, cultural, economic, historical, 

or other potential barriers to effective participation in 

the decision-making processes of Federal agencies 

under customary NEPA procedures. States 

bordering the Gulf of Mexico are home to a variety of 

onshore oil and gas infrastructure that support 

offshore oil and gas drilling activities, including oil 

refineries. Toxic pollution from these refineries and 

petrochemical facilities disproportionately impact low 

income neighborhoods and communities of color. 

For example, Port Arthur, Texas is home to two 

facilities that refine more than 900,000 barrels of 

crude per day. The Environmental Protection 

by environmental justice populations;

• further clarification as to the status of 

refineries and other processing facilities in 

relation to the proposed action (while 

acknowledging BOEM has no regulatory 

authority over them) and additional 

information in the cumulative analysis as to 

potential negative impacts to coastal 

communities;

• additional language in the cumulative 

analysis regarding hurricanes, coastal land 

loss, sea-level rise; and

• further clarification in the cumulative impacts 

chapter regarding the incremental impact of a 

single proposed lease sale.

Additional quantification of impacts is included 

where available. BOEM is currently reviewing the 

extent to which it is feasible and appropriate to 

quantify the impacts of climate change. This review 

will consider various factors, such as the 

uncertainties inherent in such analyses.

BOEM describes the impacts of onshore facilities or 

activities that contribute to air pollution in coastal 

communities as a part of the cumulative impacts 

analysis in Chapter 4.14.3 (Social Factors). 

However, BOEM does not have authority to regulate 

any onshore facilities or activities that contribute to 

air pollution. For an analysis of the impacts to air 

quality, refer to Chapter 4.1. 

Chapter 4.14.3.2.2 acknowledges that, if an 

accidental event affects more than one county or 

parish and is measurable with impacts lasting up to 

1 year, then the impact would be moderate. The 

potential impacts as a result of a low-probability 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-133

Commenter Comment ID Comment Response

Agency’s Toxics Release Inventory places Jefferson 

County, where Port Arthur is located, among the 

worst in the nation for emissions of chemicals known 

to cause cancer, birth defects, and reproductive 

disorders. Data collected by the Texas Cancer 

Registry indicates that cancer rates among African 

Americans in Jefferson County are roughly 15% 

higher than they are for the average Texan, and the 

mortality rate from cancer is more than 40% higher. 

Moreover, many of these communities are also on 

the frontlines of climate change, with severe storms 

like Hurricane Katrina displacing people. And, as 

explained above, coastal areas in Louisiana are 

eroding at the rate of a football field an hour, 

meaning the area is losing important buffers to the 

impacts of hurricanes, meaning that the impacts of 

such storms on frontline communities are only going 

to intensify in the future. Additionally, scientists say 

that at current rates, coastal erosion and sea level 

rise will lead to nearly all of Southeast Louisiana 

being under water by 2100, leading to the 

displacement of even more communities. BOEM’s 

proposal will exacerbate all these impacts by leading 

to more oil drilling, which will lead to more oil refining, 

toxic air pollution and greenhouse gas emissions. 

While BOEM quantifies the purported economic 

benefits of its proposal, such as job creation and 

value added impacts, BOEM wholly fails to quantify 

the negative impacts that would result, such as the 

quantity of air pollutants from refining and consuming 

the oil and gas to be extracted and the attendant 

societal and environmental costs of such emissions. 

This is despite BOEM’s prior quantification of harm 

caused by air emissions from oil and gas activities 

represented by dollars per ton for certain pollutants, 

and a readily available tool to analyze the costs of 

the greenhouse gas emissions generated by BOEM’s 

proposal—the social cost of carbon. The social cost 

catastrophic event like the Deepwater Horizon oil 

spill, however, are not part of a proposed action and 

are not likely expected to occur. New regulations 

focusing on improved safety, more regulatory 

checks, and inspections should decrease the 

already small likelihood of the occurrence of such 

spills. Potential impacts as a result of a lowprobability catastrophic event are discussed in the 

Catastrophic Spill Event Analysis white paper 

(USDOI, BOEM, 2017).

BOEM recognizes the importance of climate change 

in its NEPA analyses and considers many facets of 

the potential effects of climate change in its 

decisionmaking with respect to oil and gas leasing, 

whether in the Five-Year Program or lease sale 

analyses. This Multisale EIS tiers from the FiveYear Program EIS and has included a summary of 

the greenhouse gas and downstream emissions 

information that may result from a Gulf of Mexico oil 

and gas lease sale in Chapter 4.0. BOEM 

acknowledges that methods for quantifying 

greenhouse gas and potential social costs of such 

emissions remains the subject of debate. A number 

of key uncertainties are outlined in BOEM’s analysis 

and, as a result, the current estimates should be 

treated as provisional because they will evolve with 

improved scientific and economic understanding. 

BOEM continues to consider different ways to 

quantitatively address and disclose downstream 

greenhouse gas emissions and effects in 

accordance with CEQs recent directives.
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-134 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

of carbon was developed by the Interagency Working 

Group on Social Cost of Carbon, which was 

convened by the Council of Economic Advisers and 

the Office of Management and Budget. As explained 

in the Working Group’s report: The purpose of the 

“social cost of carbon” (SCC) estimates presented 

here is to allow agencies to incorporate the social 

benefits of reducing carbon dioxide (CO2) emissions 

into cost-benefit analyses of regulatory actions that 

impact cumulative global emissions. The SCC is an 

estimate of the monetized damages associated with 

an incremental increase in carbon emissions in a 

given year. It is intended to include (but is not limited 

to) changes in net agricultural productivity, human 

health, property damages from increased flood risk, 

and the value of ecosystem services due to climate 

change. The working group presents values for 

social costs from 2015 to 2050, ranging from $11 to 

$212 (in 2007 dollars per metric ton of CO2). The 

SCC demonstrates that the benefits of reducing 

carbon pollution are significant. For example, the 

proposed rules for reducing power plant carbon 

emissions calculated the climate benefits and health 

co-benefits to be $15.6 to $88 billion in 2020 and 

32.3 to $151 billion in 2030. However, recent studies 

have demonstrated that the numeric value assigned 

to the social cost of carbon vastly underestimates the 

true cost. The social cost of carbon is therefore a 

minimum value. Other analytical tools exist to 

evaluate the cost of methane emissions. The 

Environmental Protection Agency has peer-reviewed 

and employed such a tool in its “Regulatory Impact 

Analysis of the Proposed Emission Standards for 

New and Modified Sources in the Oil and Natural 

Gas Sector.” BOEM’s quantification of the purported 

economic benefits of its proposal while assigning 

zero value to the social and environmental costs is 

both disingenuous and unlawful under NEPA. 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-135

Commenter Comment ID Comment Response

Moreover, its failure to adequately describe and 

quantify these negative impacts does not comply with 

its duty to disclose the environmental justice 

implications. BOEM’s analysis of the cumulative 

impacts of its proposal on environmental justice 

communities is inadequate for the same reason. 

Indeed, BOEM seems to dismiss the import of the 

additional air pollution that could result from its 

proposal on Gulf communities because there is 

already significant OCS-related infrastructure in the 

Gulf states. This approach undercuts the entire 

purpose of a cumulative impacts analysis and efforts 

to inform and engage environmental justice 

communities.

Sierra Club,

Devorah 

Ancel, 

Staff Attorney

SC-12 BOEM Failed to Adequately Consider Environmental 

Justice Issues and Failed to Quantify the Social and 

Environmental Costs of its Proposal: BOEM’s 

proposal raises significant environmental justice 

issues. But BOEM fails to adequately address these 

significant impacts, or adequately analyze the social 

and environmental costs of continuing oil and gas 

development contemplated under the proposed lease 

sales. As BOEM is well aware, on February 11, 

1994, President Clinton issued Executive Order 

12898, “Federal Actions to Address Environmental 

Justice in Minority Populations and Low Income 

Populations.” The Executive Order makes it the 

responsibility of each federal agency to “make 

achieving environmental justice part of its mission in 

identifying and addressing, as appropriate, 

disproportionately high and adverse human health or 

environmental effects of its programs, policies, and

activities on minority populations and low-income 

populations.” Accompanying this order was a 

Presidential Memorandum stating that “each Federal 

agency shall analyze the environmental effects, 

including human health, economic and social effects, 

of Federal actions, including effects on minority 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-136 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

communities and low-income communities, when 

such analysis is required by [NEPA].” States 

bordering the Gulf of Mexico are home to a variety of 

onshore oil and gas infrastructure that support 

offshore oil and gas drilling activities, including oil 

refineries. Toxic pollution from these refineries and 

petrochemical facilities disproportionately impact low-

income neighborhoods and communities of color. 

Moreover, many of these communities are at ground 

zero for the impacts of climate change, with sea level 

rise and wetlands loss already some of the earliest 

climate migration in the U.S. Scientists estimate that, 

if current rates of coastal wetlands loss and sea level 

rise continue, nearly all of southeast Louisiana will be 

under water by 2100, leading to the displacement of 

even more communities. The proposed lease sales, 

or any option that supports the continuing sale of 

leases in federal waters, will exacerbate all these 

impacts by leading to more oil drilling, which will lead 

to more oil refining, toxic air pollution and 

greenhouse gas emissions. While BOEM quantifies 

the purported economic benefits of its proposal, such 

as job creation and value added impacts, BOEM 

wholly fails to quantify the negative impacts that 

would result, such as the quantity of air pollutants 

from refining and consuming the oil and gas to be 

extracted and the attendant societal and 

environmental costs of such emissions. This is 

despite BOEM’s prior quantification of harm caused 

by air emissions from oil and gas activities 

represented by dollars per ton for certain pollutants, 

and a readily available tool to analyze the costs of 

the greenhouse gas emissions generated by BOEM’s 

proposal—the social cost of carbon. The social cost 

of carbon was developed by the Interagency Working 

Group on Social Cost of Carbon, which was 

convened by the Council of Economic Advisers and 

the Office of Management and Budget. As explained 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-137

Commenter Comment ID Comment Response

in the Working Group’s (hereinafter Working Group) 

report: The purpose of the “social cost of carbon” 

(SCC) estimates presented here is to allow agencies 

to incorporate the social benefits of reducing carbon 

dioxide (CO2) emissions into cost-benefit analyses of 

regulatory actions that impact cumulative global 

emissions. The SCC is an estimate of the monetized 

damages associated with an incremental increase in 

carbon emissions in a given year. It is intended to 

include (but is not limited to) changes in net 

agricultural productivity, human health, property 

damages from increased flood risk, and the value of 

ecosystem services due to climate change. The 

Working Group presents values for social costs from 

2015 to 2050, ranging from $11 to $212 (in 2007 

dollars per metric ton of CO2). The SCC 

demonstrates that the benefits of reducing carbon 

pollution are significant. However, recent studies 

have demonstrated that their numeric value assigned 

to the social cost of carbon vastly underestimates the 

true cost. BOEM’s analysis of the cumulative 

impacts of its proposal on environmental justice 

communities is inadequate. In particular, its failure to 

adequately describe and quantify these negative 

impacts does not comply with its duty to disclose 

environmental justice implications. BOEM’s 

quantification of the purported economic benefits of 

its proposal while assigning zero value to the social 

and environmental costs is disingenuous and 

unlawful. Indeed, BOEM seems to dismiss the 

import of the additional air pollution that could result 

from its proposal on Gulf communities because there 

is already significant OCS-related infrastructure in 

the Gulf states. This approach undercuts the entire 

purpose of a cumulative impacts analysis and efforts 

to inform and engage environmental justice 

communities.

Lone Star LSCSC

-6 Oil spills and air pollution from offshore drilling and 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-138 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Chapter of the 

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

industrial facilities like refineries that support the 

industry make people sick and disproportionately 

harm low-income neighborhoods and communities of 

color. But BOEM fails to adequately analyze the 

environmental justice impacts of its proposal. For 

example, BOEM dismisses the import of the 

additional air pollution that could result from its 

Proposal on Gulf communities because there is 

already significant OCS-related infrastructure in Gulf 

States. This approach undercuts the entire purpose 

of a cumulative impacts analysis and efforts to inform

and engage environmental justice communities, in 

violation of NEPA.

No New 

Leases Form 

Letter

NNL-2 Moreover, oil spills and air pollution from offshore 

drilling and industrial facilities like refineries make 

people sick and disproportionately harm low income 

neighborhoods and communities of color. BOEM's 

proposal fails to adequately consider these impacts. 

Katrina Dubytz KD-1 All right. So, oil spills and air pollution from drilling 

and refining facilities make people very sick. There's 

a lot of reports out about various health issues that

are caused by it. And especially, they 

disproportionately harm low- income neighborhoods 

and communities of color, which is a huge issue for 

environmental justice. A lot of people don't realize 

that the people who are being affected are very, like -

- sorry, they're like, essentially, like lower SES people 

who live not necessarily in the cities that are 

benefiting from the results of drilling and whatnot, but 

on the outskirts, who don't even benefit from the 

things that are harming them, whether it be in health 

or noise pollution, air pollution, whatnot. Or in this 

case, especially coastal areas that might be affected 

if there were an oil spill, fishing communities, 

whatnot; those areas that don't rely on more 

commercial things that might benefit from said 

practices.

Gulf GRN

-11 The environmental justice impacts of oil drilling need 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-139

Commenter Comment ID Comment Response

Restoration 

Network, 

Howard Page 

to be better considered. Recent accidents have 

really devastated our fishing industry. They've also 

devastated our tourism industry. Our dolphin 

populations are the worst they've ever been, with 

incidents of infant mortality. Our turtle populations 

have been harmed. Our oysters are in terrible 

shape. And our fisherman are suffering from this as 

well as the tourist industry when people kind of 

question do they want to come to an area that's 

known for tarballs and known for dying dolphins and 

known for bad oyster populations where you can't 

even eat the local oysters anymore. And as these 

continuing accidents happen, like Shell, the 

fishermen continue to have their resource harmed. 

So I would ask that, too, is that the economic impact 

to fishermen and other coastal communities that are 

often environmental justice communities, that that be 

looked at.

Renate 

Heurich

RH-5 One thing that the Environmental Impact Statement 

did not really look at is, I mean, they mentioned 

global warming and climate change, but they really 

did not put a cost, the real cost of climate change as 

compared to drilling for oil, on there.· And this is 

going to be immense in terms of health impacts, but 

also catastrophic weather events, floods, droughts. 

It's going to affect the ability of people to live in cities 

where it gets hotter and hotter or to grow food when 

the land is drying up.

Renate 

Heurich

RH-7 Also, the Environmental Impact Statement did not 

look at, okay, what do we do with the oil and the gas 

that we are producing, like, if it's going to be 

transported to refineries. We have people living near 

refineries and breathing in toxic air. We create toxic 

byproducts from refining oil. All of that has to go 

somewhere. We have here in Louisiana the area 

called “Cancer Alley” with all of the petrochemical 

factories and refineries, and people are experiencing 

high levels of cancer and extremely rare cancers, but 

The proposed Federal action being analyzed in this 

Multisale EIS is to offer for lease those areas that 

may contain economically recoverable oil and gas 

resources in accordance with the OCSLA, which 

specifically states “should be made available for 

expeditious and orderly development, subject to 

environmental safeguards” (OCSLA, 43 U.S.C. §§ 

1331 et seq.). The purpose of this Multisale EIS is 

to evaluate the direct and indirect effects of a 

proposed action (i.e., a proposed lease sale) as well 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-140 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

they can’t go anywhere because their houses aren’t 

worth much anymore. And these refineries 

disproportionally affect the franchise communities, 

people of color, lower income communities, which is 

also not right, and it's a big environmental justice 

issue.

as the incremental contribution of a proposed lease 

sale to the cumulative effects. BOEM 

acknowledges that there could be impacts from 

onshore infrastructure supporting oil and gas 

activities on the OCS, whether through development 

and production or through refining onshore. Please 

refer to Chapters 4.14.1 and 4.14.3 for a discussion 

of indirect impacts to land use and coastal 

infrastructure and social factors (including 

environmental justice).

Steps 

Coalition, 

Jennifer 

Crosslin, 

Community 

Organizer 

STEPS-2 The expansion of offshore drilling ensures that her 

communities and others like it in the Gulf will 

continue to be poisoned, and it is an injustice not to 

take into account these communities in the EIS. It is 

also an injustice that your EIS calculates risk of 

drilling disaster by the number of spills and not also 

by the severity of the spill and -- by the severity of the 

spill and the negligent behavior -- the often negligent 

behavior of the oil and gas industry reporting and 

cleaning up spills.

BOEM conducts an oil-spill risk analysis prior to 

conducting lease sales in OCS areas. This risk 

analysis includes the probability of oil-spill 

occurrence, which is based on spill rates derived 

from historical data (Anderson et al., 2012) and on 

estimated volumes of oil produced and transported.

BOEM seeks to provide a robust analysis of the 

issues related to a decision of whether and how to 

proceed with oil and gas lease sales in the Gulf of 

Mexico. Our analysis of oil-spill risk, which is 

detailed in Chapter 3.2.1, includes detailed 

discussions of offshore spills <1,000 bbl and 

≥1,000 bbl, and coastal spills. As described in 

Chapter 3.2.1.4.2 (Trajectory Modeling for Offshore 

Spills ≥1,000 bbl), the Bureau of Ocean Energy 

Management’s OSRA model simulates the 

trajectory of thousands of spills throughout the Gulf 

of Mexico OCS and calculates the probability of 

these spills being transported and contacting 

specified geographic areas and features. Using the 

OSRA model, BOEM estimates the likely 

trajectories of hypothetical offshore spills 

≥1,000 bbl. Only spills ≥1,000 bbl are addressed 

because smaller spills are not likely to persist long 

enough to be simulated by trajectory modeling. For 

this analysis, the OSRA model was run for 

Alternatives A, B, and C (Tables 3-2 and 3-3) and 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-141

Commenter Comment ID Comment Response

the Cumulative OCS Oil and Gas Program (2017-

2086). Chapter 4.14.3.2.2 discusses the potential 

for oil spills to contact coastal communities.

In addition to modeling oil spills, Chapter 3.2.1.1.1

(Trends in Reported Spill Volumes and Numbers) 

reports the total number and volume of oil spills 

reported to USCG from various sources, including 

barges, tankers, pipelines, and platforms. The 

analysis reported in Etkin (2009) reinforces the fact 

that hurricanes are the most common cause of spills 

from both platforms and pipelines; it also reports 

that structural failures (e.g., corrosion) account for a 

significant percentage of the total volume of spilled 

oil from offshore pipelines. Preventative measures 

are taken, including inspecting pipelines at routine 

intervals and using corrosion resistant or corrosioninert materials. In addition, when pipelines are 

protected by rectifiers or anodes for which the initial 

cathodic protection system either cannot be 

calculated or calculations indicate a life expectancy 

of less than 20 years, the pipelines are inspected 

annually. Also, refer to Chapter 3.1.6.1 (Structure 

Age and Idle Iron) and Chapter 3.2.4 (Pipeline 

Failures), which is where BOEM addresses potential 

environmental hazards and impacts relating to 

pipelines.

Please refer to Chapters 3.2.1.4 and 3.2.1.5 and 

the response to Comment CBD, BL, GRN, LBB, 

RAHC-13.

Mississippi 

Coalition for 

VietnameseAmerican 

Fisher Folk 

and Families, 

Thao Vu, 

MCVAFFF-5 Not only was it the largest environmental disaster, 

but it caused huge social, economic as well as health 

impacts and concerns, particularly for fishing 

communities along the Gulf. There are many in 

Louisiana, here in Mississippi, Alabama, Florida, and 

Texas. And they were disproportionately impacted 

by this disaster, and they still haven't recovered 

The Trustees have reached a settlement with BP to 

resolve BP’s liability for natural resource injuries 

resulting from the Deepwater Horizon oil spill. 

Under this settlement, BP will pay up to $8.8 billion 

for restoration.

Based on the Trustees’ thorough assessment of 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-142 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Director because the disaster really deeply devastated the 

Gulf of Mexico, its habitats, its fisheries, right.

impacts to the GOM’s natural resources, they 

selected the comprehensive, integrated ecosystem 

restoration approach for restoration implementation. 

This approach is outlined in the comprehensive 

restoration plan, which will allocate funds from the 

settlement for restoration over the next 15 years.

The plan, and information on the settlement with BP 

(called the Consent Decree), can be found at 

http://www.gulfspillrestoration.noaa.gov/restorationplanning/gulf-plan. 

Chapter 4.14.3.2.2 acknowledges that, if an 

accidental event affects more than one county or 

parish and is measurable with impacts lasting up to 

1 year, then the impact would be moderate. The 

potential impacts as a result of a low-probability 

catastrophic event like the Deepwater Horizon oil 

spill, however, are not part of a proposed action and 

are not likely expected to occur. New regulations 

focusing on improved safety, more regulatory 

checks, and inspections should decrease the 

already small likelihood of the occurrence of such 

spills. Potential impacts as a result of a lowprobability catastrophic event are discussed in the 

Catastrophic Spill Event Analysis white paper 

(USDOI, BOEM, 2017).

Please refer to the response to Comment CBD, BL, 

GRN, LBB, RAHC-13 for information on BOEM’s 

environmental justice analysis.

Topic 5 – Cumulative Analysis

American 

Petroleum 

Institute (API),

Andy Radford

API-9 As BOEM recognizes, a good NEPA analysis 

considers the cumulative impacts of the proposed 

action and alternatives . “Cumulative impact” is “the 

impact on the environment which results from the 

incremental impact of the action when added to other 

BOEM appreciates the substantive content of this 

comment. BOEM has reviewed all cumulative 

impact analyses in each resource chapter in 

Chapter 4 of this Final Multisale EIS and has added 

clarification to ensure that the baseline conditions 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-143

Commenter Comment ID Comment Response

past, present, and reasonably foreseeable future 

actions regardless of what agency...or person 

undertakes such actions....” 40 C.F.R. § 1508.7 

(emphasis added). Although the DEIS accounts for 

impacts associated with many other past, present, 

and future actions affecting the same resources as 

the lease sales, it presents the information in tables 

that can appear somewhat misleading and overstate 

the impacts of the leasing actions under 

consideration. This may be because the agency 

conflates the impacts of these other factors with the 

cumulative, incremental impacts of the proposed 

lease sales. For example, the “impact-producing 

factors” (Table 4-4 on p. 4-51) indicates that the 

cumulative impact of “OCS Oil and Gas” on estuarine 

systems will be “moderate,” while the cumulative 

impact of non-OCS oil and gas on estuarine systems 

will be “major.” From the discussion in the impact 

analysis, it appears that BOEM is saying that the 

incremental impact of OCS oil and gas activities on 

those systems is “minor” when added to the past, 

present, and reasonably foreseeable future impacts 

of non-OCS oil and gas activities. However, the 

table could easily be misinterpreted to mean that the 

otherwise “minor” impacts of OCS oil and gas 

activities will become incrementally “major” when 

added to other past, present, and reasonably 

foreseeable future non-OCS oil and gas activities. 

This interpretive issue is present in many of the 

“impact-producing factors” tables contained in 

Chapter 4 of the DEIS. See, e.g., Table 4-5 at p. 4-

75. At a minimum, BOEM should revise these tables 

to ensure that the cumulative, incremental impact of 

the proposed action(s) (i.e., lease sales) is made 

clear and distinct from the impacts of other actions 

that BOEM is not proposing to undertake. This 

problem is particularly pronounced in the analysis of 

impacts to land use and coastal infrastructure, which

and the effects of past actions, events, and ongoing 

activities are accounted for in the analysis. 

Additional clarification has been added to the impact 

tables in each chapter as well, e.g., Table 4-1 in 

Chapter 4.1.2. Specifically, BOEM has reviewed 

the impact assessment for land use and coastal 

infrastructure to ensure its accuracy and 

consistency. Revisions to the text can be found in 

Chapter 4.14.1. 

Specifically, the chapter on land use and coastal 

infrastructure has been revised accordingly. The 

greatest confusion has been addressed by 

removing the sentence, “Negative and positive 

impacts are measured on that scale.” Land use and 

coastal infrastructure is the only chapter in this 

Multisale EIS that defined impact measures as 

potentially negative and/or positive across the 

impact-level range of negligible, minor, moderate, 

and major. The table that shows cumulative 

impacts as “negligible to major” did not mean major 

negative impacts, but major positive impacts. When 

the table in question (page 4-373 of the Draft

Multisale EIS) was transferred to the “Alternative 

Comparison Matrix” table (page xvii of the Draft 

Multisale EIS), this critical distinction was lost, i.e., 

the fact that an impact could be a positive impact. 

While the original approach held that impacts could 

be positive (or negative) across the range of 

negligible to major, the chapter has been revised to 

address the need for clarification and to avoid 

confusion. Rather than considering positive impacts 

as scalable (from negligible to major), they simply 

have been termed “beneficial.”

Also, the cumulative impacts chapter in each 

resource chapter has been revised to more clearly 

describe the methodological approach. Specifically, 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-144 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

appears to contain a number of additional internal 

inconsistencies. For example, on p. xxvii of the 

DEIS, BOEM explains that “[b]ecause OCS oil- and 

gas-related activities are supported by [a] long-lived, 

expansive onshore network, the potential impacts of 

a proposed lease sale are not expected to produce 

any major impacts to land use and coastal 

infrastructure.” Yet the impact levels for land use 

and coastal infrastructure indicated in the “Alternative 

Comparison Matrix” Table 1 on p. xvii of the DEIS 

are the only impacts associated with OCS oil and gas 

leasing characterized as potentially “major.” DEIS at 

pp. xvi-xvii. Moreover, examination of the impact 

analysis for land use and coastal infrastructure in 

Chapter 4 of the DEIS indicates nominally 

“negligible” to “moderate” impacts on land use and 

coastal infrastructure. Yet the cumulative impacts 

portion of the “impact-producing factors” table on p. 

4-373 indicates a potentially “major” cumulative 

impact. In contrast, the substantive cumulative 

impact analysis on p. 4-384 of the DEIS indicates a 

“minor” incremental impact. All this apparently 

conflicting information makes it difficult to determine 

the degree of impact, cumulative or otherwise, that 

the proposed lease sales are expected to have on 

land use and coastal infrastructure, and needs to be 

harmonized or explained. At a minimum, BOEM 

should revisit the impact assessment for land use 

and coastal infrastructure to ensure its accuracy and 

consistency. API suggests BOEM incorporate the 

changes below in regards to clarifying analyses (see 

below) and by incorporating more clear description of 

the methodology used to determine cumulative 

impacts, including clear documentation of the 

evidence used to determine impact levels that inform 

the cumulative analysis. Although the source of 

these apparent inconsistencies is unclear, it may be 

associated with BOEM confusing the relatively minor 

each chapter was reviewed to ensure a detailed 

discussion of the small incremental contribution of 

one proposed lease sale when added to the 

cumulative impacts of all past lease sales and the 

baseline, etc., along with a discussion of the 

rationale behind the temporal and spatial bounds of 

the analysis. Additional documentation has been 

added to the resource chapters, where appropriate, 

as well.
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-145

Commenter Comment ID Comment Response

incremental cumulative impact of the proposed lease 

sales with the impact of other (i.e., non-OCS oil and 

gas related) activities. At a minimum, BOEM should 

revisit the impact assessment to ensure accuracy 

and consistency through this DEIS as additional 

NEPA review for later decisions to hold any of the 

individual lease sales will tier heavily from this 

current DEIS.

Brenda 

Warger

BW-2 Also I am in opposition because I feel that BOEM 

underestimates the amount of climate changes 

gases and their environmental impact because they 

fail to adequately analyze past, present and future 

foreseeable actions in the Environmental Impact 

Statement.

BOEM recognizes the importance of climate change 

and considers many facets of the potential effects of 

climate change in its decisionmaking with respect to 

oil and gas leasing, whether in the Five-Year 

Program or lease sale analyses. In the Five-Year 

Program EIS, BOEM compares greenhouse gas 

emissions from direct OCS emissions to those that 

could occur from energy substitutes that would 

presumably replace OCS production in the absence 

of a new OCS Program and comparable demand 

levels. Downstream greenhouse gases have been 

quantified. Please refer to the Five-Year Program 

EIS for additional information about greenhouse gas 

emissions and climate change. BOEM expects that 

reducing OCS oil and gas consumption in the U.S. 

and the associated emissions from limiting OCS 

leasing would largely be offset by substitutes from 

other energy sources, either within the United 

States or elsewhere. BOEM has considered a no 

action alternative (i.e., cancellation of a proposed 

lease sale); however, that does not necessarily 

equate to zero downstream greenhouse gas 

emissions from oil and gas unless energy demand 

or supply changes drastically or cost-competitive 

clean energy sources are substituted.

This Multisale EIS tiers from the Five-Year Program 

EIS and has included a summary of the information 

in Chapter 4.0.

David 

Underhill

DU-1 And that makes it the duty of BOEM to consider the 

cumulative impact of these leases have on the 

effects on the climate when the oil and gas extracted 

from the leases is burned.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-146 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Mississippi 

Coalition for 

VietnameseAmerican 

Fisher Folk 

and Families, 

Thao Vu, 

Director 

MCVAFFF-7 And, you know -- and we think that the development 

of this Environmental Impact Statement, which I only 

have a small summary, but that larger one, 700 page 

or more, we think that in terms of development, that 

is a backward process and it causes more injustices, 

because we believe that you need to fully assess the 

impacts as well as the cumulative impacts to these 

communities who depend on healthy -- a healthy Gulf 

of Mexico, its ecosystems, the habitats, and its 

fisheries, right. And if you're proposing a plan that 

they don't even know about or they can't access, 

that's even causing more injustices, right. And we 

believe that's very serious, right.

BOEM is working with the Mississippi Coalition for 

Vietnamese American Fisher Folks and Families to 

identify their needs and future outreach 

opportunities. BOEM met with the Mississippi 

Vietnamese community and fishermen on Friday, 

July 15, 2016, in Gautier, Biloxi, Gulfport, and Pass 

Christian, Mississippi, to tour their boat docks and 

discuss their concerns. The fishermen believe that 

the Deepwater Horizon oil spill and spill response 

has impacted the oyster and coastal brown shrimp 

populations. The Deepwater Horizon oil spill and 

spill response is causing the fishermen more 

expenses because they need to go farther offshore 

to shrimp. BOEM is following up with government 

contacts to check on the oyster and brown shrimp 

populations and the potential reasons for the 

decrease.

Community 

Advocate

CA-1 A review [of] the EIS indicates the failure in 

complying with the NEPA process, it does not 

present an analysis of the cumulative impacts of 

past, present, and proposed leasing plan.

Thank you for your comment. Each resource 

chapter was reviewed, and clarifying language was 

added to ensure that the incremental, program, 

non-OCS, and reasonably foreseeable impacts 

were clearly identified.

Topic 6 – Oil Spills

Center for 

Biological 

Diversity, Bold 

Louisiana, 

Gulf 

Restoration 

Network, 

Louisiana 

Bucket 

Brigade, 

Radical Arts 

and Healing 

Collective

(CBD, BL, 

GRN, LBB, 

CBD, BL, GRN, 

LBB, RAHC-8 

BOEM Failed to Adequately Consider the Risks of an 

Oil Spill: BOEM also dismisses the import of routine 

and large oil spills because the transport of oil and 

gas is federally regulated. However, transporting oil 

and gas is inherently dangerous and spills occur as a 

matter of course in offshore oil and gas operations 

from both tankers and pipelines. BOEM must give 

consideration of impacts from such spills proper 

weight. BOEM’s Draft EIS states that the vast 

majority of oil and gas extracted in the Gulf of Mexico 

is transported via pipeline. A review of records of the 

federal Pipeline and Hazardous Materials Safety 

Administration, which maintains a database of all 

U.S. pipelines, demonstrates that transport of oil and 

gas carries a significant risk of environmental and 

Thank you for your comment. BOEM seeks to 

provide a robust analysis of the issues related to a 

decision of whether and how to proceed with oil and 

gas lease sales in the Gulf of Mexico. Our analysis 

of oil-spill risk, which is detailed in Chapter 3.2.1, 

includes detailed discussions of offshore spills 

<1,000 bbl and ≥1,000 bbl, and coastal spills. As 

described in Chapter 3.2.1.4.2 (Trajectory Modeling 

for Offshore Spills ≥1,000 bbl), the Bureau of Ocean 

Energy Management’s OSRA model simulates the 

trajectory of thousands of spills throughout the Gulf 

of Mexico OCS and calculates the probability of 

these spills being transported and contacting 

specified geographic areas and features. Using the 

OSRA model, BOEM estimates the likely 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-147

Commenter Comment ID Comment Response

RAHC),

Kristen 

Monsell, 

Staff Attorney

public safety impacts. Nationally, there were nearly 

8,000 significant incidents with U.S. pipelines, 

involving death, injury, and economic and 

environmental damage between 1986 and 2013—

more than 300 per year. Incidents classified as 

“significant” are those resulting in death or injury, had 

damages more than $50,000, spilled more than five 

barrels of highly volatile substances or 50 barrels of 

other liquid, or where the liquid exploded or burned. 

And offshore spills occur as a matter of course in the 

Gulf of Mexico. For example, in 2015, an offshore 

natural gas pipeline in Gulf of Mexico ruptured, 

causing a fire that injured two workers. And in 2016, 

nearly 90,000 gallons of oil leaked from a flow line 

that created an oil sheen in the Gulf of Mexico that 

was two by 13 miles wide. In fact, the U.S. 

Department of Transportation found that offshore 

pipelines can be more vulnerable than onshore 

pipelines. They have a greater vulnerability to 

severe weather conditions than onshore pipelines, 

especially during hurricane events. And massive 

wave action can alter the pipeline stability, causing 

gradual displacement, especially in small diameter 

pipelines. Offshore pipelines can also face more 

corrosion than onshore pipelines due to higher 

temperature and pressure conditions that occur 

during the laying of these pipelines. In addition, 

aging poses risks of corrosion, erosion and fatigue 

stress to subsea pipelines. Subsea pipeline 

corrosion appears to accelerate over time, and can 

act synergistically with fatigue stress to increase the 

rate of crack propagation. Marine environments are 

especially known to produce significant corrosion on 

steel surfaces, and when a steel structure is at or 

beyond its elastic limit, the rate of corrosion 

increases 10-15%. One offshore pipeline study 

found that after 20 years the annual probability of 

pipeline failure increases rapidly, with values in the 

trajectories of hypothetical offshore spills 

≥1,000 bbl. Only spills ≥1,000 bbl are addressed 

because smaller spills are not likely to persist long 

enough to be simulated by trajectory modeling. For 

this analysis, the OSRA model was run for 

Alternatives A, B, and C (Tables 3-2 and 3-3) and 

the Cumulative OCS Oil and Gas Program (2017-

2086).

In addition to modeling oil spills, Chapter 3.2.1.1.1

(Trends in Reported Spill Volumes and Numbers) 

reports the total number and volume of oil spills 

reported to USCG from various sources, including 

barges, tankers, pipelines, and platforms. The 

analysis reported in Etkin (2009) reinforces the fact 

that hurricanes are the most common cause of spills 

from both platforms and pipelines; it also reports 

that structural failures (e.g., corrosion) account for a 

significant percentage of the total volume of spilled 

oil from offshore pipelines. Preventative measures 

are taken, including inspecting pipelines at routine 

intervals and using corrosion resistant or corrosioninert materials. In addition, when pipelines are 

protected by rectifiers or anodes for which the initial 

cathodic protection system either cannot be 

calculated or calculations indicate a life expectancy 

of less than 20 years, the pipelines are inspected 

annually. Also, refer to Chapter 3.1.6.1 (Structure 

Age and Idle Iron) and Chapter 3.2.4 (Pipeline 

Failures), which is where BOEM addresses potential 

environmental hazards and impacts relating to 

pipelines.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-148 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

range of 0.1 to 1.0, which equates to a probability of 

failure of 10% to 100% per year. Another study 

covering 1996-2010 found that accident incident 

rates, including spills, increased significantly with the 

age of infrastructure. Consistent with these findings, 

a report published in 2010 found that the number of 

oil spills from offshore rigs and pipelines between 

2000 and 2009 more than quadrupled the rate of 

spills in prior decades. In particular, from the early 

1970s through the 1990s, offshore rigs and pipelines 

averaged about four spills per year of at least 

2,100 gallons. The average annual total skyrocketed 

to more than 17 from 2000 to 2009, and averaged 

22 per year from 2005 to 2009 alone. And the 

number of spills, as well as the quantity of spilled oil, 

grew significantly worse even when taking increased 

production in account. Federal data show that new 

pipelines also carry a high risk of spills, mostly 

because of faulty design or construction. These data 

indicate there are more oil spills in the first two years 

of pipeline’s life than in the next seven years 

combined. This is a significant concern given that 

BOEM estimates a single lease sale could result in 

the installation of up to 1,330 miles of new offshore 

pipelines. BOEM must therefore conduct a more 

thorough analysis of the risks and effects of oil spills 

in the Gulf of Mexico.

Sierra Club,

Devorah 

Ancel, 

Staff Attorney

SC-5 BOEM’s Risk Analysis for Offshore Spills Does Not 

Adequately Consider the Inherent Dangers of 

Deepwater and Ultra-Deepwater Drilling: In its risk 

analysis for offshore spills greater or equal to 

1,000 barrels, BOEM calculated spill rates “based on 

the assumption that spills occur in direct proportion to 

the volume of oil handled and are expressed as 

number of spills per billion barrels of oil handled.” 

This analysis fails to take into account the risks 

inherent in deepwater drilling. The lease sales at 

issue encompass high risk ultra-deepwater areas, 

BOEM acknowledges that, with respect to oil spills, 

the potential for a blowout to result in a large oil spill 

may be greater in deep water than in shallow water 

because BOEM’s resource assessment studies 

show a higher probability of large oil reservoirs 

being discovered and produced in deep water as 

compared with shallow water (DeCort, official 

communication, 2012). BOEM provides an analysis 

of a catastrophic oil spill in the Catastrophic Spill 

Event Analysis white paper (USDOI, BOEM, 2017) 

because a spill of that magnitude is not reasonably 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). Responses to Public Comments on the Draft Multisale EIS L-149

Commenter Comment ID Comment Response

close to 11,000 feet deep, and contain large areas of 

high risk formations many of which will produce high 

pressure/high temperature wells. The increased risk 

of spills and disasters associated with these high risk 

conditions must be part of BOEM’s spill risk calculus. 

Moreover, the Draft EIS bases its risk analysis of 

spills greater than 1,000 barrels on a report that uses 

spill data through 2010 which doesn’t account for the 

recent expansion of ultra-deepwater drilling. Since 

1992 when deepwater exploratory drilling began in 

earnest, a total of 244 wells have been drilled in 

ultra-deep waters. As of 2013, there were 136 ultradeepwater wells in operation. This number is a 

significant jump from 2009 when there were only 

65 ultra-deepwater wells in operation. The Draft EIS 

analysis of spill risk through 2010 omits potential 

significant increases in the risk of a spill, or even 

catastrophic spill, associated with the significant 

spike in ultra-deepwater drilling in recent years. This 

analysis must be corrected and considered when 

evaluating the risk of developing the unique 

deepwater areas encompassed within the proposed 

lease sale areas. In addition, the industry has 

developed a “mechanical risk index” (“MRI”) which 

calculates the complexities present in deepwater oil 

drilling in the Gulf of Mexico based on a number of 

factors and then rates the complexity of the well on a 

1 to 5 scale with 5 being the most complex. Those 

factors include the water depth (ranging from 

>3,200 feet to >6,700 feet), well depth (ranging from 

>19,000 feet to >30,000 feet), the number of casings 

strings, and the percent population penetrating salt. 

The Deepwater Horizon well represents a 3+ to 4 in 

these rankings. As of 2009, only 43 wells were 

drilled in the Gulf of Mexico with a complexity level of 

3, 4, or 5 which would indicate that the actual 

likelihood of catastrophic failure for wells of this 

nature based on past oil spills could be as high as 

foreseeable and not part of a proposed action 

(Ji et al., 2014).

Deepwater and ultra-deepwater wells require 

complex infrastructure, planning, and execution to 

construct; therefore, facilities and the volume of 

production tend to get larger with distance from 

shore and water depth (Shultz, 1999). The complex 

nature of the formations, combined with the drilling 

depths in high-pressure/high-temperature conditions 

required to reach the target zones, presents a 

challenge to drilling engineers (Close et al., 2008). 

This challenge is highlighted in the greater number 

of casing strings required to drill to target depth, 

which in turn creates the challenge in achieving 

good cement isolation in a tight tolerance annuli

(Close et al., 2008; Chatar et al., 2010). Despite 

such challenges, over 4,115 deepwater boreholes 

have been drilled as of September 2016 (where 

deep water is considered >1,000 ft [305 m]). Of 

these, the Macondo well is the only exploration well 

to involve a blowout and large oil spill. No spills 

have occurred for deepwater development wells.

Risk analyses may be characterized as “hazard 

based” or “risk based.” A hazard-based analysis 

examines the possible events regardless of their low 

(or high) likelihood. For example, a potential impact 

would not lose significance because the risk has 

been reduced due to an increase in the level of 

control, such as engineering standards. While 

limiting leasing (i.e., cancelling lease sales) might 

reduce risk, BOEM considers a key to managing 

risk is through implementing a rigorous regulatory 

regime to ensure that postlease drilling activities are 

conducted in a safe manner, whether those 

activities occur in shallow water or in deep water. A 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-150 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

1 in 43. BOEM’s risk analysis for high volume 

catastrophic events wholly ignores the unique 

characteristics of ultra-deepwater as a risk factor of 

drilling in the proposed lease sale areas. This must 

be corrected.

risk-based analysis, on the other hand, takes into 

account the likelihood of the event occurring and the 

measures that can be taken to mitigate against its 

potential impacts.

The Bureau of Ocean Energy Management’s OSRA 

is designed for use as a risk-based assessment. 

The OSRA uses two basic criteria in selecting the 

volume of oil handled as the primary exposure 

variable: (1) the exposure variable should be simple 

to define; and (2) it should be a quantity that can be 

estimated. In this regard, historical data on the 

volume of OCS oil handled, and associated oil 

spills, is readily available. In addition, as part of the 

OSRA analysis, a cluster analysis is used to further 

divide the geographic domain into additional 

subareas based on water depth. Cluster analysis is 

a multivariate technique that groups entities based 

on similar characteristics and identifies offshore 

areas that show similar risk. Please refer to the 

OSRA for additional information.

Recently, a BOEM/BSEE-sponsored study entitled 

2016 Update of Occurrence Rates for Offshore Oil 

Spills updated the previous work presented in 

Anderson et al. (2012). While this update includes 

oil spills reported through 2015, it also examines 

causal factors associated with each individual spill. 

The information in this report has been incorporated 

into this Final Multisale EIS. While there will always 

be incomplete or unavailable information regarding 

offshore spills that could conceivably result in 

potential future shifts in baseline conditions and 

affect BOEM’s decisionmaking, BOEM has 

determined that it can make an informed decision 

on a proposed lease sale using the most recent spill 

information provided in ABS Consulting, Inc. (2016). 

Through the tiered NEPA process for oil and 

Renate 

Heurich

RH-2 I'm also really concerned about the fact that a lot of 

those leases are in areas that are very deep. Half of 

it is as deep as the Deepwater Horizon or deeper, 

which means it's really risky to drill that deep.

John Young JY-5 Here on the south most tip of Texas, Shell and other 

oil and gas companies have boasted to industry 

insiders and investors regarding their offshore 

operations 135 miles due east of Brownsville, TX. 

But there's been nothing in the local news about how, 

for example, Shell has drilled deeper and pressed 

the limits harder there than BP's catastrophic 

Deepwater Horizon. [See See "Drilling picks up 

across the Perdido Foldbelt," Anne Leonard & Tom 

Liskey, Offshore, 01-13-2016, http://www.offshoremag.com/articles/print/volume-76/issue-1/gulf­ ofmexico/driIIing-picks-up-across-the-perdidofoldbelt.html/] 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-151

Commenter Comment ID Comment Response

leasing, future BOEM environmental reviews can 

take into account any new information that may 

emerge.

Sierra Club, 

Devorah 

Ancel, 

Staff Attorney

SC-6 BOEM Failed to Adequately Analyze the Impacts of a 

Catastrophic Spill: As described in more detail 

below, the 2010 BP Deepwater Horizon disaster 

which spilled 206 million gallons of oil into the Gulf 

has had devastating impacts on Gulf of Mexico 

ecosystems, the livelihoods of Gulf communities, and 

the tourism industry. The Gulf has endured other 

catastrophic spills, including a 140 million gallon spill 

in 1979. In 2004, Hurricane Ivan struck a Taylor 

Energy offshore platform causing hundreds of 

gallons to leak into the Gulf for over a decade; and, 

recent reports indicate a dramatic spike in the size of 

oil sheens in the vicinity and increased volumes of 

spilled oil in the past two years. Nearly 10,000 

smaller spills have been reported between 2010 and 

2015 in the Gulf of Mexico. In addition, numerous 

other catastrophic spills in other parts of the world 

have devastated marine ecosystems and the 

communities that depend upon them. The question 

is not if there will be a catastrophic spill event, it is 

when there is such an event what are the impacts 

and what are the response capabilities of the 

industry, government and other stakeholders. Oil 

spills cause irreversible damage to marine and 

coastal environments, and the destructive impacts of 

large spills are immediate and severe. Oil spills and 

cleanup are also disruptive to ship traffic and 

detrimental to impacted shorelines, subsistence 

activities, commercial and recreational fishing, 

tourism, and the health of people living along the 

coast and people involved in clean-up efforts. BOEM 

largely dismisses the impacts of a catastrophic oil 

spill concluding that such an event has a “low 

probability” of occurring and is “not reasonably 

foreseeable.” Further, the Draft EIS oddly states that 

BOEM determined that, because a catastrophic 

event like the Deepwater Horizon explosion, oil spill, 

and response is not considered reasonably 

foreseeable as a result of a proposed action, the 

analysis should be removed from this Multisale EIS 

to avoid confusion over whether it is or is not part of 

a proposed action. This is allowed under CEQ’s 

regulations, which removed the requirement to 

analyze worst-case scenarios. However, in 

accordance with CEQ guidance and to inform the 

public of the potential impacts in the unlikely event 

of such a spill (though not reasonably foreseeable), 

BOEM has made this information available to the 

public through its website. BOEM also 

acknowledges that one of the key ways of managing 

the risk of such an event is to implement a rigorous 

regulatory regime to ensure that postlease drilling 

activities are conducted in a safe manner.

For a detailed analysis of reasonably foreseeable 

impacts associated with a low-probability 

catastrophic spill, such as the Deepwater Horizon

explosion and oil spill, refer to the Catastrophic Spill 

Event Analysis white paper (USDOI, BOEM, 2017).
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-152 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

a catastrophic oil spill event is “not part of the 

proposed action.” Indeed, an unintended 

consequence with potential adverse impacts is never 

part of the proposed action, but it nevertheless must 

be evaluated as part of the NEPA process. BOEM 

deflects all analysis of a catastrophic event by simply 

referencing the Catastrophic Spill Event Analysis 

white paper prepared after the Deepwater Horizon 

spill. Further, in the Proposed Five Year Plan 

document, BOEM largely dismisses the impacts of a 

catastrophic oil spill reasoning that oil and gas 

activities are regulated and changes have been 

implemented since Deepwater Horizon. These 

assumptions are particularly troubling given that 

several recently published federal studies have found 

that necessary regulatory changes have in fact not 

yet been implemented, and the causes of the 

Deepwater Horizon oil spill still have not been fully 

addressed. Moreover, BOEM’s sister agency, BSEE, 

“has not fully addressed deficiencies in its 

investigative, environmental compliance, and 

enforcement capabilities identified by investigations 

after the Deepwater Horizon incident,” and 

accordingly, the agency is not able to effectively 

oversee offshore oil and gas development. BOEM’s 

failure to adequately assess the true impacts of a 

catastrophic spill event within the Draft EIS is a 

violation of NEPA and must be corrected.

Lone Star 

Chapter of the 

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

LSCSC-18 BOEM must analyze the impacts of a catastrophic oil 

spill. BOEM dismisses the impacts of a catastrophic 

oil spill because oil and gas activities are regulated 

and changes have been implemented since 

Deepwater Horizon. But this assumption ignores 

several federal studies published since the disaster 

finding that sufficient regulatory changes are still 

lacking. It also ignores the reality that transporting oil 

and gas is inherently dangerous and spills occur as a 

matter of course in offshore oil and gas operations 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-153

Commenter Comment ID Comment Response

from both tankers and pipelines.

Cyrus Reed CR-9 And, you know, finally -- I guess I'll try to do this in 

written form -- but I would make the argument, they 

haven't really analyzed the impacts in the EIS of a 

catastrophic oil spill, like the one that occurred six 

years ago, in making sure that you look at that 

situation again and what's changed since six years 

ago, I think would be important.

No New 

Leases Form 

Letter

NNL-4 And finally, offering new offshore oil and gas leases 

puts marine wildlife and our coasts at risk of oil spills 

and other damage. The Gulf of Mexico is still reeling 

from the Deepwater Horizon disaster. New offshore 

oil development will accelerate deepwater drilling and 

fracking, increasing the risk of yet more accidents 

and spills and again, BOEM's proposal fails to 

sufficiently analyze these threats.

BOEM is very concerned about the potential 

impacts of oil spills on the environment. In this 

Multisale EIS, OCS oil- and gas-related oil spills are 

analyzed in the “Accidental Events” chapters, and 

other spills (e.g., in State waters or from other 

sources on the OCS) are analyzed in the 

“Cumulative Impacts” chapters for all relevant 

resources. As impacts from the Deepwater Horizon

explosion, oil spill, and response continue to be 

assessed, additional analyses will be completed at 

the site-specific approval stage and in future 

Supplemental EISs.

While limiting leasing (i.e., cancelling proposed 

lease sales) might reduce risk, BOEM considers a 

key to managing risk is through implementing 

implement a rigorous regulatory regime to ensure 

that postlease drilling activities are conducted in a 

safe manner, whether those activities occur in 

shallow water or in deep water. Please refer to

Appendix A for information on BOEM’s and BSEE’s 

rigorous postlease processes.

Safety measures and technologies have increased 

since the Deepwater Horizon oil spill. A fact sheet 

on research and regulatory reforms can be found on 

BOEM’s website at http://www.boem.gov/2017-

2022-GOM-Multisale-Public-Meeting-HandoutsVisuals/.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-154 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Please refer to Chapter 3.2.1 for more information 

on oil-spill risk assessment.

Harriett E. 

Myers

HM-3 Oil disasters affect the lives of sea life; the availability 

of seafood for the seafood industry, & for my table 

are affected. Tourist industries are also affected.

Thank you for your comment. BOEM acknowledges 

the potential harmful impacts to sea life, the seafood 

industry, and the tourism industry as a result of an 

oil spill. These negative consequences are 

analyzed for each resource chapter in Chapter 4

and in the Catastrophic Spill Event Analysis white 

paper (USDOI, BOEM, 2017).

For the analysis related to coastal habitats 

(including wetlands and beaches), please refer to 

Chapter 4.3; for birds, please refer to Chapter 4.8; 

for protected birds, please refer to Chapter 4.9.4; 

and for recreational resources (tourism), please 

refer to Chapter 4.12.

Harriett E. 

Myers

HM-4 The coast is not immune to damage. Spills harm 

seabirds and coastal birds, coastal plants including 

habitat for spawning, beaches for the pleasure of 

citizens & tourists.

Gulf 

Restoration 

Network, 

Johanna de 

Graffenreid

GRN-3 We have seen numerous leaks from existing or 

plugged wells in the Gulf. Until these leaks can be 

studied on a cumulative level, pursuing new drilling is 

irresponsible and does not allow for comprehensive 

risk analysis in an EIS of this size.

BOEM is currently unaware of any issues related to 

the decommissioning of offshore wells, including 

plugging, sealing, and abandonment. A review of 

spill data reported to both USCG and BSEE 

provides no information showing abandoned wells 

are currently leaking. This issue is independent 

from the leaking wells from the Taylor Energy 

platform that was lost during Hurricane Ivan and 

which is located in Mississippi Canyon Block 20.

Additional information regarding this issue has been 

incorporated into this Final Multisale EIS. BOEM’s 

analysis in this Multisale EIS acknowledges the 

risks of accidental spills and events, even in light of 

the rigorous safety regulations in place. Accidental 

events are identified and described in Chapter 3.2. 

Potential impacts from these activities are analyzed 

in each resource chapter in Chapter 4. 

Nevertheless, BOEM acknowledges that, even with 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-155

Commenter Comment ID Comment Response

the stringent standards, risk is not wholly eliminated. 

For example, Table 3-17 acknowledges that, even 

with application of these standards, certain small 

spills (≥1.000 bbl) may be reasonably foreseeable. 

BOEM/BSEE are constantly evaluating and 

responding to potential risks through strengthening 

enforcement and inspection, and continually 

updating regulatory requirements.

Hilton Kelley HK-5 So, we need to do more to help protect our Gulf. We 

need to do more to explore renewable energies in 

ways we could get off of fossil fuels and ways we can 

save our wildlife. Because as we know, a lot of birds 

each year get caught in some of the oil spills 

because they can't differentiate whether or not it's 

water or oil in the water when they land and they are 

being destroyed.

This Final Multisale EIS analyzes the harm spills 

can have on seabirds and coastal birds; the analysis 

can be found in Chapter 4.8. In this Final Multisale 

EIS, the impact analysis of oil spills includes much 

pertinent information on impacts on seabirds and 

coastal birds by the Deepwater Horizon explosion, 

oil spill, and response. BOEM also used the Oil 

Spill Risk Analysis model to forecast potential 

impacts of future large spills that may impact 

seabirds and coastal birds. This analysis can be 

found in Chapter 4.8.2 (Environmental 

Consequences) of this Final Multisale EIS.

BOEM determined that an analysis of the potential 

for alternative energy is outside the scope of this 

Multisale EIS for a proposed action. The purpose 

and need identified for this Multisale EIS is to 

provide an analysis of the environmental impacts of 

oil and gas leasing. However, BOEM does 

recognize the need to investigate the potential for 

alternative energy on the Federal OCS, and this is 

addressed in the Five-Year Program EIS (Chapters 

1.4.6.1 and 2.7.4), from which this Multisale EIS 

tiers. BOEM's Office of Renewable Energy is 

responsible for developing an offshore renewable 

energy program in the Gulf of Mexico. Information 

on BOEM’s renewable energy program, OCS 

leases, and renewable energy projects 

(34 proposed or currently in development) is 

available on BOEM’s website at 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-156 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

http://www.boem.gov/Renewable-Energy/.

Leon Soil and 

Water 

Conservation 

District 

Supervisory 

Board in Leon 

County, 

Florida, Brian 

Lee 

LSWCDSB-2 And the other issue very strongly related to that is the 

severity of more spills and accidents occurring in the 

Gulf, happening as climate change becomes 

exacerbated. So as the climate gets worse, there 

are going to be more storms, and as there are more 

storms, the equipment used for drilling and 

developing fossil fuels in the Gulf is more at risk to 

damage and causing even more spills.

While it is possible that, as a result of climate 

change, both the number and severity of hurricanes 

may increase, the Bureau of Ocean Energy 

Management’s OSRA estimates the risk of oil-spill 

contact to sensitive offshore and onshore 

environmental resources and socioeconomic 

features. Included in this analysis are trajectory 

simulations based on historical surface ocean 

currents and winds, which incorporate periods of 

hurricane conditions. In addition, BSEE provides a 

robust set of regulations relating to hurricane 

preparedness that help lower the risk of oil spills 

occurring and help prevent any loss of life. The 

effects of hurricanes on coastal areas and oil and 

gas structures are discussed in Chapters 3.1.6.1 

and 3.2.1.1 and in the resource sections in 

Chapter 4. The effects of climate change and sealevel rise on coastal areas is discussed in Chapters 

3.3.2.8.1 and 3.3.2.10 and in the resource sections 

in Chapter 4. 

Additionally, Chapter 3.2.1.1.1 (Trends in Reported 

Spill Volumes and Numbers) reports the total 

number and volume of oil spills reported to USCG 

from various sources, including barges, tanks, 

pipelines, and platforms. The analysis reported in 

Etkin (2009) not only reinforces the fact that 

hurricanes historically are the most common cause 

of spills from both platforms and pipelines but also 

reports that structural failures (e.g., corrosion) also 

account for a significant percentage of the total 

volume of spilled oil from offshore pipelines. As 

noted above, BSEE and BOEM’s rigorous safety 

regulations require industry to ensure they are 

sufficiently prepared for hurricanes, both to prevent 

spills and to respond to any spills that do happen.
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-157

Commenter Comment ID Comment Response

Restore 

Mississippi 

Sound, 

Sharon Hayes, 

Director

RMS-1 The EIS seriously underestimates the health of the 

Gulf and its aquatic life. It underestimates the 

impacts of the BP oil spill, the amount of oil and the 

dispersant remaining in the water, and their effects 

on marine mammals, fish, and other aquatic life. The 

analysis says that the probability of another large 

spill is so small that its possible effects are not 

considered in the EIS. And the model that they used 

to assess the impacts of oil spills, SYMAP, is not 

designed to handle large spills. Given that they use 

that model, it would be overwhelmed if they -- if they 

considered the damaging effects of large spills.

The Department of the Interior has adopted the 

definition of scientific and scholarly integrity as the 

condition resulting from adherence to professional 

values and practices, when conducting and applying 

the results of science and scholarship, that ensures 

objectivity, clarity, reproducibility, and utility and that 

provides insulation from bias, fabrication, 

falsification, plagiarism, outside interference, 

censorship, and inadequate procedural and 

information security.

For more information on this policy and contact 

information for BOEM’s Scientific Integrity Officer 

(http://www.doi.gov/scientificintegrity/ScientificIntegrity-Officers.cfm), visit DOI’s webpage on the 

Integrity of Scientific and Scholarly Activities 

(http://www.doi.gov/scientificintegrity/index.cfm). 

BOEM has determined that the analysis in this 

Multisale EIS is centered on credible scientific 

research and addresses any gaps in information, 

including any related to the Deepwater Horizon

explosion, oil spill, and response. This includes the 

incorporation of publicly available data from the 

PDARP/PEIS. In the vast majority of the scientific 

references used in this document, the methods 

used to conduct the research are explained. The 

studies cited in the references are publicly available 

and the “explicit documentation of what constitutes 

[best available science] BAS” would be too 

extensive to detail in an EIS. However, in numerous 

places in this Multisale EIS, where it was considered 

important or when BOEM had derived independent 

methods for evaluating a resource, these methods 

are included in the descriptions in the text or specific 

methodologies were summarized, e.g., the 

calculation of OCS oil- and gas-related service 

vessels. BOEM’s subject-matter experts have 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-158 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

clarified in this Multisale EIS where incomplete or 

unavailable information may be essential to a 

reasoned choice among alternatives, if the 

information could be obtained or, if the costs of 

obtaining it are exorbitant, and that what 

scientifically credible information is available was 

applied using accepted scientific methodologies.

BOEM has used the most relevant, up-to-date, and 

credible science throughout the preparation of this 

Multisale EIS, including throughout development of 

the oil and gas hydrocarbon forecasts and activity 

scenarios. BOEM has presented a robust range to 

reasonably bound low and high activity levels for 

each alternative for each proposed lease sale. 

BOEM does not expect every proposed lease sale 

to reach the highest high or lowest low of the 

scenario forecasts but that it will fall within the 

reasonable range presented in Tables 3-1 and 3-2. 

BOEM continues to pursue and utilize the most 

relevant, up-to-date and credible science in 

development of this Final Multisale EIS and 

subsequent NEPA documents.

Please refer to Chapter 3.0, which is where we 

provide information on the science and methods 

used to develop the scenarios.

Each alternative single lease sale scenario is based 

on (1) recent trends in the amount and location of 

leasing, exploration, and development activity; 

(2) estimates of undiscovered, unleased, 

economically recoverable oil and gas resources in 

each water-depth category and each planning area; 

(3) existing offshore and onshore oil and/or gas 

infrastructure; (4) published data and information; 

(5) industry information; and (6) oil and gas 

technologies and the economic considerations and 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-159

Commenter Comment ID Comment Response

environmental constraints of these technologies. 

Due to the inherent uncertainties associated with an 

assessment of undiscovered resources, probabilistic 

techniques were employed to develop the scenario, 

and the results are reported as a range of values 

corresponding to probabilities of occurrence. BOEM 

used the aforementioned categories to develop a 

low-activity scenario and a high-activity scenario. 

The activity level associated with a proposed lease 

sale is expected to vary based on a number of 

factors, including the price of oil, resource potential, 

cost of development, and resource availability (e.g., 

drill rig availability). BOEM feels the developed 

ranges provide a reasonable expectation of oil and 

gas production and associated activity anticipated 

from a single proposed lease sale.

Restore 

Mississippi 

Sound, 

Sharon Hayes, 

Director

RMS-2 The EIS also doesn't include reference to the Taylor 

Energy Spill in the Gulf caused by Hurricane Ivan in 

2006. Currently discharges over 90 gallons per day 

for over 10 years, and there is no end in sight.

Additional information regarding the Taylor Energy 

platform that was lost during Hurricane Ivan and that 

was located in Mississippi Canyon Block 20 was 

incorporated into this Final Multisale EIS (Chapter 

3.2.1.1.3).

Restore 

Mississippi 

Sound, 

Sharon Hayes, 

Director

RMS-4 Most recently we have the Shell Oil Spill. This past 

week observers who flew over the spill believe that it 

was actually several times larger than originally 

reported.

Official estimates are currently being investigated by 

USCG and have yet to be released. The latest 

available information does not suggest that the size 

of the Shell oil spill in May 2016 was any larger or 

smaller than what was originally reported.

Gulf Coast 

Group of the 

Mississippi 

Sierra Club, 

Steve 

Shepard, 

Chair

GCGMSC-1 I am unhappy with the notion of more oil and gas 

lease sales because of the propensity of oil spills, 

plus having a spill from 2004, the Taylor Spill, that 

has not ever been stopped. And I obviously have a 

fear that as we drill deeper and in more difficult 

places, that we will be seeing more and more of 

these spills, which are accumulating and causing our 

Gulf to lose its previous productivity.

Additional information regarding the Taylor Energy 

platform that was lost during Hurricane Ivan and that 

was located in Mississippi Canyon Block 20 was 

incorporated into this Final Multisale EIS (Chapter 

3.2.1.1.3). The BSEE and BOEM have worked with 

USCG under a Unified Command to monitor and 

respond to discharges from Taylor Energy’s 

Mississippi Canyon Block 20 site since the oil 

production platform and 25 of the 28 connected 

wells were impacted and damaged during Hurricane 

Ivan in 2004. The multi-agency effort has worked 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-160 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

continuously to prevent and control oil discharge, to 

improve the effectiveness of containment around 

the source of the oil discharge, and to mitigate 

environmental impacts. The Unified Command’s 

collaborative efforts have resulted in the removal of 

the platform deck, removal of subsea debris, 

decommissioning of the oil pipeline, and intervention 

of 9 of the 25 impacted wells. Taylor Energy, as the 

responsible party, has a continuing legal obligation 

and responsibility to pay for oil-spill recovery and 

response costs under the Oil Pollution Act of 1990.

Please refer to the response to Comment MR-1 

regarding recent rigorous regulatory requirements 

both before and after the Deepwater Horizon

explosion, oil spill, and response, and to Comment 

SC-5 for information about deepwater drilling.

Yolanda 

Ferguson

YF-6 If they choose to drill, they have to choose a way to 

show us how they're not going to make us sick 

anymore. That's my major concern, how are you 

going to clean it up?

Oil-spill prevention and response plans are 

discussed in Chapter 3.2.8.1.1 and Appendix A.5, 

and the discussion of mitigating measures can be 

found in Appendix B. While BOEM discusses oil 

spills in Chapter 3.2.1, a catastrophic oil spill as a 

result of a blowout is not part of a proposed action 

nor is it considered likely to occur. BOEM provides 

an analysis of such a spill in the Catastrophic Spill 

Event Analysis white paper (USDOI, BOEM, 2017). 

Nevertheless, oil-spill response plan requirements 

mandate that operators estimate a worst-case 

discharge scenario and prepare to respond to such 

a spill even if not reasonably foreseeable.

Yolanda 

Ferguson

YF-7 You all -- they -- if they were going to -- I want to 

know who's in charge of the spill. I don't want the 

spiller in charge of the spill ever again. I don't want 

someone like BP to write a contingency plan that 

gives them the power to do what they did ever again. 

The spiller doesn't need control of the spill.

Please refer to the response to Comment YF-5, and 

refer to Chapter 3.2.8.1 for a more detailed 

discussion of BSEE’s spill-response requirements 

and initiatives.

A Federal On-Scene Coordinator (FOSC) is a 

representative of a Federal agency such as USCG 

or USEPA. The FOSC oversees the oil-spill 

Gulf 

Restoration 

GRN-10 The Coast Guard or U.S. Government should be 

entirely in control of a cleanup. It should not be the 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-161

Commenter Comment ID Comment Response

Network,

Howard Page

corporation that destroyed the water. response effort and determines if the efforts were 

conducted in accordance with the National 

Contingency Plan (USDHS, CG, 2016).

The NOAA’s Office of Response and Restoration is 

charged with responding to oil spills, chemical 

accidents, and other emergencies in coastal areas. 

Under the National Contingency Plan, NOAA is 

responsible for providing scientific support to the 

FOSC for oil and hazardous material spills. To 

support this mandate, the Office of Response and 

Restoration provides 24-hour, 7-day-a-week 

response to spills (USDOC, NOAA, Office of 

Response and Restoration, 2016).

Gulf 

Restoration 

Network, 

Howard Page

GRN-9 Also more access needs to be given to coverage the 

these events. The press needs to be given full, 

unrestricted access to any spill.

BOEM's Office of Public Affairs promotes 

transparency, responds to all media requests, and 

provides accurate and timely information on all 

BOEM-related subjects. The BSEE oversees oilspill planning and preparedness for U.S. facilities 

that are located in both State and Federal waters 

seaward of the coastline and that handle, store, or 

transport oil. This authority is granted through the 

Oil Pollution Act of 1990 and Executive Order 

12777. All functions related to BSEE’s authorities in 

oil-spill research, planning, preparedness, and 

response are now handled through the National Oil 

Spill Program, which is administered by the Oil Spill 

Preparedness Division. The BSEE makes available 

to the public the information regarding oil spills, 

incidents, investigations, and statistics; this 

information can be found on BSEE’s website at 

http://www.bsee.gov. Refer also to the response to 

Comment YF-7.

Mississippi 

Coalition for 

VietnameseAmerican 

Fisher Folk 

MCVAFFF-8 Lastly, we're very, very concerned that our federal 

and state agencies have not learned to implement 

the lessons learned and best practices, right. For 

example, from -- after the Exxon Valdez, you know, 

oil disaster, the -- in Prince William Sound, they 

The Trustees have issued the PDARP/PEIS, and 

information on the settlement with BP (called the 

Consent Decree) can be found at http://

www.gulfspillrestoration.noaa.gov/restorationplanning/gulf-plan.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-162 Gulf of Mexico Multisale EIS

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and Families,

Thao Vu, 

Director 

create a regional citizen advisory council, right. And 

that's to provide some citizen oversight and 

monitoring. There is a great, great critical need to 

implement that -- establish that here for the Gulf -- for 

the Gulf Coast region, right. And it needs to be 

implemented now so we can have contingency 

programs to be able to prepare to -- you know, 

prepare and respond to other future disasters like the 

one we just had with Shell last week. Right. That is 

greatly, greatly needed and -- to have contingency 

programs in place and to have adequate 

infrastructure and cleanup workers are properly 

trained and to be able to respond to that. And we 

believe that is greatly missing. That needs to be 

implemented right away. And, in fact, after BP, there 

was a National Spill Commission. One of their key 

recommendations was the establishment of this 

Regional Citizen Advisory Council, and to this day it 

hasn't been established.

Within the PDARP/PEIS, the Trustees received 

similar comments calling for a Regional Advisory 

Council to be established. The Trustees also 

received a comment that “referenced a report 

recommending a public advisory committee. That 

September 2010 report, correctly titled America’s 

Gulf Coast: A Long-Term Recovery Plan after the 

Deepwater Horizon Oil Spill, provides 

recommendations on working with existing Federal 

and State advisory committees to ensure that 

relevant scientific and technical knowledge 

underpins planning but does not have 

recommendations specific to a citizen’s advisory 

group for the NRDA effort.

Within Chapter 8.3 (page 8-109) of the 

PDARP/PEIS, the Trustees acknowledged the need 

to more specifically describe the public engagement 

and transparency that will occur in the restoration 

planning process, and they believe that the 

additional engagement and transparency steps 

described in Sections 7.3 and 7.7 of the 

PDARP/PEIS, and in response to Comments 7-28 

and 7-29 on the PDARP/PEIS, meet the current 

needs for public engagement and involvement 

without formal development of a Regional Citizens 

Advisory Group. Public dialogue and comment will 

be possible during an annual Trustee Council 

meeting and annual Trustee Implementation Group 

(TIG) meetings that will be open to the public. The 

Trustees will also engage the public and maintain 

transparency of the restoration planning process by 

accepting public submittal of project ideas, providing 

the public with a description of what Restoration 

Type(s) each TIG will focus on over a specified 

timeframe, providing public review and comment on 

each restoration plan, including opportunities for 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-163

Commenter Comment ID Comment Response

public engagement during draft restoration plan 

meetings. Further, the Trustees are committed to a 

transparent restoration planning process and will 

ensure that information is shared in a timely manner 

related to restoration planning milestones, project 

reporting, and monitoring data aggregation through 

the use of the Trustee Council website; TIG 

websites; the DIVER Restoration Management 

Portal; and focused press releases, email blasts, 

and/or text messages, although the exact means 

will likely vary by TIG. Additional details of the 

public engagement and transparency steps have 

been included in Sections 7.3 and 7.7 to provide 

clarifying information in the Final PDARP/PEIS. 

More specific details will be further described in the 

Trustee Council’s Standard Operating Procedures 

and any subsequent Standard Operating 

Procedures for a given TIG.

Refer to Chapter 3.2.8.3 for more information on 

Area Contingency Plans (ACPs). The ACPs cover 

subregional geographic areas and represent the 

third tier of the National Response Planning System 

mandated by the Oil Pollution Act of 1990. The 

ACPs are a focal point of response planning, 

providing detailed information on response 

procedures, priorities, and appropriate 

countermeasures. The USCG has worked diligently 

to improve coastal oil-spill response since the 

Deepwater Horizon oil spill by improving the ACPs 

for each coastal USCG sector. The GOM coastal 

area that falls within USCG’s 8th District is covered 

by ACPs for areas covered by USCG Sector Corpus 

Christi, Sector Houston/Galveston, Sector Port 

Arthur, Sector Morgan City, Sector New Orleans, 

and Sector Mobile. The ACPs from USCG’s 7th

District cover the remaining GOM coastal area.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-164 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Apalachicola 

Riverkeeper

AR-1 The method and data BOEM used in developing the 

document includes flawed assumptions about: 1) the 

degree of impacts, 2) the accuracy in reporting of 

volume and range of impacts, and 3) the life or 

duration of the impacts that result from spills. These 

assumptions provide an over estimation of the 

benefits without assessing the real costs of the 

impact. We know that the estimates of past OCS 

Spills is built on inaccurate and often unreported 

incidents and spills which grossly underestimates the 

volume of contaminants leaked and the probable 

impacts that result from them. BOEM also assumes 

that certain incidents have a low potential of 

recurring, when in fact the potential is unknown or 

much higher. For example the Deep Water Horizon 

spill is viewed as unlikely to reoccur when in all 

probability as exploration into deeper water and wells 

occur, the risk increase with a greater probability of 

occurring. Realistic evaluations and a new analysis 

should be undertaken.

Specifically, per 30 CFR § 250.187 and 30 CFR § 

254.46(a), operators are required to immediately 

report to BSEE all spills of oil or other liquid 

pollutants that are known or suspected to be 1 bbl in 

volume or greater. This requirement is in addition 

to, but does not substitute for, the National 

Response Center’s reporting requirements. Per 

30 CFR § 254.46(b)(2), spills >50 bbl in volume 

require more detailed reporting and monitoring, and 

such spills trigger greater investigative response by 

BSEE, which may require the operator to submit 

additional information about the response. These 

reports of historical spills help form the basis of the 

range of spills that may be reasonably foreseeable 

as a result of a proposed lease sale. For 

information related to the probability of a 

catastrophic spill occurring, please refer to the 

response to Comment CBD, BL, GRN, LBB, 

RAHC-4.

John Kersting JK-2 Exploration, drilling, and transportation raise the risks 

of catastrophic oil spills, and expose our air, water, 

and wildlife to significant amounts of pollution. There 

have been 40 large oil spills (greater than 42,000 

gallons) since 1964, but smaller spills occur on a 

daily basis. In the past 45 years, BOEM estimates 

that more than 500,000 barrels of oil have leaked, 

unreported, into American waters.

Thank you for your comment. Please see the 

responses to Comments CBD, BL, GRN, LBB, 

RAHC-8 and SC-6.

Ronald Kardos RK-2 The potential for leaks is too risky and there is no 

adequate way to monitor for leaks in this 

environment. The damage done to the fragile 

ecosystem during construction and forever after is 

inestimable. Although the Flower Banks Marine 

Sanctuary will not be sold for the highest bidder, 

there is a potential for damage to it.

Here is just one example of the dangers of offshore 

drilling (a Taylor Energy Company owned platform 

Please refer to Chapter 3.2.1 for more information 

on oil-spill risk assessment.

BOEM considered and eliminated an alternative 

excluding the Flower Garden Banks National Marine 

Sanctuary in Chapter 2.2.3. 

BOEM included information on the Taylor platform 

leak in Chapter 3.2.1.1.3. 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-165

Commenter Comment ID Comment Response

that has been leaking since 2004):

http://www. nola.com/environment/index 

.ssf/2015/04/gulf_ oiI_spill_hidden_2004. htmI

Topic 7 – Mitigation

State of 

Louisiana 

Department of 

Natural 

Resources

(LADNR), Don 

Haydel,

Acting 

Administrator

Interagency 

Affairs/Field

LADNR-3 In a broader sense, it is of concern to OCM that the 

responsibility within BOEM for compensatory 

mitigation appears to be unclear. The DEIS states 

that this responsibility lies with unspecified “program 

offices” at Headquarters level: Program and Policy 

Issues: Comments and concerns that relate to 

program and policy are issues under the direction of 

the U.S. Department of the Interior and/or BOEM’s 

guiding regulations, statutes and laws. The [scoping] 

comments and concerns related to program and 

policy issues are not considered to be specifically 

related to the proposed actions. For example, the 

Louisiana Department of Natural Resources, Office 

of Coastal Management requested in their scoping 

comments that this Multisale EIS make provisions for 

compensatory mitigation for all lease sale impacts. 

Such comments are forwarded to the appropriate 

program offices for their consideration. 

Programmatic issues ... have been considered in the 

preparation of the Draft Five-Year Program EIS. 

(DEIS page 2-32). However, the Outer Continental 

Shelf Oil and Gas Leasing Program: 2017-2022 Draft 

Programmatic Environmental Impact Statement, 

prepared by BOEM’s Headquarters office, places the 

responsibility for compensatory mitigation at the Gulf 

of Mexico Region level: “Appropriately scaled 

analyses at these later decisions for leasing, 

exploration, development, and production can best 

identify specific mitigation measures, including 

required compensatory mitigation measures“ (pg. 

1-8). Once again, OCM strongly urges BOEM to 

accept the responsibility to identify and quantify the 

accumulating coastal impacts of OCS lease sales to 

Louisiana, and provide appropriate compensatory 

BOEM recognizes the apparent, but unintended, 

contradiction in statements on compensatory 

mitigation in the Draft Multisale EIS and Draft FiveYear Program EIS. BOEM is in the process of 

developing a compensatory mitigation program to 

determine how and at what stage(s) it could be 

applied to BOEM-regulated activities. The 

information provided in the Five-Year Program EIS 

is intended to provide a high-level overview of how 

BOEM could use a landscape-level approach to 

planning and mitigating impacts, including 

implementation of the full mitigation hierarchy.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-166 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

habitat mitigation.

Alabama 

Historical 

Commission, 

Lee Anne 

Wofford

AHC-1 Upon review of the above referenced project, we 

request that a professional maritime archeologist 

meeting the DOI's professional standards complete a 

maritime archeological survey of the project areas to

identify any cultural resources that may be present. 

The survey should conform to Alabama’s Standards 

for Submerged Cultural Resource Survey as 

provided. Submit the resulting report to our office for 

review and determination prior to construction 

activities.

Section 106 reviews of proposed actions are 

conducted by BOEM’s staff of professional marine 

archaeologists as part of the environmental reviews 

conducted for postlease activities. These reviews 

are based, in part, upon data collected by remotesensing (i.e., magnetometer, side-scan sonar, and 

subbottom profiler) surveys conducted on behalf of 

the individual lease operators. The surveys are 

reviewed and reported on by their contracted 

archaeologists, with the reports submitted to BOEM. 

Approximately 200 such reports are received and 

reviewed each year. The archaeologists preparing 

the reports for submittal to BOEM meet the National 

Park Service’s guidelines for professional 

archaeologists. Surveys typically cover an 

operator’s 9-mi2 (23-km2

) lease block, but the 

surveys may extend to cover multiple blocks, 

especially in very deep water. These are not likely 

to occur for years after any one individual lease 

sale.

The technical requirements of the archaeological 

resource reports are detailed in NTL 2005-G07, 

“Archaeological Resource Surveys and Reports.” 

Under 30 CFR § 550.194(c) and 30 CFR § 

250.1010(c), lessees are required to notify BOEM 

and BSEE immediately of the discovery of any 

potential archaeological resources. BOEM is 

committed to consulting with the Alabama Historical 

Commission regarding the potential impacts to 

submerged cultural heritage of interest located off 

the coast of Alabama. However, given regulatory 

due dates imposed by the OCSLA and the volume 

of applications processed by this office each year (in 

the hundreds), it is our belief that it is not practical to 

consult on each individual action within the GOM if 

the potential resource can be avoided. We 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-167

Commenter Comment ID Comment Response

recommend, instead, initiating consultation in the 

event that a resource has been found to be 

significant and cannot be avoided. BOEM’s staff is 

amenable to a follow-up conversation that explains 

the process more fully and to explain the 

archaeological survey procedures and standard 

mitigations that are employed to ensure historic 

properties on the OCS are not affected by offshore 

energy development.

Alabama 

Department of 

Environmental 

Management

(ADEM),

Anthony Scott 

Hughes, Chief

ADEM 1 The ADEM supports the leasing of any unleased 

blocks in the Gulf of Mexico with the exception of 

those blocks which are located within the 15 miles of 

the Baldwin County, Alabama coastline. Alabama's 

Governors have consistently opposed the sale of 

these leases. IN addition, the ADEM requests 

BOEM require adequate protection for the live 

bottom areas, pinnacle reefs, chemosynthetic 

communities, and other sensitive environments in the 

OCS off Alabama's coast.

As noted in ADEM’s letter, the Governors of 

Alabama have historically indicated opposition to 

new leasing south and within 15 mi (24 km) of 

Baldwin County; however, they have requested that, 

if the area is offered for lease, a lease stipulation to 

reduce the potential for visual impacts should be 

applied to all new leases in this area. Protective 

measures are in place to mitigate the potential 

impacts to the areas south of Baldwin County and to 

the biologically significant bottom-founded marine 

communities and archeological resources. 

Coordination requirements are described in the 

Blocks South of Baldwin County, Alabama and 

Topographic Features Stipulations (which can be 

found in Appendix D), and the resource analyses in 

Chapter 4. In addition, during postlease reviews, 

BOEM and BSEE have a suite of mitigations that 

are included as conditions of approval, as the site 

specific conditions warrant. Examples of such 

relevant postlease mitigations might include, but is 

not limited to, prohibiting discharges near sensitive 

live bottom habitats (e.g., chemosynthetic 

communities), anchoring restrictions, distancing 

requirements, ROV surveys. Appendix B provides 

more detail on the suite of applicable mitigations 

that could be applied to protect the areas of concern 

presented in your comment.

United States 

Environmental 

USEPA-4 EPA has noted in several past EISs that coastal 

wetland systems in the Gulf of Mexico are very 

In order to clarify the basis for negligible impacts, 

BOEM projects that the majority of new pipelines 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-168 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Protection 

Agency

sensitive systems that are increasingly stressed from 

all types of activities including but not limited to 

coastal development, maintenance dredging of 

channels, and oil and gas development. These 

systems are also stressed due to natural events such 

as hurricanes. Stresses on these systems are only 

predicted to increase with climate change and sea 

level rise.

A report by Stedman and Dahl (2008) on the status 

and trends of wetlands in coastal watersheds states 

that the "Gulf of Mexico coastal watersheds exhibited 

substantial losses in freshwater wetlands. This rate 

of loss was 6 times higher than the rate of freshwater 

vegetated wetlands losses in the Atlantic coastal 

watersheds. The estimated losses for all wetland 

types in the Gulf of Mexico were 25 times higher than 

those estimates for the Atlantic over the course of 

this study." This report also indicates that coastal 

areas along the panhandle of Florida, Alabama, 

Mississippi, Louisiana, and Texas are listed as areas 

of greatest coastal wetland loss in the Gulf of Mexico 

and that a "majority of the coastal wetland loss 

(61,800 acres per year) from 1998 to 2004 occurred 

in the Gulf of Mexico." EPA notes BOEM's efforts to 

better quantify historical wetland losses for coastal 

areas in the Gulf of Mexico, the inclusion of State 

specific information on the status and trends of 

coastal wetland systems in Chapter 4 of the EIS, and 

the evaluation of several recent studies looking at the 

impacts of the Deepwater Horizon spill on these 

coastal systems.

In Section 4.3.1 Estuarine Systems (Wetlands and 

Seagrass/Submerged Vegetation), Table 4-4 

identifies routine impacts as negligible for pipeline 

construction and maintenance, navigation channel 

maintenance dredging, vessel operation, disposal of 

constructed as a result of a proposed action would 

connect to the existing pipeline infrastructure 

offshore; therefore, there would be no coastal and 

wetland impacts from pipeline landfalls. In the rare 

instance that a new pipeline to shore would need to 

be constructed, it would likely be because there are 

no existing pipelines reasonably close and because 

constructing a pipeline to shore is considered more 

cost effective, although it is highly unlikely for an 

operator to choose this contingency (Dismukes, 

official communication, 2011). BOEM anticipates 

that pipelines from most of the new offshore 

production facilities would tie into the existing 

pipeline infrastructure offshore or in State waters, 

which would result in few new pipeline landfalls 

(page 3-42 of the Draft Multisale EIS). Impacts are 

deemed negligible due primarily to the fact that only 

0-1 pipeline landfalls are projected with a proposed 

action. In addition, the 12- to 20-ac (5- to 8-ha) 

estimate represents the impact that could occur 

without mitigation. In practice, it would likely be an 

overestimate, given current regulatory policies of 

COE and the Gulf Coast States. As stated in the 

Draft Multisale EIS, this estimate does not take into 

account mitigating measures from the present 

regulatory programs of Federal or State agencies, 

modern installation techniques, and the Federal “no 

net loss” policy. These programs and techniques 

include compensatory mitigations and less 

destructive construction methods.

BOEM has no regulatory authority over wetland 

mitigation and cannot commit to the implementation 

of mitigating measures for wetlands impacts. 

BOEM’s authority is generally limited to oil and gas 

activities on the OCS. However, such authority is 

enforceable through the Clean Water Act and the 

Coastal Zone Management Act. BOEM prepares 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-169

Commenter Comment ID Comment Response

OCS oil- and gas-related wastes, and construction 

and use of coastal support infrastructure under 

Alternatives A, B, C and D. However, on page 4-56 

and 4-57, the DEIS states that one (1) pipeline 

construction resulting in12-20 acres of 'land loss' is 

expected without modern techniques (e.g., 

trenchless construction) or mitigation. It is unclear 

how the impacts are deemed negligible. Trenchless 

or modem techniques are only required for 'crossing 

barrier island and shore faces', and the expected 

impact is negligible. The DEIS identifies access and 

staging areas for trenchless construction will entail 

impacts. The Lease Stipulations in Appendix D and 

the discussions in Section 2.2.4 (Mitigation 

Measures) does not discuss the requirement to use 

modern techniques for new pipeline construction. 

Additionally, Appendix B mitigation measures for 

pipelines relates solely to deep water construction 

and does not indicate any measures required for 

pipelines in coastal habitat. Further, it appears the 

DEIS does not fully evaluate new pipeline 

construction for more inland coastal habitats and 

wetlands.

Recommendation:

EPA recommends the FEIS clarify how the pipeline 

construction and operation mitigation measures 

required of lease operators will be enforceable.

We recommend the FEIS commit to implementation 

of mitigation measures for all pipeline construction 

and operations activities in coastal habitats.

EPA recommends the FEIS clarify the basis of 

negligible impact for pipeline construction and 

maintenance.

Coastal Zone Consistency Determinations to the 

individual states regarding lease sales. Additionally, 

BSEE does not approve pipeline right-of-way 

applications that traverse the OCS to State 

submerged lands until the corresponding permits 

from the State and COE have been reviewed and 

approved. Given Federal and State requirements 

regarding construction in the coastal zone and 

wetlands, we expect any related State and Federal 

permit to include enforceable mitigation 

requirements.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-170 Gulf of Mexico Multisale EIS

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United States 

Environmental 

Protection 

Agency

USEPA-7 On page 4-59 under Onshore Facilities, the DEIS 

states that all new facilities attributed to the OCS 

Program are described in Section 3.1.7 Coastal 

Instructure, which included 0 - 1 gas processing 

plant. Also, it states any large construction project in 

the coastal zone is likely to impact some wetland 

acreage, and any impacts upon wetlands are 

mitigated in accordance with the Clean Water Act 

requirements, Corps of Engineers' 404 Permit, and 

State permitting requirements. Further, the DEIS 

states that since no new facilities are estimated with 

the proposed action and any possible impacts would 

be mitigated, the impact would be negligible.

On page 4-66 under Coastal Infrastructure and 

Pipelines, the DEIS states activities that would 

further contribute to wetland loss include additional 

construction of access channels to shoreline staging 

areas and expansion of onshore and offshore 

facilities. It further projects 0-1 new gas processing 

facility and 0-1 new pipeline landfall. The DEIS 

identifies that if a new facility is constructed and a 

pipeline makes landfall, any impacts to wetlands 

would be mitigated. Thus, it appears BOEM is 

relying on mitigation under the Clean Water act 

requirements, Corp. of Engineers' 404 Permit, and 

State permitting programs for any potential reduction 

or mitigation of impacts. Also, it is appears the DEIS 

has conflicting statements on whether new facilities 

are included with the proposed project. Please 

clarify in the final EIS.

It is correct that BOEM is relying on mitigating 

measures typically required under the Clean Water 

Act’s requirements, COE’s 404 Permit, and Statepermitting programs for any potential reduction or 

avoidance of impacts. BOEM has no authority to 

enforce mitigation for wetland impacts, and there is 

no known footprint for construction at this stage of 

prelease impact assessment.

No new facilities are expected to be constructed as 

a result of any alternative of a proposed action 

(page 3-78 of the Draft Multisale EIS). However, 

BOEM acknowledges that the possibility still exists 

that a company would decide to construct a facility 

and, if it supported OCS oil- and gas-related activity, 

it would likely be placed in the coastal zone and 

wetland impacts could result. That is why such 

potential impacts are discussed in this Multisale 

EIS. Therefore, BOEM projects 0-1 gas processing 

plants because BOEM makes conservative 

infrastructure scenario estimates; nevertheless, the 

projection of between 0 and 1 is more likely to be 

0 than 1 (page 3-86 of the Draft Multisale EIS).

United States 

Environmental 

Protection 

Agency

USEPA-11 In Sections 2.2.4.2 Pre-lease Mitigating Measures by 

Alternative and 2.2.4.3 Post-lease Mitigating 

Measures, the DEIS discusses mitigating measures 

that could be applied at the prelease stage and 

during site-specific plan and/or permit reviews. 

Further, Appendix B identifies commonly applied 

mitigating measures that could apply. Specific 

In Chapter 2.2.4.1, BOEM defines all prelease 

mitigating measures (stipulations) analyzed in this 

Multisale EIS and identifies which stipulations are 

applicable to which alternative in Table 2-1. 

Appendix B provides definitions of all commonly 

applied postlease mitigating measures.
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-171

Commenter Comment ID Comment Response

measures were not identified.

Recommendation:

EPA recommends the FEIS clarify the specific 

mitigation measures and incorporate a commitment 

to implement mitigation measures selected to reduce 

or avoid any adverse impacts from the proposed 

project.

The Topographic Features and Live Bottom 

(Pinnacle Trend) Stipulations have been applied as 

programmatic mitigation in the Five-Year Program 

EIS (USDOI, BOEM, 201a) and therefore, would 

apply to all leases issued under the Five-Year 

Program in designated lease blocks. The analysis 

of the other eight stipulations for any particular 

alternative does not ensure that the Assistant 

Secretary for Land and Minerals Management will 

make a decision to apply the stipulations to leases 

that may result from any proposed lease sale nor 

does it preclude minor modifications in wording 

during subsequent steps in the prelease process if 

comments indicate changes are necessary or if 

conditions change. Any prelease mitigating 

measures are disclosed in the Record of Decision 

for that particular lease sale. Those stipulations 

become enforceable provisions of the lease and are 

enforced by BSEE through their rigorous inspection 

program. Postlease mitigating measures are 

implemented on a case-by-case basis throughout 

the postlease process through site-specific plan 

and/or permit reviews and cannot be speculated on 

at this point in the program. Appendix A provides 

detailed information on BOEM’s and BSEE’s 

postlease permitting and approval processes.

Topic 8 – Regulations and Safety

ConocoPhillips

, 

Richard 

Lunam, 

VP E&P, 

North America 

Exploration

CP-3 These efforts between the oil and gas industry and 

governmental agencies have built a stronger offshore 

safety culture. With increasing experience and strong 

processes in place, the nation stands to benefit 

tremendously from increased Gulf of Mexico 

exploration and development.

Thank you for your comment.

American 

Petroleum 

Institute (API), 

API-3 As part of the EIS analysis, BOEM must also 

consider the extensive safety improvements 

implemented by the industry and the new 

Thank you for your comment. In response to the 

Deepwater Horizon explosion and oil spill in the Gulf 

of Mexico in 2010, DOI launched the most 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-172 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Andy Radford requirements imposed on offshore operations since 

the Deepwater Horizon incident. Throughout the 

scoping and development of the EIS, BOEM must 

remember that history indicates the possibility of a 

catastrophic oil spill remains a very low probability. 

With the implementation of the new drilling and 

environmental safeguards adopted by industry, the 

probability of a catastrophic spill will be reduced even 

further. In addition, the formation of well containment 

companies and their ability to assist in the response 

to any future incidents must be considered.

aggressive and comprehensive reforms to offshore 

oil and gas regulation and oversight in U.S. history 

(USDOI, BSEE, 2016). The DOI has implemented a 

suite of regulatory changes following the Deepwater 

Horizon explosion, oil spill, and response. These 

changes are discussed in detail in Chapter 3.2 and 

Appendix A. 

As noted throughout this Multisale EIS, a 

catastrophic event like the Deepwater Horizon

explosion, oil spill, and response is not considered 

reasonably foreseeable as a result of a proposed 

action. The key to managing the risk of such an 

event is to implement a rigorous regulatory regime 

to ensure that postlease drilling activities are 

conducted in a safe manner. It is at this stage that 

detailed information regarding a specific proposed 

action is available for review, including reservoir 

characteristics, infrastructure designs, and features 

to ensure safety and reduce environmental risk. For 

an analysis of reasonably foreseeable impacts 

associated with a low-probability catastrophic spill, 

such as the Deepwater Horizon explosion and oil 

spill, please refer to the Catastrophic Spill Event 

Analysis white paper (USDOI, BOEM, 2017).

Furthermore, as stated in Appendix A.11, to assure 

that oil and gas exploration, development, and 

production activities on the OCS are conducted in a 

safe and environmentally sound manner, 43 U.S.C. 

§ 1347(b) of the OCSLA, as amended, requires that 

all OCS technologies and operations use the best 

available and safest technology whenever practical.

BOEM’s analysis in this Multisale EIS acknowledges 

the risks of accidental spills and events, even in light 

of the rigorous safety regulations in place. These 

are identified and the potential impact-producing 

Harriett E. 

Myers

HM-1 I believe there is no way to 100% prevent fires, spills 

or collapses; and I believe the nature of business is 

to take risks. Also, I believe current regulations are 

weak.

Jack Radosta JR-1 I implore the power that be to put a moratorium on all 

drilling unless it is 100% failsafe.

Renate 

Heurich

RH-3 I feel even with the improved regulations, there is still 

a huge risk of extreme accidents, and we know the 

impact of the Deepwater Horizon spill are still 

around. I just – I have tarballs here that I could show 

you that were just collected last month on Elmer’s 

Island. They’re all over the place. These tarballs, 

when you break them open, they contain flesh-eating 

bacteria, so we’ll be fooling with dangerous stuff. 

And we don't even know, you know, what's still going 

on at the bottom of the Gulf because that's an area 

where it's hard to explore, but there are resources. 

There are large mats of oil and we -- I'm afraid to see 

how it is going to affect the environment and fisheries 

in the long-term.

Maxine 

Ramsay

MR-1 In this here problem -- and we see it as a problem --

why should we believe any gas or oil drilling in the 

Gulf will be safe?

Yolanda 

Ferguson

YF-3 The deepwater drilling, it -- it's been -- we've had this 

before, and it was disastrous results. Have you all 

changed your itinerary on cleaning up?
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-173

Commenter Comment ID Comment Response

factors as a result of an event are described in 

Chapter 3.2. Potential impacts from these activities 

are analyzed in each resource chapter in 

Chapter 4. Nevertheless, BOEM acknowledges 

that, even with the stringent standards, risk is not 

wholly eliminated. For example, Table 3-17

acknowledges that, even with application of these 

standards, certain small spills (≥1.000 bbl) may be 

reasonably foreseeable. BOEM/BSEE are 

constantly evaluating and responding to potential 

risks through strengthening enforcement and 

inspection, and continually updating regulatory 

requirements.

Cyrus Reed CR-8 And if we are going to allow oil and gas drilling, I sure 

want there to be good rules in place so that we're not 

allowing fugitive emissions of things, and there 

should be a good leak detection and repair program 

for all offshore equipment and rigs. So, I would want 

to make sure that was in place.

Thank you for your comment. A description of the 

air emissions’ regulations and jurisdiction, and 

fugitive emissions can be found in Chapter 3.1.8. 

Please refer to Chapter 4.1 for the impacts of a 

proposed action to air quality.

Yolanda 

Ferguson

YF-4 I say, do you -- do they -- do they have a requirement 

where they go back and they have to recheck all 

these wells that they have leased over a certain 

amount of time? Your website said it's 10 years. 

Can you tell me if there is somebody that goes back 

out and rechecks all these leases? You all have got 

these little blocks to say where you leased them. 

Does anybody go out there and recheck these 

leases? I mean, you -- you're giving all these leases 

off, leases like a piece of property and it sits there 

empty. 

Thank you for your comment. A lease conveys the 

right to explore for, develop, and produce the oil and 

gas contained within the lease area. Leases are 

offered as blocks that are 9 mi2 (3 mi on a side). An 

oil and natural gas lease grants the exclusive right 

to explore for, develop, and produce oil and/or 

natural gas for a specific initial period (minimum of 

5 and maximum of 10 years) from a specific block of 

OCS land. All plans for OCS oil- and gas-related 

activities (e.g., exploration and development plans) 

go through rigorous BOEM review and approval to 

ensure compliance with established laws and 

regulations before any project-specific activities can 

begin on a lease. The OCSLA authorizes and 

requires BSEE to provide for both an annual 

scheduled inspection and a periodic unscheduled 

(unannounced) inspection of all oil and gas 

operations on the OCS. Appendix A.4 discusses 

inspection and enforcement of ongoing oil and gas 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-174 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

activities.

While the Gulf of Mexico has a mature OCS oil and 

gas leasing program, it is a huge area and there 

remain unleased blocks and interest in exploring 

new and previously leased blocks.

Yolanda 

Ferguson

YF-5 It says -- it's like they like – you wonder because if 

you're out there, do they have a contingency plan? 

We're -- you know, to clean this mess up. What's 

going to happen the next oil spill? That's my major 

concern. How are you going to clean this up? 

Where do we go to do the checks and balances to 

find out how you're going to go about what happens 

in the next spill?

As a result of the Oil Pollution Act of 1990 and the 

reorganization of the Bureau of Ocean Energy 

Management, Regulation and Enforcement into 

BOEM and BSEE, BSEE was tasked with a number 

of oil-spill response duties and planning 

requirements. Within BSEE, the Oil Spill

Preparedness Division addresses all aspects of 

offshore oil-spill planning, preparedness, and 

response. Additional information about the Oil Spill 

Preparedness Division can be found on BSEE’s 

website at http://www.bsee.gov/AboutBSEE/Divisions/OSPD/index/. Please refer to 

Chapter 3.2.8.1 for a more detailed discussion of 

BSEE’s spill-response requirements and initiatives.

The responsible party for covered offshore facilities 

must demonstrate oil-spill financial responsibility, as 

required by 30 CFR part 553. These regulations 

implement the oil-spill financial responsibility 

requirements of Title I of the Oil Pollution Act of 

1990, as amended. Penalties for noncompliance 

with these requirements are covered at 30 CFR § 

553.51 and in NTL 2008-N05, “Guidelines for Oil 

Spill Financial Responsibility for Covered Facilities.” 

A covered offshore facility, as defined in 30 CFR § 

553.3, is any structure and all of its components 

(including wells completed at the structure and the 

associated pipelines), equipment, pipeline, or device 

(other than a vessel or other than a pipeline or 

deepwater port licensed under the Deepwater Port 

Act of 1974) used for exploring, drilling, or producing 

oil, or for transporting oil from such facilities. The 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-175

Commenter Comment ID Comment Response

BSEE ensures that each responsible party has 

sufficient funds for removal costs and damages 

resulting from the accidental release of liquid 

hydrocarbons into the environment for which the 

responsible party is liable. More information on oilspill response plan regulations and processes can 

be found in Appendix A.5.

Gulf 

Restoration 

Network, 

Howard Page

GRN-6 [...] then also a real look at improved safety on the 

rigs.

The BSEE promotes compliance with safety and 

environmental standards through regular 

inspections and other monitoring activities, timely 

notice to operators of detected violations, clear 

direction for coming into compliance, and a 

reasonable opportunity for improvement. The 

BSEE’s intent is to prevent incidents; however, 

should they occur, BSEE has a duty to investigate, 

to determine the causal elements/factors, and to 

take the appropriate corrective actions. Refer to 

Appendix A.4 for more information on BSEE’s 

inspection and enforcement responsibilities, as 

authorized by the OCSLA, and to the response to 

Comment API-3 for more information on regulatory 

changes since the Deepwater Horizon explosion, oil 

spill, and response.

Gulf 

Restoration 

Network, 

Howard Page

GRN-7 There needs to be better monitoring of the pipelines 

to find the leaks in real time.

Thank you for your comment. Operators are 

required to periodically inspect pipeline routes. 

Monthly overflights are conducted to inspect 

pipeline routes for leakage. When a pipeline 

requires a repair, a repair plan notification and 

repair completion report must be submitted to BSEE 

for review and acceptance. Refer to Appendix A.3

for more information.

Gulf 

Restoration 

Network, 

Howard Page

GRN-8 So, again, much better emergency response plans 

need to happen with real assets that are really 

available, not just a few boom ships.

The BSEE oversees oil-spill planning and 

preparedness for U.S. facilities that are located in 

both State and Federal waters seaward of the 

coastline and that handle, store, or transport oil. 

This authority is granted through the Oil Pollution 

Act of 1990 and Executive Order 12777. All 

functions related to BSEE’s authorities in oil-spill 

Apalachicola 

Riverkeeper

AR-5 In addition to avoiding impacts by making the 

development of oil resources more safe and 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-176 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

sustainable by designing for all classes of hurricanes, 

mudslides, and other natural events known to be 

likely to occur, BOEM could improve spill response 

and clean up requirements. Experience has shown 

that clean-up and spill response is ineffective and 

often unsuccessful for small spills, such as the Taylor 

Oil spill going on 10 years leaking with no end in 

sight, much less catastrophic spills such as Deep 

Water Horizon. Vastly improved response and clean 

up seem reasonable and logical if our goal is to 

recover the health and productivity of the Gulf of 

Mexico and must be developed and implemented 

before additional leases are considered.

research, planning, preparedness, and response 

are now handled through the National Oil Spill 

Program, which is administered by the Oil Spill 

Preparedness Division. This Division addresses all 

aspects of offshore oil-spill planning, preparedness, 

and response. Additional information about the Oil 

Spill Preparedness Division can be found on 

BSEE’s website at http://www.bsee.gov/AboutBSEE/Divisions/OSPD/index/. Refer to Chapter 

3.2.8.1 for a more detailed discussion of BSEE’s 

spill response requirements and initiatives, to the 

response to Comment SC-11 for more information 

on oil-spill response plans, and Appendix A.5 for 

additional information.

United States 

Environmental 

Protection 

Agency

USEPA-2 The DEIS states that the Bureau of Safety and 

Environmental Environment (BSEE) "performs NP 

DES inspection on behalf of the USEPA for 

production platforms and drilling rigs though a 1984 

Memorandum of Understanding between the U.S. 

Department of the Interior, the USEPA, and the U.S. 

Department of Transportation (USDOI, MMS, 1983) 

and a 1989 Memorandum of Agreement between 

MMS (BSEE predecessor) and the USEPA Region 6 

(USDOI, MMS, 1989)." Seep. 3-55. Also, it states 

that "Produced water may be discharged if the oil 

and grease concentration does not exceed 

42 milligrams per liter (mg/L) daily or 29 mg/L 

monthly average. The discharge must also be tested 

for toxicity." See p. 3-61.

Recommendation:

EPA recommends the statement referenced on page 

3-55 start with "BSEE performs NPDES inspections 

on behalf of USEPA Region 6 for production facilities 

..... " It is later clarified that BSEE only conducts 

NPDES inspections in Region 6 jurisdictional waters, 

however to make this more clear, the above text is 

BOEM thanks USEPA for their comment. The 

suggested additional language was added to 

Chapter 3.1.5.1. 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-177

Commenter Comment ID Comment Response

recommended. 

We recommend the above text on page 3-61 include 

a statement that toxicity is primarily for chronic 

exposure but can include acute exposure.

John Young JY-4 Has the BSEE implemented the proposed "well 

control rule" to significantly strengthen safety of 

drilling and development against BP Deepwater 

Horizon type blowout disasters? [See "Protect Our 

\Miters from Oil Disasters," Gulf Restoration Network 

.03-22-2016, http:l/healthygulf.org/protect-ourwaters-oi l-disasters/]

Thank you for your comment. BSEE implemented 

the new well control rule “Oil and Gas and Sulfur 

Operations in the Outer Continental Shelf-Blowout 

Preventer Systems and Well Control” in 2016. The 

final rule is codified at 30 CFR part 250.

Topic 9 – Statutory Compliance

American 

Petroleum 

Institute (API),

Andy Radford

API-7 On p. v of the DEIS, BOEM should replace the 

phrase “requiring an EIS” with “requiring 

environmental review under the National 

Environmental Policy Act (“NEPA”).” Leasing, 

developing, and producing oil and gas resources on 

the (OCS) under the OCS Lands Act (“OCSLA”) is a 

staged decision-making process. See e.g., Native 

Village of Point Hope v. Jewell, 740 F.3d 489, 493 

(9th Cir. 2014). Because issuing OCS leases does 

not involve an irretrievable commitment of resources 

to any action with significant environmental 

consequences, NEPA does not compel the 

preparation of an EIS. Cf. Sec’y of the Interior v. 

California, 464 U.S. 312 (1984); Native Village of

Point Hope, 740 F.3d at 493; Connor v. Burford, 863 

F.2d 1521 (9th Cir. 1988). Though BOEM 

traditionally has prepared an EIS for OCS lease 

sales, BOEM need not make unnecessarily broad 

statements.

Thank you for your comment. While this language 

does not appear on page v, the text has been 

clarified in Chapter 1. 

Care2Petition Care2Petition-1 Any new oil development must follow through on 

President Obama's promise to "change the way we 

manage our oil and coal resources so that they better 

reflect the costs they impose on taxpayers and our 

planet." It's time to more appropriately balance the 

Thank you for your comment. During preparation of 

this Multisale EIS, BOEM was working under 

President Obama’s The All-of-the-Above Energy 

Strategy as a Path to Sustainable Economic Growth

(All-of-the-Above Energy Strategy) (The White 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-178 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

needs of the environment, the coast, the climate and 

our communities your current assessments fail to do 

this. Cancel these lease sales now!

House, 2014), which has three main goals: to 

support economic growth and job creation; to 

enhance energy security; and to deploy low-carbon 

energy technologies and lay the foundation for a 

clean energy future. According to that plan, oil and 

natural gas supplies are integral to meeting national 

energy demand. For more information, please refer 

to The White House’s website (The White House, 

2014).

This plan also aligns with President Trump’s 

America First Energy Plan, which calls for energy 

policies that stimulate our economy, ensure our 

security, and protect our health. For more 

information, please refer to The White House’s 

website (The White House, 2017).

Center for 

Biological 

Diversity, Bold 

Louisiana, 

Gulf 

Restoration 

Network, 

Louisiana 

Bucket 

Brigade, 

Radical Arts

and Healing 

Collective

(CBD, BL, 

GRN, LBB, 

RAHC), 

Kristen 

Monsell, 

Staff Attorney

CBD, BL, GRN, 

LBB, RAHC-2 

BOEM’s Area-Wide Lease Sale Approach Violates 

OCSLA: As courts have made clear, OCSLA’s 

procedures for authorizing oil and gas activities on 

the OCS “are pyramidic in structure, proceeding from 

broad-based planning to an increasingly narrower 

focus as actual development grows more imminent.” 

Thus, the first stage—the fiveyear planning stage—

has “important practical and legal significance,” 

including its role as the basis for “future planning.” 

As such, Section 18(a) expressly requires BOEM to 

prepare a leasing program that consists “of a 

schedule of proposed lease sales indicating, as 

precisely as possible, the size, timing, and location of 

leasing activity.” But rather than “precisely” defining 

the location of lease sales, BOEM’s Proposed 

Program takes an area-wide approach that 

designates the entire Gulf of Mexico as the area 

eligible for lease sales. This area-wide lease sale 

approach is incompatible with OCSLA. Indeed, 

under this approach, BOEM is allowing the oil 

industry to determine which areas are explored and 

developed, thereby abdicating the agency’s 

The OCSLA provides the Congressional mandate 

for BOEM to make “available for expeditious and

orderly development, subject to environmental 

safeguards, in a manner which is consistent with the 

maintenance of competition and other national 

needs” the land of the Federal OCS. The Secretary 

of the Interior oversees the OCS oil and gas 

program and is required to balance orderly resource 

development with protection of the human, marine, 

and coastal environments while simultaneously 

ensuring that the public receives an equitable return 

for these resources and that free-market 

competition is maintained. It is during this nationallevel review that the location (GOM regionwide 

leasing) and timing of lease sales (number of lease 

sales per year) is set in the schedule of proposed 

lease sales. The Five-Year Program EIS analyzes 

the environmental impacts of the entire 10 lease 

sale program in the Gulf of Mexico. The regionallevel NEPA analysis covered in this Multisale EIS 

provides a regional-level analysis of the 

environmental impacts of a single proposed lease 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-179

Commenter Comment ID Comment Response

responsibility under OCSLA to direct oil activities and 

assure that they do not cause environmental harm. 

BOEM’s area-wide lease sale approach is 

particularly troubling considering that this approach 

has been cited as one of the problems in the offshore 

oil regime that led to the Deepwater Horizon oil spill. 

In response to the spill, President Obama 

established the National Commission on the BP 

Deepwater Horizon Oil Spill and Offshore Drilling 

(“Commission”) as an independent, nonpartisan 

entity charged with providing a thorough analysis of 

the causes of the disaster and recommending 

reforms for making offshore drilling safer. The 

Commission issued its final report in January 2011, 

in which it highlighted the need for a fundamentally 

different approach to management of offshore 

drilling. The Commission noted that the areawide 

approach favored industry at the cost of meaningful 

environmental analysis. According to the 

Commission: the disaster and recommending 

reforms for making offshore drilling safer. The 

Commission issued its final report in January 2011, 

in which it highlighted the need for a fundamentally 

different approach to management of offshore 

drilling. The Commission noted that the areawide 

approach favored industry at the cost of meaningful 

environmental analysis. According to the 

Commission: OCS lease sales cover such large 

geographic areas that meaningful NEPA review is 

difficult. A decision to dramatically increase the size 

of lease sales—known as area-wide leasing—was 

made over 20 years ago at the request of industry; it 

has necessitated environmental analyses of very 

large areas at the lease sale stage. For example, the 

Final Environmental Impact Statement for the 2007–

2012 multilease sales in the Gulf of Mexico covered 

more than 87 million acres, while the Final 

Environmental Impact Statement for Chukchi Sea 

sale in the Five-Year Program. Therefore, the 

analysis in this Multisale EIS evaluates a smaller 

action consistent with the OCSLA’s pyramidal 

structure. Pursuant to NEPA, this Multisale EIS 

analyzes a range of alternatives, but NEPA does not 

require carrying all alternatives considered through 

a full analysis of impacts. BOEM has ensured that a 

reasonable range of alternatives to a proposed 

action, within the framework of the Five-Year 

Program, has been considered in this Multisale EIS. 

Chapter 2.2.3 discusses additional alternatives 

considered but eliminated them based on the best 

available information currently available. As noted 

in Chapter 1.3.1.2, any individual lease sale could 

still be scaled back during the prelease sale process 

to offer a smaller area should circumstances 

warrant. Additionally, the issuance of leases does 

not conclude the environmental analysis of planned 

OCS oil- and gas-related activities. Each plan 

throughout the exploration, production, and 

decommissioning processes receives a site-specific 

environmental analysis pursuant to NEPA and the 

OCSLA’s pyramidal structure going from large scale 

to site specific. For more information on BOEM’s 

postlease processes, please refer to Appendix A. 

As suggested in the Commission’s final report, 

BOEM (along with BSEE) has implemented many 

fundamental changes to improve the management 

of offshore leasing and drilling. Some of the 

changes made since 2010 include the following:

an Investigations and Review Unit was instituted to 

root out problems within the regulatory agencies 

and target companies that aim to game the system;

BOEM created multiple Implementation Teams, 

tasked with analyzing various aspects of BOEM’s 

regulatory structure and helping to implement the 

reform agenda; BOEM implemented a recusal policy 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-180 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Lease Sale 193 covered about 34 million acres. 

Given that 2008 lease sales in the Central Gulf of 

Mexico and the Chukchi Sea attracted almost 

$3.7 billion and almost $2.7 billion in high bids, 

respectively, it is appropriate to conduct 

environmental reviews on a finer geographic scale 

before private-sector commitments of this magnitude 

are made to purchase leases. However, BOEM’s 

current proposal does just the opposite. In fact, it 

backslides from prior programs with respect to lease 

sales in the Gulf of Mexico. While previous programs 

have established lease sales based on the three 

separate planning areas—the Western Gulf, the 

Central Gulf and the Eastern Gulf—BOEM is now 

proposing to hold two lease sales per year in 

unleased portions of the “Gulf of Mexico.” But the 

Gulf of Mexico contains nearly 160 million acres, 

more than 70 million of which are currently unleased 

and available for lease under BOEM’s proposal. The 

Gulf also contains a great diversity of environmental 

and socioeconomic characteristics. For example, as 

BOEM has repeatedly admitted, the separate regions 

in the Gulf of Mexico have distinct ecological 

features. The Western Region “hosts the 

northernmost tropical coral reef system in the United 

States at the Flower Garden Banks, an isolated 

system of predominately encrusting corals atop salt 

dome formations.” The system attracts reef fishes 

and large open-water species such as hammerhead 

and whale sharks. The Western Region is also 

“home to some of the most important nesting sites for 

the endangered Kemp’s ridley sea turtle.” The 

Central Region is home to a resident population of 

endangered sperm whales, and the Eastern Region 

includes manatee habitat. And the Louisiana 

coastline contains a variety of wetlands that make up 

one of the largest deltas in the world. Moreover the 

line between the Western and Central Region and 

for employees to deal with real and perceived 

conflicts of interest; and Secretary Salazar and 

Director Bromwich launched a full review of the use 

of NEPA, categorical exclusions, during which they 

are not being used to approve proposed deepwater 

drilling projects.

BOEM places a significant emphasis on public input 

and scientific analysis, which are critical to safe 

exploration and development of offshore resources. 

Public comment is solicited in our environmental 

review programs for both oil and gas and renewable 

energy proposals. Plans submitted by industry are 

subject to rigorous scientific review to ensure that 

environmental safeguards are the foundation of all 

offshore energy development.

A brief summary of the reforms within BOEM and 

BSEE since the Deepwater Horizon explosion, oil 

spill, and response can be found on BOEM’s 

website at https://www.boem.gov/RegulatoryReform/. BOEM and BSEE will remain vigilant in 

instituting reform efforts and lessons learned since 

the Deepwater Horizon explosion, oil spill, and 

response.

Mitigating measures are an integral part of BOEM’s 

program to ensure that postlease operations are 

conducted in an environmentally sound manner 

(with an emphasis on minimizing any adverse 

impact of routine activities on the environment). 

BOEM assigns site-specific mitigation by imposing 

conditions of approval on a plan, permit, or 

authorization. Appendix A discusses BOEM’s 

rigorous postlease process, and Appendix B

describes over 120 standard mitigations that may be 

required by BOEM or BSEE as a result of the plan 

and permit review processes for the Gulf of Mexico 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-181

Commenter Comment ID Comment Response

the Eastern Region follows the De Soto Canyon off 

the coast of Alabama and traces the eastern edge of 

the Loop Current, which effectively divides the Gulf. 

In other word’s the Gulf’s size and variation clearly 

requires greater specificity in the size and location of 

lease sales. BOEM states in its Draft EIS that the 

agency is proposing an area-wide approach to 

provide greater flexibility to industry and balance 

agency workload. However, BOEM does not have 

“carte blanche to wholly disregard a statutory 

requirement out of convenience.” Nor can it abdicate 

its statutory duties under OCSLA or NEPA to 

appease industry. The designation lacks the 

precision required by the statute and is therefore 

unlawful. Moreover, in its Draft EIS, BOEM states 

that it will no longer conduct a supplemental EIS for 

each lease sale in the Gulf of Mexico. Instead, 

BOEM says it will supplemental its Multisale EIS 

once per calendar year. According to BOEM, this 

approach is necessary because the short-time frame 

between lease sales proposed from 2017 to 2022 

does not provide sufficient time to prepare an EIS. 

But this is a product of the agency’s own making. 

There is absolutely no reason BOEM must hold 

multiple lease sales per year. Indeed, BOEM’s new 

approach appears to violate its duties under OCSLA 

to comply with NEPA and the Endangered Species 

Act (“ESA”) at every stage of the offshore oil and gas 

authorization process and its duty to ensure offshore 

developments is balanced with environmental 

safeguards and protection of the human, marine, and 

coastal environments. BOEM’s new approach also 

directly contradicts the Commission’s express 

recommendations that BOEM conduct environmental 

reviews on a finer geographic scale.

OCS Region.

Center for 

Biological 

Diversity, Bold 

CBD, BL, GRN, 

LBB, RAHC-3 

BOEM’s purpose and need statement fails to comply 

with NEPA: NEPA’s implementing regulations 

provide that an EIS should “specify the underlying 

The text in Chapter 1.1 has been clarified to state 

“. . . in accordance with OCSLA, which specifically 

states ‘should be made available for expeditious 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-182 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Louisiana, 

Gulf 

Restoration 

Network, 

Louisiana 

Bucket 

Brigade, 

Radical Arts 

and Healing 

Collective

(CBD, BL, 

GRN, LBB, 

RAHC), 

Kristen 

Monsell, 

Staff Attorney

purpose and need to which the agency is responding 

in proposing the alternatives including the proposed 

action.” This purpose and need inquiry is crucial for

a sufficient environmental analysis because “[t]he 

stated goal of a project necessarily dictates the range 

of ‘reasonable’ alternatives.” Thus, “an agency 

cannot define its objectives in unreasonably narrow 

terms” without violating NEPA. BOEM’s stated 

purpose and need for its proposal is “to offer for 

lease those areas that may contain economically 

recoverable oil and gas resources” in order to 

manage the development of oil and gas resources on 

the OCS. This purpose and need is too narrow and 

thus inadequate because BOEM necessarily 

considered an unreasonably narrow range of 

alternatives. By framing its statement as needing to 

auction off areas of the OCS that might contain 

recoverable oil and gas, BOEM necessarily makes 

auctioning off all of the Gulf of Mexico not under 

moratorium, i.e., the proposed alternative, the only 

way to meet such a need. But OCSLA charges the 

Bureau with ensuring that “environmental 

safeguards” are in place for offshore oil development 

and ensuring the “balance [of] orderly energy 

resource development with protection of the human, 

marine, and coastal environments” and “national 

needs.” Accordingly, BOEM should have focused its 

purpose and need inquiry on objectives that comport 

with these statutory duties. This is particularly true 

considering that BOEM has already leased more 

than 22 million acres of the Gulf of Mexico to oil 

companies, and U.S. commitments to limit 

greenhouse gas emissions to help prevent the most 

catastrophic impacts of climate change.

Moreover, NEPA evaluation must take place “before 

decisions are made.” Such an approach ensures 

that agencies will take the requisite “hard look” at 

and orderly development, subject to environmental 

safeguards.’” The alternatives in this Multisale EIS 

provide a reasonable range of alternatives that 

provide environmental safeguards, including 

alternatives and mitigations that can be included at 

the site-specific decision level.

As required by the Five-Year Program, 10 individual 

phased decisions on whether and/or how to proceed 

with each proposed lease sale will be made. So 

while the obligation to fully comply with NEPA does 

not mature until leases are issued (Center for 

Biological Diversity v. U.S. Department of the 

Interior, 2009; Center for Sustainable Economy v. 

Sally Jewell, 2015), BOEM has chosen to prepare 

an EIS at this stage to analyze the potential 

environmental impacts that could result if 

exploration, development, production, and 

decommissioning activities eventually occur in order 

to provide the context and setting of future proposed 

actions and to better understand the potential 

impacts associated with these types of activities, as 

well as the cumulative impacts on GOM resources. 

This programmatic approach to this Multisale EIS 

allows more time to include more public 

involvement, evaluate potential impacts, and 

provide for a more informed decision, which in turn 

allows site-specific reviews to tier from this Multisale 

EIS and be more streamlined.

Because of these multiple and tiered programmatic 

documents, along with future site-specific reviews 

that tier to these programmatic and discretionary 

documents, BOEM has taken a hard look at the 

potential for environmental consequences at each 

phase of the decisionmaking process that considers 

a proposed action in the GOM. At each phase, 

BOEM has identified numerous environmental 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). Responses to Public Comments on the Draft Multisale EIS L-183

Commenter Comment ID Comment Response

environmental consequences before approving any 

major federal action. But BOEM’s purpose and need 

statement indicates that it did just the opposite. In 

other words, the statement demonstrates that BOEM 

already made the decision hold offshore oil and gas 

leases across all of the Gulf of Mexico and that its 

entire analysis was framed in a way to support that 

pre-determined outcome. BOEM’s backward 

approach reflects a fundamental misunderstanding of 

its legal obligations and an apparent desire to 

appease the oil industry at the expense of our ocean 

environment and climate.

safeguards to minimize the impacts, i.e., through the 

consideration of EISs and programmatic mitigation 

at the Five-Year Program level, consideration of 

alternatives to limit sensitive topographic features in 

this Multisale EIS, and commonly applied mitigation 

measures.

Center for 

Biological 

Diversity, Bold 

Louisiana, 

Gulf 

Restoration 

Network, 

Louisiana 

Bucket 

Brigade, 

Radical Arts 

and Healing 

Collective

(CBD, BL, 

GRN, LBB, 

RAHC), 

Kristen 

Monsell, 

Staff Attorney

CBD, BL, GRN, 

LBB, RAHC-14

BOEM Should Not Propose Additional Lease Sales 

Until it Completes Section 7 Consultation under the 

ESA: BOEM should complete consultation under the 

ESA before proposing new lease sales. In enacting 

the ESA, Congress recognized that certain species 

“have been so depleted in numbers that they are in 

danger of or threatened with extinction.” Accordingly, 

a primary purpose of the ESA is “to provide a means 

whereby the ecosystems upon which endangered 

species and threatened species depend may be 

conserved, [and] to provide a program for the 

conservation of such . . . species.” To reach these 

goals, Section 9 of the ESA prohibits any person, 

including any federal agency, from “taking” any 

endangered species without proper authorization 

through a valid incidental take permit. The term 

“take” is statutorily defined broadly as “to harass, 

harm, pursue, hunt, shoot, wound, kill, trap, capture, 

or collect, or to attempt to engage in any such 

conduct.” The definition of “harm” has been defined 

broadly by regulation as “an act which actually kills or 

injures wildlife. Such act may include significant 

habitat modification or degradation where it actually 

kills or injures wildlife by significantly impairing 

essential behavioral patterns, including breeding, 

feeding or sheltering.” Courts have found federal 

BOEM and BSEE have submitted Biological 

Assessments to NMFS and FWS, and are actively 

engaged with them in consultation concerning all of 

our past and reasonably foreseeable future 

activities. Until the above-mentioned NMFS’ formal 

consultation is complete, BOEM is under an interim 

consultation agreement with NMFS. . The NMFS 

and FWS understand the types and levels of 

activities that BOEM is engaged in and have not 

raised concerns with our ongoing activities. They 

are fully informed of the potential impacts identified 

in this Multisale EIS as well as in the Biological 

Assessments. The Protected Species Stipulation, if 

applied, would require already existing terms and 

conditions and mitigations implemented to protect 

species at the lease sale stage. As the stipulation 

notes, BOEM and BSEE can condition approval of 

any postlease authorization or permit on compliance 

with the most current mitigations or requirements to 

protected listed species or habitats at the time. The 

staged OCSLA decisionmaking and approval 

process ensures that BOEM and BSEE can require 

additional protected species protections after leases

are issued.

Refer to Chapter 5.8 for more information on the 
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

L-184 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

agencies liable for take of listed species where 

agency-authorized activities resulted in the killing or 

harming of ESA-listed species. Additionally, Section 

7(a)(2) of the ESA requires federal agencies to 

“insure that any action authorized, funded, or carried 

out by such agency . . . is not likely to jeopardize the 

continued existence of any [listed] species or result in 

the destruction or adverse modification of [the critical] 

habitat of such species.” “Action” is broadly defined 

to include “all activities or programs of any kind 

authorized, funded, or carried out, in whole or in part” 

by federal agencies and include granting permits and 

licenses, as well as actions that may directly or 

indirectly cause modifications to the land, water, or 

air. To facilitate compliance with Section 7(a)(2), an 

“agency shall . . . request” from the National Marine 

Fisheries Service and the U.S. Fish and Wildlife 

Service (the Services”) information regarding 

whether any listed species “may be present” in a 

proposed action area, and if so, the “agency shall 

conduct a biological assessment” to identify species 

likely to be affected. The agency must then initiate 

formal consultation with the Services if a proposed 

action “may affect” any of those listed species. After 

formal consultation, the Services issue a biological 

opinion to determine whether the agency action is 

likely to jeopardize” any species’ existence. If so, the 

opinion may specify reasonable and prudent 

alternatives that avoid jeopardy. If the Services 

conclude that the action or the reasonable and 

prudent alternatives will not cause jeopardy, the 

Services will issue an incidental take statement 

(“ITS”) that specifies “the impact, i.e., the amount or 

extent, of . . . incidental taking” that may occur. 

When those listed species are marine mammals, the 

take must first be authorized pursuant to the MMPA, 

and the ITS must include any additional measures 

necessary to comply with the MMPA take 

ESA consultations.
Table L-1. Public 

Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-185

Commenter Comment ID Comment Response

authorization. The take of a listed species in 

compliance with the terms of a valid ITS is not 

prohibited under Section 9 of the ESA. But an 

agency’s consultation duties do not end with the 

issuance of a biological opinion. Instead, an agency 

must reinitiate consultation when: (1) the amount of 

take specified in the ITS is exceeded; (2) new 

information reveals that the action may have effects 

not previously considered; or (3) the action is 

modified in a way not previously considered. Finally, 

after consultation is reinitiated, ESA Section 7(d) 

prohibits the agency from “mak[ing] any irreversible 

or irretrievable commitment of resources” toward a 

project that would “foreclos[e] the formulation or 

implementation of any reasonable and prudent 

alternative measures.” The 7(d) prohibition “is in 

force during the consultation process and continues 

until the requirements of section 7(a)(2) are 

satisfied.” As recognized in BOEM’s Draft EIS, 

several federally threatened and endangered species 

are found in the Gulf of Mexico and may be impacted 

by its leasing proposal; the proposal also impacts 

critical habitat for ESA-listed species. Thus, Section 

7 of the ESA is clearly triggered. While BOEM 

engaged in Section 7 consultation on its Five-Year 

Program for offshore oil and gas leasing in the Gulf of Mexico from 2007-2012, and reinitiated Section 7 

consultation following the Deepwater Horizon oil spill, 

it has not yet completed such consultation. Instead, 

BOEM is relying on a biological opinion issued by the 

National Marine Fisheries Service in 2007 that fails to 

consider the impacts of climate change and does not 

any impacts of offshore oil and gas activities on 

several ESA-listed species or their critical habitat in 

the Gulf of Mexico. Accordingly, BOEM should not 

propose further lease sales and should suspend 

approval of leasing and site-specific drilling activities 

until consultation is complete. Such action is 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-186 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

necessary to ensure that its actions do not result in 

the unauthorized take of listed species, do not 

jeopardize listed species or their critical habitat, and 

that such approvals do not “foreclos[e] the 

formulation or implementation of any reasonable and 

prudent alternative measures.”

Lone Star 

Chapter of the 

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

LSCSC-14 BOEM says the purpose and need of its analysis is 

to offer oil and gas lease sales so that oil and gas 

resources on the OCS can be developed. But the 

law clearly requires BOEM to analyze the impacts of 

dirty, dangerous offshore drilling on the Gulf’s 

ecosystem, coastal communities and our climate 

before deciding whether to allow them, not the other 

way around. BOEM’s backward approach reflects a 

fundamental misunderstanding of its legal obligations 

and an apparent desire to appease the oil industry at 

the expense of our ocean environment and climate.

The purpose and need statement in Chapter 1 has 

been clarified to state the following: The purpose of 

the proposed Federal actions in this Multisale EIS is 

to offer for lease those areas that may contain 

economically recoverable oil and gas resources in 

accordance with the OCSLA, which specifically 

states “should be made available for expeditious 

and orderly development, subject to environmental 

safeguards” (OCSLA, 43 U.S.C. §§ 1331 et seq.).

Please refer to the response to Comment CBD, BL, 

GRN, LBB, RAHC-3 for more information about 

BOEM’s staged decisionmaking process in 

Chapter 1.

United States 

Environmental 

Protection 

Agency

USEPA-15 Executive Order 13175, Consultation and 

Coordination with Indian Tribal Governments (65 FR 

67249; November 6, 2000), requires regular and 

meaningful consultation and collaboration with tribal 

officials in the development of federal policies that 

have tribal implications, and to strengthen the United 

States government-to-government relationships with 

Indian tribes. The DEIS states the analyzed 

environmental justice issues for minority and low 

income populations is broadly applicable to federally 

recognized Indian Tribes. Further, it states there is 

ongoing discussions with designated Tribal 

representatives.

Recommendation:

EPA recommends the FEIS include updated and 

completed descriptions of consultation and 

BOEM initiated the Section 106 and Tribal 

consultation processes and a request for comment 

on the NOI for this Multisale EIS via a formal letter 

to each of the affected Gulf Coast States on April 3, 

2015, and to each of the Gulf Coast State-affiliated 

federally recognized Indian Tribes, including the 

Alabama-Coushatta Tribe of Texas, Caddo Nation 

of Oklahoma, Chitimacha Tribe of Louisiana, 

Choctaw Nation of Oklahoma, Coushatta Tribe of 

Louisiana, Jena Band of Choctaw Indians, 

Miccosukee Tribe of Indians of Florida, Mississippi 

Band of Choctaw Indians, Poarch Band of Creek 

Indians, Seminole Tribe of Florida, Seminole Nation 

of Oklahoma, and Tunica-Biloxi Indian Tribe of 

Louisiana. The State Historic Preservation Officers 

for Alabama, Florida, and Louisiana responded via 

formal letters, all concurring that no historic 

properties will be affected. The Florida State 

Historic Preservation Officer further requested to be 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-187

Commenter Comment ID Comment Response

coordination activities, including correspondence to 

and from Tribal governments and other consultationrelated documents. These documents would 

demonstrate fulfillment of Tribal consultation duties 

by the lead agencies and Tribal government 

engagement.

notified and given the opportunity to comment 

should any cultural resources be identified off the 

Florida coast. No additional responses were 

received. Copies of the received letters can be 

found in Appendix K. 

Topic 10 – Other

Center for 

Biological 

Diversity, Bold 

Louisiana, 

Gulf 

Restoration 

Network, 

Louisiana 

Bucket 

Brigade, 

Radical Arts 

and Healing 

Collective

(CBD, BL, 

GRN, LBB, 

RAHC), 

Kristen 

Monsell, 

Staff Attorney

CBD, BL, GRN, 

LBB, RAHC-1 

BOEM’s proposal to lease over 70 million acres of 

the Gulf of Mexico so that oil and gas companies can 

drill up to 9.5 billion barrels of oil equivalent over the 

next 70 years will deepen the climate crisis and 

reverse course on President Obama’s commitment to 

combat climate change. We therefore urge BOEM to 

halt all new oil and gas lease sales in federal waters 

and keep these dirty fossil fuels in the ground.

The OCSLA provides the Congressional mandate 

for BOEM to make “available for expeditious and 

orderly development, subject to environmental 

safeguards, in a manner which is consistent with the 

maintenance of competition and other national 

needs” the land of the Federal OCS. The proposed 

Federal action is to offer for lease those areas that 

may contain economically recoverable oil and gas 

resources in accordance with the OCSLA (67 Stat. 

462), as amended (43 U.S.C §§ 1331 et seq.). The 

decision on whether and how to proceed with each 

proposed lease sale is under the authority of the 

Assistant Secretary for Land and Minerals 

Management and will be disclosed in the Record of 

Decision following publication of this Final Multisale 

EIS.

According to the President’s All-of-the-Above 

Energy Strategy (The White House, 2014), oil and 

natural gas supplies are integral to meeting the 

national energy demand.

This plan also aligns with President Trump’s 

America First Energy Plan, which calls for energy 

policies that stimulate our economy, ensure our 

security, and protect our health. For more 

information, please refer to The White House’s 

website (The White House, 2017). 

Oil from the Gulf of Mexico OCS contributes to 

No New 

Leases Form 

Letter

NNL-1 I am writing to urge you to halt all new oil and gas 

lease sales in federal waters and keep these fossil 

fuels where they belong safely in the ground. The 

Bureau of Ocean Energy Management's proposal to 

lease more than 70 million acres in the Gulf of 

Mexico is absurd. Oil and gas companies would be 

allowed to drill our ocean for the next 70 years 

deepening the climate crisis and reversing course on 

President Obama's commitments to address this 

global problem.

Robert RDS-1 The Bureau of OCEAN ENERGY MANAGEMENT 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-188 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Desmarais 

Sullivan

has obligations to the citizens of the United States to 

find alternative ways of managing energy from the 

oceans. Fossil fuels have to end, as do any fuels that 

produce carbon dioxide and methane. That was the 

agreement in Paris in December of 2015. On Earth 

Day of 2016, The US signed the agreement. In this 

another meaningless US treaty like the many signed 

with Native peoples or will the US respect this one, in 

view of the fact the ignoring it could actually destroy 

the US in a fiery climate change. I believe BOEM as

a responsible federal agency can play an active role 

in directing the answers.

meeting domestic demand and enhances national 

economic security. Although peak OCS production 

may not occur until some point in the future, oil and 

gas production is still necessary to bridge to a 

balanced, or even different, energy future. Over the 

next 20 years, the U.S. Dept. of Energy’s Energy 

Information Administration expects the U.S. to rely 

on more oil and natural gas to meet its energy 

demands, even as alternative sources of energy 

provide an increasing share of U.S. energy needs. 

Since the U.S. is expected to continue to rely on oil 

and natural gas to meet its energy needs, a 

proposed action would contribute to meeting 

domestic demand. The OCS is a major long-term 

supplier of crude oil and natural gas, and the Gulf of 

Mexico OCS region has the greatest resource 

potential of the four OCS regions in the United 

States.

Susan 

Feathers

SF-3 Finally, I wish there were NO MORE LEASE SALES, 

and as agency formed to transition to alternative, 

clean fuel or energy generation, at high speed. With 

the [CO2] rising steadily, it seems risky to keep 

pursuing fossil fuels – sometime, we have to make 

the commitment to clean energy.

Lone Star 

Chapter of the 

Sierra Club

(LSCSC),

Cyrus Reed, 

Conservation 

Director

LSCSC-1 First of all, we were appreciative of the decision by 

the Obama Administration to remove future leasing 

and drilling for the 2017-2022 for the Atlantic Region, 

and some areas within the Arctic that were originally 

considered as part of the overall plan for ocean 

drilling.

Thank you for your comment.

American 

Petroleum 

Institute (API),

Andy Radford

API-1 Consistent with previous Five-year Program EIS 

efforts, the GOM Multisale EIS should be designed to 

serve as a document for future environmental 

reviews in the Gulf in compliance with the NEPA, its 

implementing regulations, and BOEM guidance. 

Future near-term environmental reviews should be 

able to tier off the analysis conducted in the EIS so 

the EIS should be designed specifically with the idea 

of it being used as a reference for future NEPA 

analysis. This tiering approach will make the best 

use of BOEM resources.

Thank you for your comment. Please refer to 

Chapter 1.3 for more information on the Bureau of 

Ocean Energy Management’s OCS oil and gas 

program’s planning and decision process.
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-189

Commenter Comment ID Comment Response

American 

Petroleum 

Institute (API),

Andy Radford

API-4 In closing, the American Petroleum Institute is 

pleased that the BOEM is performing this Multisale 

EIS so that the NEPA documents can remain current 

throughout the 2017-2022 Five-year Program. We 

urge BOEM to continue the process of updating 

NEPA analyses to ensure the most current science is 

being used in the decision making process.

Thank you for your comment. BOEM’s Gulf of 

Mexico OCS Region is planning to produce 

supplemental EISs for each calendar year of the 

2017-2022 Five Year Program, and each lease sale 

decision will have an accompanying NEPA 

document. Please refer to Chapter 1.3 for more 

information on the Bureau of Ocean Energy 

Management’s OCS oil and gas program’s planning 

and decision process.

Consumer 

Energy 

Alliance

(CEA),

Brent 

Greenfield

CEA-3 On behalf of energy consumers across Texas, the 

Gulf Coast region, and the entire nation, Consumer 

Energy Alliance urges the Interior Department to 

ensure that all Americans are able to affordably heat 

their homes and feed their children. An "all of the 

above" approach to energy policy is the only sensible 

solution, and that must include the Gulf of Mexico.

Thank you for your comment. BOEM is working 

under President Obama's All-of-the-Above Energy 

Strategy, which has three main goals: to support 

economic growth and job creation; to enhance 

energy security; and to deploy low-carbon energy 

technologies and lay the foundation for a clean 

energy future. More information on President 

Obama’s All-of-the-Above Energy Strategy can be 

found on the White House’s website (The White 

House, 2014). 

This plan also aligns with President Trump’s 

America First Energy Plan, which calls for energy 

policies that stimulate our economy, ensure our 

security, and protect our health. For more 

information, please refer to The White House’s 

website (The White House, 2017). 

The decision on whether and how to proceed with 

each proposed lease sale is under the authority of 

the Assistant Secretary for Land and Minerals 

Management and will be disclosed in the Record of 

Decision following publication of this Final Multisale 

EIS.

Consumer 

Energy 

Alliance

(CEA),

Brent 

Greenfield

CEA-4 That is why we urge the Interior Department to 

include valuable offshore opportunities in the Gulf of 

Mexico, finalize a Multisale EIS that allows Gulf lease 

sales to proceed without any further exclusions or 

restrictions, and reject any demands to take actions 

that would in any way delay, restrict, or prohibit 2017-

2022 lease sales in the Gulf of Mexico.

The Ehrhardt 

Group, Caitlin 

Switzer

EG-1 Lease sales are not about today, but rather, the 

future. Oil and gas exploration and cultivation are 

critical to our future. I support the current preferred 

proposal for lease sales in the Gulf of Mexico. 

Exploration must continue in the Western and 

Central blocks of the Gulf of Mexico. We must 

continue allowing energy companies to further 

develop their practices, perfecting their operationsgetting cleaner, and more efficient than they already 

are.

Susan 

Feathers

SF-1 I am impressed with the process BOEM has 

established to determine relative risk of oil & gas 

exploration to marine resources and ecosystems. 

The fact that B.O.E.M. is its own separate agency is 

Thank you for your comment.
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-190 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

a good thing to remove the influences of conflicting 

interests to protection of waters and wildlife and 

human communities.

Hilton Kelley HK-1 One of the things that we would like to see as a total 

halt on oil drilling in the Gulf of Mexico due to the fact 

it's been overburdened already and there are more 

than 3,400 oil rigs out there already and some of 

them are abandoned and some of them are leaking.

As of 2013, active platforms were estimated at 

approximately 2,634 (USDOI, BSEE, 2015; Chapter 

3.3.1.5 and Figure 3-14). A review of spill data 

reported to both USCG and BSEE indicates there 

are no reports of abandoned wells and platforms 

that are currently leaking. Additional information 

regarding this issue has been incorporated into this 

Final Multisale EIS.

All of the current terms and conditions of structure 

and well-removal activities are outlined in NTL 

2010-G05, “Decommissioning Guidance for Wells 

and Platforms,” which became effective on 

October 15, 2010. Any infrastructure that is 

decommissioned and no longer “economically 

viable,” severely damaged, or idle on active leases 

is considered “idle iron” according to NTL 2010-

G05, “Decommissioning Guidance for Wells and 

Platforms.” The BSEE’s idle iron policy keeps 

inactive facilities and structures from littering the 

Gulf of Mexico by requiring companies to dismantle 

and responsibly dispose of infrastructure after they 

plug nonproducing wells.

Operators are required to either (a) remove seafloor 

obstructions from a lease within 1 year of lease 

termination or after a structure has been deemed 

obsolete or unusable or (b) obtain an exemption 

such as those authorized in Section 388 of the 

Environmental Protection Act. Section 388 clarifies 

the Secretary’s authority to allow an offshore oil and 

gas structure, previously permitted under the 

OCSLA, to remain in place after OCS oil- and gasrelated activities have ceased in order to allow the 

use of the structure for other energy- and marine-
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-191

Commenter Comment ID Comment Response

related activities.

Hilton Kelley HK-3 So, we think that the Gulf of Mexico needs an 

opportunity to heal itself and, also, to sort of 

replenish some of the wildlife that was there, maybe 

like 30, 40 years ago, before all the oil spills started 

happening along the Gulf.

BOEM considered an alternative to delay leasing 

and determined that it did not warrant full analysis in

this Multisale EIS. More information on why this 

alternative was eliminated from further analysis is 

provided in Chapter 2.2.3. 

Cancelling all future lease sales and all activities 

under existing lease sales is not before the agency 

with this decision and is outside the scope of this 

Multisale EIS. To the extent that you are requesting 

cancellation of this proposed lease sale, we 

acknowledge your preference for Alternative E.

Louisiana MidContinent Oil 

and Gas 

Association

(LAMOGA),

Melissa 

Cloutet

LAMOGA-1 LAMOGA fully supports a continued robust OCS 

leasing program in the Gulf of Mexico, and we 

support Alternative A proposed action of the Draft 

EIS.

Thank you for your comment. The Secretary of the 

Interior oversees the OCS oil and gas program and 

is required to balance orderly resource development 

with protection of the human, marine, and coastal 

environments while simultaneously ensuring that the 

public receives an equitable return for these 

resources and that free-market competition is 

maintained. The decision on whether and how to 

proceed with each proposed lease sale is under the 

authority of the Assistant Secretary for Land and 

Minerals Management and will be disclosed in the 

Record of Decision following the publication of this 

Final Multisale EIS.

Louisiana MidContinent Oil 

and Gas 

Association

(LAMOGA),

Melissa 

Cloutet

LAMOGA-2 For the benefit of the nation, LAMOGA respectfully 

requests that BOEM continue to provide leasing 

opportunities in the Gulf of Mexico as well as expand 

to other OCS areas, including the Eastern Gulf of 

Mexico.

Thank you for your comment. Currently, much of 

the EPA is deferred from leasing by the Gulf of 

Mexico Energy Security Act of 2006 and cannot be 

offered for lease in this Five-Year Program. Please 

refer to the OCS Regulatory Framework white paper 

for more information on GOMESA (Cameron and 

Matthews, 2016).

Renate 

Heurich

RH-1 And President Obama, in Paris, agreed and signed 

the Accord where the goal is not just a limit of 2 

degrees Celsius, but 1.5 if possible. In order to 

achieve that, we cannot drill for more oil or gas in the 

BOEM recognizes the importance of climate change 

in its NEPA analyses and considers many facets of 

the potential effects of climate change in its 

decisionmaking with respect to oil and gas leasing, 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-192 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Gulf. It's just the opposite of what we should be 

doing. We should look for renewable sources of 

energy in the ocean. Other countries are able to do 

it; we should absolutely be able to do it to the Gulf. 

There is the possibility to build wind turbines. Those 

devices get more and more efficient all of the time.

They also get cheaper. We already have -- we could 

put cables through the pipelines that are running 

already from rigs onshore, so we could try to use the 

infrastructures already there.

whether in the Five-Year Program or lease sale 

analyses. In the Five-Year Program EIS, BOEM 

compares greenhouse gas emissions from direct 

OCS emissions to those that could occur from 

energy substitutes that would presumably replace 

OCS production in the absence of a new OCS 

Program and comparable demand levels. 

Downstream greenhouse gases have been 

quantified. Please refer to the Five-Year Program 

EIS and to Chapter 4.1 (Air Quality) of this Final

Multisale EIS for additional information about how 

BOEM evaluates greenhouse gas emissions and 

climate change. BOEM expects that reducing OCS 

oil and gas consumption in the U.S. and the 

associated emissions from limiting OCS leasing 

would largely be offset by substitutes from other 

energy sources, either within the United States or 

elsewhere. BOEM has considered a no action 

alternative (i.e., cancellation of a proposed lease 

sale); however, that does not necessarily equate to 

zero downstream greenhouse gas emissions from 

oil and gas unless energy demand or supply 

changes drastically or cost-competitive clean energy 

sources are substituted.

BOEM also has jurisdiction over renewable energy 

on the OCS, but this is an oil and gas leasing 

decision required to be considered under the 

OCSLA and the Five-Year Program. Therefore, 

renewable energy leasing is outside of the scope of 

this Multisale EIS.

This Multisale EIS tiers from the Five-Year Program 

EIS and has included a summary of the information

in Chapter 4.0.

Yolanda 

Ferguson

YF-2 You know, do you charge every year for a fee for 

them to be out there for like – for the wells that you 

have? You -- they've already bid on the wells and 

Thank you for your comment. The OCSLA grants 

the Secretary of the Interior the authority to issue 

leases on the OCS. Section 18(a)(4) of the OCSLA 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-193

Commenter Comment ID Comment Response

they won the leases. Do you all charge for the 

leases every year?

states that "Leasing activities shall be conducted to 

assure receipt of fair market value for the lands 

leased and the rights conveyed by the Federal 

Government." Lessees pay bonuses, rentals, and 

royalties reflecting the value of the rights to explore 

and potentially develop and produce OCS oil and 

gas resources. BOEM sets minimum bid levels, 

rental rates, and royalty rates by individual lease 

sale based on its assessment of market and 

resource conditions as the proposed lease sale 

approaches.

When the lease is acquired, a bonus bid is paid. 

The bonus bid is the winning highest dollar amount 

paid at the time of the lease sale. This acquisition 

cost reflects the opportunity cost of exploring and 

producing those mineral resources. During the 

initial term of a lease and before royalty on 

production is paid, the lessee pays annual rentals in 

an amount prescribed in the Final Notice of Sale. 

Rentals reflect the holding cost of the lease during 

the initial term prior to production in paying 

quantities. In recent lease sales, BOEM has 

imposed rentals that escalate over time to 

encourage faster exploration and development of 

leases. The Government receives a royalty 

payment once production starts. The royalty rate is 

a percentage of production. The royalty rate is used 

to calculate the royalty payment, i.e., the dollar 

amount paid based on the value of the amount of 

production. Under certain conditions, the royalty 

payment might be temporarily waived. Known as 

royalty relief, this generally occurs when an 

economic incentive is needed to spur additional 

production, such as in a frontier area or deeper 

water depth. Price thresholds or triggers suspend 

royalty payments if market prices are low but do not 

suspend royalty payments if market prices are high. 
Table L-1. Public Comments and BOEM’s Response Matrix (continued). L-194 Gulf of Mexico Multisale EIS

Commenter Comment ID Comment Response

Price thresholds provide an incentive when 

production might not otherwise occur. Additionally, 

they provide protection when market prices are high 

and the incentive is no longer needed.

Revenues from OCS leases consist of bonuses, 

royalties, and rentals and are collected by ONRR. 

These revenues are shared with coastal states, as 

directed by statute, and the remaining funds are 

deposited in the U.S. Treasury. The OCS revenues 

provide annual deposits of nearly $900 million to the 

Land and Water Conservation Fund and 

$150 million to the Historical Preservation Fund. By 

statute, coastal states share a portion of the 

revenues from OCS leasing and production under 

three programs: (1) the OCSLA’s Section 8(g) 

revenue sharing program that provides states with 

offshore Federal leases located within the first 3 mi 

(5 km) of the State’s seaward boundary receive 

27 percent of the revenue generated from those 

leases; (2) the Coastal Impact Assistance Program 

(CIAP) for Alaska, Alabama, California, Louisiana,

Mississippi, and Texas; and (3) the Gulf of Mexico 

Energy Security Act (GOMESA) for Alabama, 

Louisiana, Mississippi, and Texas.

For more information on OCS oil and gas leasing, 

please refer to BOEM’s leasing fact sheet (USDOI, 

BOEM, 2016c).

John Young JY-2 Have the Environmental Defense Center and 

Surfrider Foundation objections to the draft 

Programmatic Environmental Assessment of these 

agencies been evaluated and incorporated into the 

assessment? [See "Flaws in Government's Analysis 

of Offshore Fracking and Acidizing Exposed by 

Environmental Groups," Environmental Defense 

Center, 03·23·2016, Santa Barbara Independent. 

http:l/www.independent.com/pr/ 2016/mar/23/flawsWell stimulation activities and potential impacts 

differ greatly between the Pacific and Gulf of Mexico 

OCS due to a variety of factors (e.g., different 

reservoir properties and different affected 

environment); therefore, BOEM has analyzed the 

use and potential impacts from these activities 

specifically for the Gulf of Mexico OCS in this 

Multisale EIS. The primary impact-producing factor 

of concern related to well stimulation activities in the 
Table L-1. Public Comments and BOEM’s Response Matrix (continued).

Responses to Public Comments on the Draft Multisale EIS L-195

Commenter Comment ID Comment Response

governments-analysis-offshore-fracking-and-a/J

If so. let us know. If not, give us an update and a 

chance to join in on the negotiations.

Gulf of Mexico OCS would be discharges of well 

treatment, completion, and workover fluids, which 

are discussed in Chapters 3.1.5.1, 3.1.3.1, and 4.2. 

The potential effects of produced waters (including 

well treatment, completion, and workover fluids) on 

other resources, such as deepwater benthic 

communities (Chapter 4.4.2), live bottom habitats 

(Chapter 4.6), and protected species (Chapter 4.9) 

have also been analyzed and are expected to be 

negligible due to the assumed compliance with all 

permitting requirements and existing regulations.

John Young JY-3 Has the Government Accountability Office's been 

satisfied yet that the Bureau of Safety and 

Environmental Enforcement's investigative and 

enforcement policies, procedures, and action are 

now adequate? [See "GAO: BSEE makes little 

progress on offshore oil, gas reforms," Nick Snow, 

03-21-2016, Oil & Gas Journal,

hitp:lwww.ogj.com/articles/print/volume-114/issue3b/general-interest/gao-bsee- makes-little-progresson- offshore-oil-gas-reforms.html !

If so. let us know. If not, give us an update and a 

chance to join in on the negotiations. As of 

03-23-2016, the Gulf Restoration Network reported 

little action on the BSEE rule changes 

recommendations following the 2010 BP Deepwater 

Horizon disaster [http:l/healthygulf. org/protect-gulf-oi 

l-disasters-0/].

Thank you for your comment. The GAO report is 

outside the scope of this Multisale EIS. However, 

BOEM acknowledges your concerns, has forwarded 

your email to BSEE, and recommends that you 

contact BSEE directly regarding your requests. 

Please also see the response to Comment CBD, 

BL, GRN, LBB, RAHC-7.
L-196 Gulf of Mexico Multisale EIS

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L-202 Gulf of Mexico Multisale EIS

United States Environmental Protection Agency United States Environmental Protection Agency (continued) 
Responses to Public Comments on the Draft Multisale EIS L-203

United States Environmental Protection Agency (continued) United States Environmental Protection Agency (continued) 
L-204 Gulf of Mexico Multisale EIS

United States Environmental Protection Agency (continued) United States Environmental Protection Agency (continued) 
Responses to Public Comments on the Draft Multisale EIS L-205

United States Environmental Protection Agency (continued) United States Environmental Protection Agency (continued) 
L-206 Gulf of Mexico Multisale EIS

United States Environmental Protection Agency (continued) United States Environmental Protection Agency (continued) 
Responses to Public Comments on the Draft Multisale EIS L-207

United States Environmental Protection Agency (continued) Alabama Department of Environmental Management
L-208 Gulf of Mexico Multisale EIS

Alabama Historical Commission Louisiana Department of Natural Resources
Responses to Public Comments on the Draft Multisale EIS L-209

Louisiana Department of Natural Resources (continued) Louisiana Department of Natural Resources (continued)
L-210 Gulf of Mexico Multisale EIS

Leon Soil and Water Conservation District 

Supervisory Board 

Leon Soil and Water Conservation District Supervisory 

Board (continued)
Responses to Public Comments on the Draft Multisale EIS L-211

Alabama Chapter of the Sierra Club Alabama Chapter of the Sierra Club (continued)
L-212 Gulf of Mexico Multisale EIS

Alabama Chapter of the Sierra Club (continued) Alabama Chapter of the Sierra Club (continued)
Responses to Public Comments on the Draft Multisale EIS L-213

Apalachicola Riverkeeper Apalachicola Riverkeeper (continued)
L-214 Gulf of Mexico Multisale EIS

Apalachicola Riverkeeper (continued) American Petroleum Institute
Responses to Public Comments on the Draft Multisale EIS L-215

American Petroleum Institute (continued) American Petroleum Institute (continued)
L-216 Gulf of Mexico Multisale EIS

American Petroleum Institute (continued) American Petroleum Institute (continued)
Responses to Public Comments on the Draft Multisale EIS L-217

American Petroleum Institute (continued) American Petroleum Institute (continued)
L-218 Gulf of Mexico Multisale EIS

American Petroleum Institute (continued) American Petroleum Institute (continued)
Responses to Public Comments on the Draft Multisale EIS L-219

American Petroleum Institute (continued) American Petroleum Institute (continued)
L-220 Gulf of Mexico Multisale EIS

American Petroleum Institute (continued) American Petroleum Institute (continued)
Responses to Public Comments on the Draft Multisale EIS L-221

American Petroleum Institute (continued) American Petroleum Institute (continued)
L-222 Gulf of Mexico Multisale EIS

American Petroleum Institute (continued) American Petroleum Institute (continued)
Responses to Public Comments on the Draft Multisale EIS L-223

American Petroleum Institute (continued) Care2Petition
L-224 Gulf of Mexico Multisale EIS

Care2Petition (continued) Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, 

Radical Arts and Healing Collective
Responses to Public Comments on the Draft Multisale EIS L-225

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)
L-226 Gulf of Mexico Multisale EIS

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)
Responses to Public Comments on the Draft Multisale EIS L-227

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)
L-228 Gulf of Mexico Multisale EIS

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)
Responses to Public Comments on the Draft Multisale EIS L-229

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)
L-230 Gulf of Mexico Multisale EIS

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)
Responses to Public Comments on the Draft Multisale EIS L-231

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)
L-232 Gulf of Mexico Multisale EIS

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)
Responses to Public Comments on the Draft Multisale EIS L-233

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)
L-234 Gulf of Mexico Multisale EIS

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)
Responses to Public Comments on the Draft Multisale EIS L-235

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)
L-236 Gulf of Mexico Multisale EIS

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)
Responses to Public Comments on the Draft Multisale EIS L-237

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)
L-238 Gulf of Mexico Multisale EIS

Center for Biological Diversity, Bold Louisiana, Gulf 

Restoration Network, Louisiana Bucket Brigade, Radical Arts 

and Healing Collective (continued)

Consumer Energy Alliance
Responses to Public Comments on the Draft Multisale EIS L-239

Consumer Energy Alliance (continued) The Ehrhardt Group
L-240 Gulf of Mexico Multisale EIS

Gulf Coast Group of the Mississippi Sierra Club Gulf Coast Group of the Mississippi Sierra Club (continued)
Responses to Public Comments on the Draft Multisale EIS L-241

Gulf Coast Group of the Mississippi Sierra Clubv Gulf Restoration Network
L-242 Gulf of Mexico Multisale EIS

Gulf Restoration Network (continued) Gulf Restoration Network (continued)
Responses to Public Comments on the Draft Multisale EIS L-243

Gulf Restoration Network (continued) Gulf Restoration Network (continued)
L-244 Gulf of Mexico Multisale EIS

Louisiana Mid-Continent Oil and Gas Association Louisiana Mid-Continent Oil and Gas Association

(continued)
Responses to Public Comments on the Draft Multisale EIS L-245

Louisiana Mid-Continent Oil and Gas Association

(continued)

Louisiana Mid-Continent Oil and Gas Association

(continued)
L-246 Gulf of Mexico Multisale EIS

Lone Star Chapter of the Sierra Club Lone Star Chapter of the Sierra Club (continued)
Responses to Public Comments on the Draft Multisale EIS L-247

Lone Star Chapter of the Sierra Club (continued) Lone Star Chapter of the Sierra Club (continued)
L-248 Gulf of Mexico Multisale EIS

Lone Star Chapter of the Sierra Club (continued) Lone Star Chapter of the Sierra Club (continued)
Responses to Public Comments on the Draft Multisale EIS L-249

Mississippi Coalition for Vietnamese-American 

Fisher Folk and Families

Mississippi Coalition for Vietnamese-American Fisher Folk 

and Families (continued)
L-250 Gulf of Mexico Multisale EIS

Mississippi Coalition for Vietnamese-American Fisher Folk 

and Families (continued)

Mississippi Coalition for Vietnamese-American Fisher Folk 

and Families (continued)
Responses to Public Comments on the Draft Multisale EIS L-251

Mississippi Coalition for Vietnamese-American Fisher Folk 

and Families (continued)

Mississippi Coalition for Vietnamese-American Fisher Folk 

and Families (continued)
L-252 Gulf of Mexico Multisale EIS

Mississippi Coalition for Vietnamese-American Fisher Folk 

and Families (continued)

Mississippi Coalition for Vietnamese-American Fisher Folk 

and Families (continued)
Responses to Public Comments on the Draft Multisale EIS L-253

Mississippi Coalition for Vietnamese-American Fisher Folk 

and Families (continued)

No New Leases Form Letter
L-254 Gulf of Mexico Multisale EIS

OffshoreAlabama.com OffshoreAlabama.com (continued)
Responses to Public Comments on the Draft Multisale EIS L-255

Restore Mississippi Sound Restore Mississippi Sound (continued)
L-256 Gulf of Mexico Multisale EIS

Restore Mississippi Sound (continued) Restore Mississippi Sound (continued)
Responses to Public Comments on the Draft Multisale EIS L-257

Restore Mississippi Sound (continued) Restore Mississippi Sound (continued)
L-258 Gulf of Mexico Multisale EIS

Restore Mississippi Sound (continued) Sierra Club
Responses to Public Comments on the Draft Multisale EIS L-259

Sierra Club (continued) Sierra Club (continued)
L-260 Gulf of Mexico Multisale EIS

Sierra Club (continued) Sierra Club (continued)
Responses to Public Comments on the Draft Multisale EIS L-261

Sierra Club (continued) Sierra Club (continued)
L-262 Gulf of Mexico Multisale EIS

Sierra Club (continued) Sierra Club (continued)
Responses to Public Comments on the Draft Multisale EIS L-263

Sierra Club (continued) Sierra Club (continued)
L-264 Gulf of Mexico Multisale EIS

Sierra Club (continued) Sierra Club (continued)
Responses to Public Comments on the Draft Multisale EIS L-265

Sierra Club (continued) Sierra Club (continued)
L-266 Gulf of Mexico Multisale EIS

Sierra Club (continued) Sierra Club (continued)
Responses to Public Comments on the Draft Multisale EIS L-267

Sierra Club (continued) Sierra Club (continued)
L-268 Gulf of Mexico Multisale EIS

Steps Coalition Steps Coalition (continued)
Responses to Public Comments on the Draft Multisale EIS L-269

Steps Coalition (continued) Steps Coalition (continued)
L-270 Gulf of Mexico Multisale EIS

Steps Coalition (continued) Steps Coalition (continued)
Responses to Public Comments on the Draft Multisale EIS L-271

Steps Coalition (continued) Steps Coalition (continued)
L-272 Gulf of Mexico Multisale EIS

Steps Coalition (continued)

Chevron
Responses to Public Comments on the Draft Multisale EIS L-273

ConocoPhillips ConocoPhillips (continued)
L-274 Gulf of Mexico Multisale EIS

ConocoPhillips (continued) Spectrum Geo
Responses to Public Comments on the Draft Multisale EIS L-275

Spectrum Geo (continued) Spectrum Geo (continued)
L-276 Gulf of Mexico Multisale EIS

Andrea Alexander Andrea Alexander (continued)
Responses to Public Comments on the Draft Multisale EIS L-277

Charles Mackey Clark Jeff Cobb
L-278 Gulf of Mexico Multisale EIS

Suzanne Cohen J Conn
Responses to Public Comments on the Draft Multisale EIS L-279

J Conn (continued) Community Advocate
L-280 Gulf of Mexico Multisale EIS

Community Advocate (continued) Katrina Dubytz
Responses to Public Comments on the Draft Multisale EIS L-281

Katrina Dubytz (continued) Susan Feathers
L-282 Gulf of Mexico Multisale EIS

Yolanda Ferguson Yolanda Ferguson (continued)
Responses to Public Comments on the Draft Multisale EIS L-283

Yolanda Ferguson (continued) Yolanda Ferguson (continued)
L-284 Gulf of Mexico Multisale EIS

Yolanda Ferguson (continued) Yolanda Ferguson (continued)
Responses to Public Comments on the Draft Multisale EIS L-285

Yolanda Ferguson (continued) Yolanda Ferguson (continued)
L-286 Gulf of Mexico Multisale EIS

Yolanda Ferguson (continued) Melissa Fleming
Responses to Public Comments on the Draft Multisale EIS L-287

Leah Gentry Leah Gentry (continued)
L-288 Gulf of Mexico Multisale EIS

Jason Hannon Jason Hannon (continued)
Responses to Public Comments on the Draft Multisale EI

S L-289

Erica Heimberg Renate Heurich
L-290 Gulf of Mexico Multisale EIS

Renate Heurich (continued) Renate Heurich (continued)
Responses to Public Comments on the Draft Multisale EIS L-291

Renate Heurich (continued) Renate Heurich (continued)
L-292 Gulf of Mexico Multisale EIS

David Hilfiker Hilton Kelley
Responses to Public Comments on the Draft Multisale EIS L-293

Hilton Kelley (continued) Ronald Kardos
L-294 Gulf of Mexico Multisale EIS

Ronald Kardos (continued) John Kersting
Responses to Public Comments on the Draft Multisale EIS L-295

Brenna Landis Brenna Landis (continued)
L-296 Gulf of Mexico Multisale EIS

Brenna Landis (continued) Kellan Lyman
Responses to Public Comments on the Draft Multisale EIS L-297

Kellan Lyman (continued) Michelle Macy
L-298 Gulf of Mexico Multisale EIS

Jane McBride Bruce Melton
Responses to Public Comments on the Draft Multisale EIS L-299

Harriett Myers James Mulcare
L-300 Gulf of Mexico Multisale EIS

Joanna Nasar Rebecca Parsons
Responses to Public Comments on the Draft Multisale EIS L-301

Rebecca Parsons (continued) Jack Radosta
L-302 Gulf of Mexico Multisale EIS

Maxine Ramsay Cyrus Reed
Responses to Public Comments on the Draft Multisale EIS L-303

Cyrus Reed (continued) Cyrus Reed (continued)
L-304 Gulf of Mexico Multisale EIS

Cyrus Reed (continued) Cyrus Reed (continued)
Responses to Public Comments on the Draft Multisale EIS L-305

Cyrus Reed (continued) Kim Ross
L-306 Gulf of Mexico Multisale EIS

Kim Ross (continued) Kim Schultz
Responses to Public Comments on the Draft Multisale EIS L-307

Sally Stevens Sally Stevens (continued)
L-308 Gulf of Mexico Multisale EIS

Robert Desmarais Sullivan Robert Desmarais Sullivan (continued)
Responses to Public Comments on the Draft Multisale EIS L-309

Diana Tomlinson David Underhill
L-310 Gulf of Mexico Multisale EIS

David Underhill (continued) Margie Vicknair-Pray
Responses to Public Comments on the Draft Multisale EIS L-311

Margie Vicknair-Pray (continued) Rachel Walsh
L-312 Gulf of Mexico Multisale EIS

Rachel Walsh (continued) Rachel Walsh (continued)

 
Responses to Public Comments on the Draft Multisale EIS L-313

Brenda Warger Sky Yardley
L-314 Gulf of Mexico Multisale EIS

Sky Yardley (continued) John Young
Responses to Public Comments on the Draft Multisale EIS L-315

John Young (continued)

KEYWORD INDEX

Keyword Index Keywords-3 

KEYWORD INDEX

Air Quality, xvi, xvii, xviii, xix, xx, xxv, xxxiii, xxxiv, 1-12, 1-16, 2-31, 2-33, 2-35, 2-37, 2-38, 2-39, 

2-40, 2-45, 3-3, 3-4, 3-26, 3-92, 3-93, 3-132, 3-165, 3-181, 4-3, 4-4, 4-9, 4-13, 4-14, 4-15, 4-16, 

4-17, 4-18, 4-19, 4-20, 4-21, 4-24, 4-25, 4-27, 4-29, 4-30, 4-31, 4-32, 4-33, 4-34, 4-35, 4-36, 4-37, 

4-38, 4-39, 4-40, 4-41, 4-42, 4-43, 4-45, 4-48, 4-49, 4-50, 4-51, 4-52, 4-53, 4-233, 4-234, 4-245, 

4-247, 4-248, 4-249, 4-250, 4-329, 4-396, 4-478, 4-486

Alternate Use, 1-16, 3-185

Alternative Energy, 1-13

Archaeological Resources, xvi, xviii, xxx, xxxiii, 1-12, 2-31, 2-35, 2-37, 2-38, 2-50, 3-12, 3-15, 3-17, 

3-171, 3-192, 4-3, 4-4, 4-104, 4-399, 4-400, 4-401, 4-403, 4-405, 4-406, 4-407, 4-408, 4-409, 

4-410, 4-411, 4-412, 4-413, 4-414, 4-415, 4-489, 4-491

Artificial Reefs, xxix, xxx, xxxiii, 1-12, 2-31, 2-49, 3-81, 3-168, 3-169, 4-118, 4-132, 4-187, 4-198, 

4-225, 4-229, 4-233, 4-245, 4-321, 4-332, 4-361, 4-368, 4-376, 4-378, 4-379, 4-380, 4-385, 4-387, 

4-388, 4-397, 4-398, 4-399, 4-410, 4-411, 4-493

Beach Mice, xvi, xviii, xxvii, 2-35, 2-37, 2-47, 4-3, 4-75, 4-102, 4-260, 4-262, 4-263, 4-264, 4-336, 

4-337, 4-338, 4-339, 4-340, 4-341, 4-342, 5-10

Blowout Preventer, 3-20, 3-43, 3-58, 3-73, 3-131, 4-284

Blowouts, 2-33, 3-12, 3-20, 3-32, 3-43, 3-58, 3-73, 3-101, 3-111, 3-112, 3-119, 3-129, 3-130, 3-131, 

3-132, 3-143, 3-144, 4-32, 4-135, 4-136, 4-137, 4-138, 4-202, 4-203, 4-284, 4-401, 4-410, 4-427, 

4-473

Catastrophic Spill, xxxii, 1-19, 1-20, 2-5, 2-15, 2-23, 2-24, 2-32, 2-52, 3-101, 3-119, 3-123, 4-4, 4-5, 

4-6, 4-8, 4-11, 4-12, 4-31, 4-32, 4-48, 4-64, 4-66, 4-79, 4-84, 4-85, 4-94, 4-104, 4-108, 4-109, 

4-113, 4-115, 4-134, 4-135, 4-136, 4-137, 4-138, 4-140, 4-141, 4-147, 4-163, 4-166, 4-181, 4-185, 

4-200, 4-201, 4-202, 4-203, 4-207, 4-208, 4-253, 4-264, 4-265, 4-293, 4-326, 4-349, 4-392, 4-409, 

4-424, 4-426, 4-427, 4-447, 4-471, 4-473, 4-474, 4-476, 4-483, 4-486, 5-11, 5-14

Chemosynthetic Communities, xxii, xxxiii, 1-12, 2-19, 2-30, 2-31, 2-42, 3-12, 4-115, 4-123, 4-124, 

4-125, 4-126, 4-128, 4-134, 4-140, 5-10

Coastal and Marine Birds, xxv, xxvii, 2-45, 2-47, 4-150, 4-151, 4-235, 4-236, 4-237, 4-244, 4-245, 

4-247, 4-248, 4-249, 4-250, 4-251, 4-254, 4-277, 4-345, 5-10

Coastal Barrier Beaches, xvii, xxi, 2-35, 2-37, 2-41, 4-3, 4-96, 4-97, 4-103, 4-104, 4-105, 4-106, 

4-107, 4-108, 4-110, 4-111, 4-112, 4-113, 4-114, 4-264, 4-317, 4-337, 4-338, 4-339, 4-348, 4-396, 

4-436, 5-10

Coastal Zone Management, xvi, xxxiii, xxxiv, 1-12, 1-14, 1-18, 1-20, 1-22, 3-93, 4-6, 4-230, 5-3, 5-17

Collisions, xxvi, xxxi, 2-46, 2-51, 3-3, 3-4, 3-134, 3-135, 3-136, 3-137, 3-172, 4-9, 4-105, 4-154, 

4-233, 4-246, 4-249, 4-250, 4-252, 4-253, 4-254, 4-255, 4-274, 4-282, 4-283, 4-295, 4-300, 4-311, 
Keywords-4 Gulf of Mexico Multisale EIS

4-320, 4-321, 4-323, 4-336, 4-348, 4-349, 4-417, 4-426, 4-428, 4-429, 4-430, 4-431, 4-437, 4-446, 

4-473, 4-474, 4-476, 4-483, 4-487, 4-488

Commercial Fisheries, xvi, xviii, xxix, 2-35, 2-37, 2-48, 4-3, 4-4, 4-266, 4-286, 4-301, 4-356, 4-357, 

4-358, 4-360, 4-361, 4-362, 4-363, 4-364, 4-365, 4-366, 4-446, 4-488, 4-490, 5-10

Commercial Fishing, xvi, xviii, xxix, 2-35, 2-37, 2-48, 4-3, 4-4, 4-266, 4-286, 4-301, 4-356, 4-357, 

4-358, 4-360, 4-361, 4-362, 4-363, 4-364, 4-365, 4-366, 4-446, 4-488, 4-490, 5-10

Consultation and Coordination, 1-13, 1-17, 1-20, 1-22, 3-101

Cumulative Activities, xv, 1-21, 3-3, 3-5, 3-175, 3-182, 3-198, 3-205, 4-10, 4-341, 4-424, 4-471

Cumulative Impacts, ix, xvii, xx, xxi, xxii, xxiii, xxiv, xxv, xxvi, xxvii, xxviii, xxix, xxx, xxxi, xxxii, 1-8, 

2-22, 2-23, 2-36, 2-39, 2-40, 2-41, 2-42, 2-43, 2-44, 2-45, 2-46, 2-47, 2-48, 2-49, 2-50, 2-51, 2-52, 

3-5, 3-157, 3-169, 3-185, 3-204, 4-3, 4-6, 4-7, 4-9, 4-11, 4-13, 4-14, 4-24, 4-33, 4-37, 4-45, 4-48, 

4-50, 4-52, 4-53, 4-55, 4-64, 4-66, 4-67, 4-69, 4-70, 4-83, 4-87, 4-91, 4-92, 4-93, 4-94, 4-95, 4-96, 

4-97, 4-106, 4-111, 4-112, 4-113, 4-114, 4-115, 4-117, 4-118, 4-137, 4-138, 4-139, 4-142, 4-143, 

4-144, 4-145, 4-146, 4-156, 4-158, 4-159, 4-160, 4-161, 4-163, 4-164, 4-172, 4-178, 4-180, 4-181, 

4-182, 4-183, 4-184, 4-185, 4-186, 4-187, 4-203, 4-204, 4-205, 4-207, 4-208, 4-209, 4-210, 4-211, 

4-212, 4-213, 4-214, 4-215, 4-221, 4-227, 4-229, 4-230, 4-231, 4-232, 4-234, 4-245, 4-246, 4-249, 

4-250, 4-251, 4-252, 4-253, 4-254, 4-255, 4-256, 4-258, 4-259, 4-262, 4-263, 4-265, 4-278, 4-279, 

4-297, 4-305, 4-307, 4-308, 4-318, 4-329, 4-334, 4-336, 4-337, 4-339, 4-340, 4-341, 4-342, 4-347, 

4-349, 4-350, 4-351, 4-354, 4-355, 4-356, 4-358, 4-360, 4-362, 4-364, 4-367, 4-368, 4-375, 4-377, 

4-381, 4-382, 4-387, 4-393, 4-394, 4-396, 4-397, 4-398, 4-399, 4-400, 4-410, 4-415, 4-416, 4-417, 

4-429, 4-430, 4-431, 4-432, 4-433, 4-434, 4-436, 4-438, 4-439, 4-443, 4-447, 4-451, 4-453, 4-457, 

4-466, 4-471, 4-474, 4-475, 4-478, 4-479, 4-480, 4-483, 4-492, 5-9, 5-13, 5-14

Decommissioning, xix, xxv, xxvi, xxix, xxx, xxxiii, 1-5, 1-7, 1-8, 1-12, 1-16, 1-17, 1-21, 2-32, 2-38, 

2-44, 2-46, 2-49, 2-50, 3-3, 3-4, 3-10, 3-17, 3-55, 3-76, 3-77, 3-80, 3-81, 3-96, 3-115, 3-131, 

3-162, 3-165, 3-168, 3-169, 3-182, 3-183, 3-204, 4-9, 4-13, 4-14, 4-24, 4-27, 4-30, 4-54, 4-58, 

4-62, 4-118, 4-130, 4-132, 4-163, 4-164, 4-166, 4-172, 4-174, 4-196, 4-198, 4-225, 4-228, 4-232, 

4-249, 4-263, 4-279, 4-285, 4-297, 4-299, 4-319, 4-321, 4-329, 4-332, 4-360, 4-361, 4-363, 4-376, 

4-378, 4-379, 4-380, 4-381, 4-385, 4-388, 4-394, 4-397, 4-398, 4-399, 4-400, 4-406, 4-408, 4-411, 

4-414, 4-489, 4-490, 4-491

Deepwater, xvi, xvii, xxii, xxvi, 1-17, 1-19, 1-20, 1-21, 2-3, 2-15, 2-16, 2-19, 2-21, 2-23, 2-24, 2-32, 

2-33, 2-34, 2-35, 2-37, 2-42, 2-46, 3-3, 3-18, 3-19, 3-20, 3-26, 3-29, 3-30, 3-31, 3-32, 3-33, 3-34, 

3-38, 3-39, 3-40, 3-43, 3-50, 3-51, 3-53, 3-55, 3-56, 3-63, 3-68, 3-77, 3-80, 3-85, 3-88, 3-91, 3-93, 

3-94, 3-97, 3-99, 3-100, 3-103, 3-106, 3-112, 3-116, 3-119, 3-123, 3-125, 3-129, 3-130, 3-131, 

3-132, 3-133, 3-136, 3-137, 3-141, 3-142, 3-143, 3-144, 3-145, 3-147, 3-148, 3-149, 3-150, 3-151, 

3-152, 3-168, 3-182, 3-183, 3-184, 3-185, 3-188, 3-190, 3-191, 3-192, 3-199, 3-200, 3-201, 3-202, 

3-205, 3-206, 3-207, 3-212, 3-213, 3-214, 4-3, 4-4, 4-5, 4-8, 4-10, 4-11, 4-13, 4-29, 4-32, 4-36, 

4-42, 4-53, 4-64, 4-66, 4-67, 4-74, 4-78, 4-84, 4-85, 4-93, 4-99, 4-100, 4-106, 4-107, 4-108, 4-112, 

4-113, 4-115, 4-116, 4-117, 4-118, 4-119, 4-120, 4-121, 4-122, 4-123, 4-124, 4-125, 4-127, 4-128, 

4-129, 4-130, 4-131, 4-132, 4-133, 4-134, 4-135, 4-136, 4-137, 4-138, 4-139, 4-140, 4-141, 4-142, 
Keyword Index Keywords-5 

4-143, 4-144, 4-145, 4-152, 4-158, 4-160, 4-171, 4-172, 4-176, 4-181, 4-190, 4-197, 4-201, 4-202, 

4-203, 4-207, 4-216, 4-223, 4-224, 4-228, 4-231, 4-237, 4-243, 4-244, 4-246, 4-248, 4-264, 4-268, 

4-269, 4-276, 4-283, 4-287, 4-293, 4-295, 4-302, 4-303, 4-304, 4-305, 4-306, 4-307, 4-329, 4-334, 

4-336, 4-349, 4-362, 4-363, 4-377, 4-391, 4-392, 4-404, 4-405, 4-409, 4-410, 4-418, 4-420, 4-422, 

4-424, 4-427, 4-447, 4-473, 4-474, 4-476, 4-482, 4-483, 4-490, 4-493, 5-10, 5-14, 5-15

Deepwater Horizon, xvi, xxvi, 1-19, 1-20, 2-3, 2-15, 2-16, 2-21, 2-23, 2-24, 2-32, 2-34, 2-46, 3-85, 

3-100, 3-103, 3-106, 3-112, 3-119, 3-123, 3-125, 3-129, 3-130, 3-131, 3-132, 3-141, 3-142, 3-143, 

3-144, 3-145, 3-147, 3-148, 3-149, 3-150, 3-151, 3-152, 3-188, 3-190, 3-191, 3-199, 3-200, 3-201, 

3-202, 3-207, 3-213, 3-214, 4-5, 4-10, 4-11, 4-13, 4-32, 4-67, 4-74, 4-84, 4-85, 4-93, 4-99, 4-100, 

4-106, 4-107, 4-108, 4-112, 4-113, 4-134, 4-135, 4-137, 4-138, 4-140, 4-141, 4-152, 4-158, 4-160, 

4-171, 4-172, 4-181, 4-201, 4-202, 4-203, 4-207, 4-237, 4-243, 4-244, 4-246, 4-248, 4-264, 4-293, 

4-295, 4-302, 4-303, 4-304, 4-305, 4-307, 4-334, 4-336, 4-349, 4-362, 4-363, 4-377, 4-391, 4-392, 

4-409, 4-410, 4-427, 4-447, 4-473, 4-474, 4-476, 4-482, 4-483, 5-14, 5-15

Demographics, 4-229, 5-10

Discharges, xvi, xx, xxii, xxiii, xxiv, xxv, xxvi, xxvii, 2-26, 2-32, 2-33, 2-34, 2-40, 2-42, 2-44, 2-45, 

2-46, 2-47, 3-3, 3-25, 3-58, 3-59, 3-60, 3-62, 3-64, 3-70, 3-71, 3-73, 3-74, 3-75, 3-76, 3-95, 3-115, 

3-147, 3-165, 3-171, 3-172, 3-177, 3-178, 3-179, 3-180, 3-211, 4-9, 4-54, 4-57, 4-58, 4-59, 4-60, 

4-61, 4-62, 4-64, 4-65, 4-66, 4-67, 4-79, 4-116, 4-117, 4-118, 4-129, 4-131, 4-132, 4-137, 4-138, 

4-141, 4-147, 4-154, 4-156, 4-157, 4-165, 4-173, 4-175, 4-178, 4-185, 4-187, 4-196, 4-197, 4-198, 

4-204, 4-208, 4-214, 4-233, 4-245, 4-249, 4-250, 4-254, 4-263, 4-279, 4-284, 4-297, 4-298, 4-319, 

4-321, 4-329, 4-332, 4-333, 4-348, 4-392, 4-401, 4-486, 4-487, 4-488

Dispersants, xx, 2-40, 3-118, 3-119, 3-132, 3-140, 3-141, 3-142, 3-143, 3-147, 3-148, 3-149, 3-150, 

3-156, 4-33, 4-64, 4-85, 4-106, 4-134, 4-135, 4-136, 4-138, 4-140, 4-155, 4-156, 4-177, 4-178, 

4-181, 4-200, 4-201, 4-203, 4-204, 4-207, 4-247, 4-295, 4-296, 4-327, 4-409, 4-410, 4-413, 4-477, 

4-486, 4-487, 4-488

Dunes, xvi, xvii, xxi, xxvii, 2-35, 2-37, 2-41, 2-47, 3-203, 4-3, 4-73, 4-96, 4-97, 4-98, 4-99, 4-100, 

4-101, 4-102, 4-103, 4-104, 4-105, 4-106, 4-107, 4-108, 4-109, 4-110, 4-111, 4-112, 4-113, 4-114, 

4-115, 4-150, 4-237, 4-248, 4-264, 4-317, 4-335, 4-336, 4-337, 4-338, 4-339, 4-340, 4-344, 4-348, 

4-394, 4-396, 4-436, 4-482, 5-10

Economic Factors, xviii, xxix, xxxi, xxxii, 2-35, 2-38, 2-49, 2-51, 4-3, 4-259, 4-365, 4-379, 4-380, 

4-387, 4-390, 4-393, 4-396, 4-397, 4-439, 4-440, 4-443, 4-446, 4-447, 4-466

Employment, 2-34, 4-375, 4-383, 4-392, 4-416, 4-422, 4-424, 4-440, 4-441, 4-444, 4-447, 4-448, 

4-449, 4-450, 4-451, 4-452, 4-454, 4-456, 4-457, 4-458, 4-460, 4-461, 4-462, 4-463, 4-465, 4-466, 

4-472, 4-473, 4-475, 4-476, 4-483, 4-484

Environmental Justice, xvi, xviii, xxxi, xxxii, 2-3, 2-35, 2-38, 2-51, 2-52, 4-3, 4-4, 4-465, 4-466, 4-481, 

4-485, 5-10

Essential Fish Habitat, 1-19, 1-20, 4-4, 4-7, 4-119, 4-162, 4-168, 4-172, 4-174, 4-188, 4-190, 4-216, 

4-218, 4-220, 4-228, 4-363, 4-377, 4-385, 4-446, 5-3, 5-11
Keywords-6 Gulf of Mexico Multisale EIS

Explosive Removals, 2-31, 4-285, 4-322

Fish Resources, 4-119, 4-188, 4-363, 4-377, 4-446

Fisheries, ix, xxviii, xxix, 1-14, 2-34, 2-49, 3-72, 3-112, 3-116, 3-168, 3-169, 3-191, 4-7, 4-162, 

4-190, 4-214, 4-216, 4-217, 4-218, 4-229, 4-230, 4-250, 4-253, 4-269, 4-271, 4-272, 4-275, 4-302, 

4-309, 4-312, 4-314, 4-315, 4-317, 4-330, 4-356, 4-358, 4-360, 4-361, 4-362, 4-363, 4-364, 4-365, 

4-368, 4-379, 4-380, 4-381, 4-477

Flaring, xix, xxxiii, 1-12, 2-33, 2-38, 3-51, 3-71, 3-95, 3-132, 3-133, 3-181, 4-13, 4-14, 4-24, 4-25, 

4-27, 4-29, 4-30, 4-31, 4-48

Flower Garden Banks, x, xii, xxviii, 1-18, 2-3, 2-6, 2-9, 2-15, 2-31, 2-48, 4-169, 4-171, 4-178, 4-179, 

4-181, 4-195, 4-352, 4-353, 4-354, 4-355

Gulf Sturgeon, 2-20, 4-215

Human Resources, xviii, xxxi, 2-35, 2-38, 2-51, 4-4, 4-383, 4-415

Hurricanes, xvi, xxix, 1-16, 2-17, 2-32, 2-34, 2-49, 3-44, 3-45, 3-53, 3-80, 3-81, 3-84, 3-102, 3-103, 

3-105, 3-106, 3-111, 3-112, 3-113, 3-114, 3-115, 3-125, 3-134, 3-135, 3-138, 3-172, 3-183, 3-188, 

3-196, 3-198, 3-206, 3-207, 3-208, 3-209, 4-5, 4-49, 4-66, 4-73, 4-79, 4-84, 4-85, 4-86, 4-87, 4-91, 

4-92, 4-98, 4-99, 4-100, 4-101, 4-108, 4-110, 4-176, 4-178, 4-179, 4-201, 4-206, 4-243, 4-244, 

4-245, 4-251, 4-253, 4-302, 4-305, 4-309, 4-333, 4-339, 4-340, 4-341, 4-352, 4-364, 4-365, 4-378, 

4-379, 4-395, 4-405, 4-410, 4-413, 4-421, 4-481, 4-482

Income, xxxii, 2-34, 2-52, 4-366, 4-375, 4-381, 4-385, 4-396, 4-399, 4-440, 4-441, 4-444, 4-448, 

4-449, 4-450, 4-452, 4-454, 4-456, 4-457, 4-458, 4-460, 4-461, 4-462, 4-463, 4-465, 4-468, 4-477, 

4-479, 4-480, 4-481, 4-482, 4-485

Infrastructure, xv, xvi, xviii, xxiv, xxx, xxxi, xxxii, 1-22, 2-13, 2-16, 2-34, 2-35, 2-38, 2-44, 2-50, 2-51, 

2-52, 3-3, 3-6, 3-8, 3-9, 3-10, 3-17, 3-22, 3-23, 3-28, 3-33, 3-35, 3-38, 3-39, 3-40, 3-41, 3-44, 3-48, 

3-50, 3-51, 3-52, 3-53, 3-54, 3-56, 3-57, 3-75, 3-79, 3-80, 3-81, 3-82, 3-83, 3-84, 3-90, 3-101, 

3-105, 3-132, 3-133, 3-134, 3-159, 3-162, 3-163, 3-165, 3-166, 3-168, 3-187, 3-188, 3-189, 3-191, 

3-195, 3-199, 3-208, 4-3, 4-9, 4-11, 4-12, 4-25, 4-49, 4-62, 4-68, 4-69, 4-70, 4-76, 4-78, 4-83, 

4-84, 4-87, 4-90, 4-91, 4-96, 4-97, 4-102, 4-104, 4-107, 4-111, 4-113, 4-118, 4-120, 4-130, 4-132, 

4-140, 4-187, 4-188, 4-196, 4-197, 4-199, 4-204, 4-214, 4-215, 4-224, 4-225, 4-226, 4-228, 4-232, 

4-233, 4-297, 4-298, 4-364, 4-376, 4-378, 4-385, 4-390, 4-393, 4-394, 4-399, 4-400, 4-407, 4-415, 

4-416, 4-417, 4-422, 4-423, 4-424, 4-425, 4-426, 4-427, 4-428, 4-429, 4-430, 4-431, 4-432, 4-433, 

4-434, 4-436, 4-437, 4-438, 4-439, 4-446, 4-468, 4-472, 4-474, 4-476, 4-478, 4-479, 4-480, 4-481, 

4-485, 4-487, 4-492

Land Use, xvi, xviii, xxxi, xxxiv, 2-3, 2-34, 2-35, 2-38, 2-51, 3-82, 3-212, 4-3, 4-4, 4-415, 4-416, 

4-417, 4-418, 4-419, 4-422, 4-424, 4-425, 4-426, 4-427, 4-428, 4-429, 4-430, 4-431, 4-432, 4-433, 

4-434, 4-436, 4-437, 4-438, 4-439, 4-446

Live Bottoms, xiii, xv, xvi, xvii, xviii, xxii, xxiii, xxiv, xxviii, xxix, xxxiii, 1-21, 2-3, 2-10, 2-11, 2-13, 2-19, 

2-25, 2-26, 2-29, 2-30, 2-35, 2-37, 2-42, 2-43, 2-44, 2-48, 2-49, 3-200, 3-201, 4-3, 4-4, 4-8, 4-53, 
Keyword Index Keywords-7 

4-68, 4-96, 4-114, 4-115, 4-116, 4-119, 4-120, 4-123, 4-125, 4-127, 4-128, 4-129, 4-130, 4-131, 

4-132, 4-134, 4-135, 4-136, 4-138, 4-139, 4-140, 4-144, 4-161, 4-162, 4-168, 4-169, 4-170, 4-172, 

4-174, 4-175, 4-176, 4-177, 4-178, 4-179, 4-180, 4-181, 4-184, 4-185, 4-187, 4-188, 4-189, 4-190, 

4-191, 4-192, 4-193, 4-194, 4-195, 4-196, 4-197, 4-198, 4-199, 4-200, 4-201, 4-202, 4-203, 4-204, 

4-205, 4-206, 4-207, 4-208, 4-209, 4-210, 4-211, 4-213, 4-216, 4-228, 4-258, 4-259, 4-260, 4-262, 

4-263, 4-264, 4-312, 4-327, 4-342, 4-351, 4-352, 4-353, 4-354, 4-355, 4-356, 4-366, 4-368, 4-381, 

4-399, 4-439, 4-464, 4-484, 5-10

Loss of Well Control, 2-32, 3-3, 3-4, 3-101, 3-129, 3-130, 3-141, 3-142, 4-9, 4-32, 4-134, 4-135, 

4-136, 4-200, 4-201, 4-202, 4-226, 4-290

Louisiana Highway 1, 4-423, 4-424

Low Relief, xvii, xxiv, 2-26, 2-35, 2-37, 2-43, 2-44, 4-3, 4-170, 4-185, 4-186, 4-187, 4-189, 4-190, 

4-191, 4-192, 4-194, 4-195, 4-196, 4-198, 4-199, 4-200, 4-202, 4-203, 4-204, 4-205, 4-206, 4-207, 

4-208, 4-209, 4-210, 4-211, 4-212, 4-218, 5-10

Macondo, 3-130, 3-143, 3-144, 3-150, 3-152, 4-32, 4-136, 4-410

Mangroves, 3-156, 3-201, 4-73, 4-312, 4-345

Marine Mammals, ix, xvi, xviii, xxvi, 1-18, 1-20, 2-20, 2-22, 2-31, 2-34, 2-35, 2-37, 2-45, 2-46, 3-57, 

3-97, 3-136, 3-171, 3-200, 3-203, 4-3, 4-6, 4-259, 4-260, 4-263, 4-265, 4-266, 4-267, 4-268, 

4-269, 4-270, 4-271, 4-275, 4-277, 4-278, 4-279, 4-280, 4-281, 4-282, 4-283, 4-284, 4-285, 4-286, 

4-287, 4-288, 4-289, 4-290, 4-291, 4-292, 4-293, 4-294, 4-295, 4-296, 4-297, 4-298, 4-299, 4-300, 

4-301, 4-302, 4-303, 4-304, 4-305, 4-306, 4-307, 4-308, 4-319, 4-336, 4-487, 4-488, 5-10

Mercury, 2-33, 3-51, 3-65, 3-66, 3-70, 3-213, 4-60, 4-284

Meteorological Conditions, 3-119, 4-176

Mitigating Measures, x, xiv, xv, xx, xxi, xxxii, xxxiii, 1-9, 1-12, 1-18, 1-21, 2-5, 2-13, 2-16, 2-19, 2-21, 

2-22, 2-24, 2-25, 2-29, 2-30, 2-31, 2-40, 2-41, 3-13, 3-24, 3-191, 4-8, 4-68, 4-76, 4-94, 4-174, 

4-251, 4-281, 4-332, 4-434, 4-481, 4-492

Mitigation, ix, xv, xviii, xx, xxii, xxiv, xxvi, xxviii, xxx, xxxiii, 1-3, 1-12, 1-21, 2-12, 2-22, 2-24, 2-25, 

2-29, 2-30, 2-31, 2-35, 2-38, 2-39, 2-42, 2-44, 2-46, 2-48, 2-50, 3-42, 3-143, 3-167, 3-185, 3-199, 

4-7, 4-8, 4-14, 4-15, 4-33, 4-50, 4-51, 4-52, 4-53, 4-55, 4-60, 4-63, 4-64, 4-66, 4-67, 4-76, 4-77, 

4-79, 4-83, 4-87, 4-88, 4-90, 4-94, 4-103, 4-106, 4-107, 4-116, 4-117, 4-120, 4-127, 4-130, 4-132, 

4-133, 4-137, 4-138, 4-140, 4-141, 4-142, 4-143, 4-144, 4-145, 4-164, 4-167, 4-174, 4-182, 4-183, 

4-184, 4-185, 4-189, 4-196, 4-198, 4-199, 4-203, 4-204, 4-207, 4-208, 4-209, 4-210, 4-211, 4-212, 

4-213, 4-216, 4-230, 4-233, 4-247, 4-250, 4-255, 4-264, 4-281, 4-283, 4-285, 4-287, 4-296, 4-297, 

4-307, 4-319, 4-320, 4-321, 4-322, 4-328, 4-336, 4-339, 4-341, 4-350, 4-354, 4-355, 4-356, 4-390, 

4-392, 4-400, 4-401, 4-406, 4-407, 4-408, 4-410, 4-411, 4-412, 4-413, 4-414, 4-415, 4-436, 4-482, 

4-486, 4-491, 4-493, 5-9, 5-13, 5-14

NEPA, vii, viii, xix, 1-3, 1-4, 1-6, 1-7, 1-10, 1-11, 1-13, 1-14, 1-15, 1-16, 1-18, 1-19, 1-20, 1-21, 2-3, 

2-4, 2-6, 2-20, 2-24, 2-25, 2-29, 2-31, 2-35, 2-39, 3-100, 4-3, 4-4, 4-5, 4-6, 4-9, 4-10, 4-12, 4-20, 
Keywords-8 Gulf of Mexico Multisale EIS

4-67, 4-93, 4-112, 4-182, 4-189, 4-231, 4-238, 4-264, 4-265, 4-279, 4-285, 4-303, 4-404, 4-413, 

4-485, 5-3, 5-12, 5-14, 5-15

Noise, xxv, xxvi, xxvii, 2-34, 2-45, 2-46, 2-47, 3-3, 3-14, 3-26, 3-56, 3-95, 3-96, 3-97, 3-98, 3-99, 

3-191, 4-9, 4-187, 4-221, 4-222, 4-223, 4-228, 4-229, 4-231, 4-232, 4-233, 4-245, 4-249, 4-254, 

4-263, 4-271, 4-279, 4-280, 4-281, 4-283, 4-286, 4-287, 4-288, 4-289, 4-295, 4-297, 4-298, 4-300, 

4-301, 4-307, 4-319, 4-320, 4-322, 4-323, 4-329, 4-333, 4-348, 4-349, 4-395, 4-478, 4-488, 5-14

NRDA, 2-23, 3-188, 3-189, 3-190, 3-191, 3-200, 4-5, 4-10, 4-93, 4-112, 4-244, 4-301, 4-305, 4-331, 

4-332, 4-334, 4-482

Oil Spills, ix, xvi, xix, xx, xxi, xxii, xxiii, xxiv, xxv, xxvi, xxvii, xxviii, xxix, xxx, xxxi, xxxii, xxxiii, 1-16,

1-19, 1-20, 2-3, 2-15, 2-16, 2-21, 2-23, 2-24, 2-32, 2-34, 2-38, 2-40, 2-41, 2-42, 2-44, 2-45, 2-46, 

2-47, 2-49, 2-51, 2-52, 3-3, 3-4, 3-40, 3-54, 3-85, 3-100, 3-101, 3-102, 3-103, 3-104, 3-105, 3-106, 

3-107, 3-110, 3-116, 3-117, 3-118, 3-119, 3-120, 3-121, 3-122, 3-123, 3-124, 3-125, 3-126, 3-127, 

3-128, 3-129, 3-130, 3-131, 3-132, 3-139, 3-140, 3-141, 3-142, 3-143, 3-144, 3-145, 3-147, 3-149, 

3-150, 3-151, 3-152, 3-163, 3-171, 3-178, 3-200, 3-201, 3-202, 3-207, 3-209, 3-213, 3-214, 4-5, 

4-6, 4-8, 4-9, 4-10, 4-11, 4-13, 4-14, 4-24, 4-30, 4-32, 4-33, 4-49, 4-55, 4-63, 4-64, 4-65, 4-66, 

4-67, 4-68, 4-70, 4-74, 4-79, 4-80, 4-82, 4-83, 4-84, 4-85, 4-89, 4-90, 4-93, 4-94, 4-95, 4-96, 4-97, 

4-99, 4-100, 4-104, 4-105, 4-106, 4-107, 4-108, 4-109, 4-111, 4-112, 4-113, 4-114, 4-115, 4-117, 

4-118, 4-133, 4-134, 4-135, 4-137, 4-138, 4-140, 4-141, 4-146, 4-147, 4-152, 4-154, 4-155, 4-156, 

4-158, 4-160, 4-163, 4-164, 4-166, 4-171, 4-172, 4-174, 4-176, 4-178, 4-181, 4-182, 4-185, 4-187, 

4-199, 4-200, 4-201, 4-202, 4-203, 4-204, 4-208, 4-214, 4-215, 4-226, 4-233, 4-234, 4-236, 4-237, 

4-243, 4-244, 4-245, 4-247, 4-248, 4-249, 4-250, 4-253, 4-255, 4-256, 4-257, 4-258, 4-263, 4-264, 

4-265, 4-289, 4-290, 4-291, 4-292, 4-293, 4-294, 4-295, 4-296, 4-297, 4-298, 4-302, 4-303, 4-304, 

4-305, 4-307, 4-324, 4-325, 4-326, 4-327, 4-329, 4-330, 4-334, 4-336, 4-338, 4-339, 4-341, 4-346, 

4-349, 4-350, 4-351, 4-357, 4-361, 4-362, 4-363, 4-365, 4-368, 4-377, 4-379, 4-380, 4-381, 4-382, 

4-391, 4-392, 4-394, 4-395, 4-397, 4-398, 4-399, 4-401, 4-408, 4-409, 4-410, 4-413, 4-414, 4-417, 

4-424, 4-426, 4-427, 4-428, 4-429, 4-430, 4-431, 4-437, 4-446, 4-447, 4-471, 4-473, 4-474, 4-476, 

4-482, 4-483, 4-486, 4-487, 4-488, 4-489, 4-490, 4-492, 5-14, 5-15

OSRA, xxxii, 3-120, 3-121, 3-122, 3-123, 3-126, 4-293, 4-326, 4-338

PDARP/PEIS, 1-19, 2-23, 4-5, 4-10, 4-84, 4-181, 4-201, 4-207, 4-264, 4-303

Physical Oceanography, 1-14, 3-206, 4-56, 4-414

Pinnacle Trend, xiii, xiv, xv, xvi, xxiv, xxxiii, 2-3, 2-10, 2-11, 2-19, 2-25, 2-26, 2-29, 2-43, 4-8, 4-53, 

4-68, 4-96, 4-114, 4-135, 4-144, 4-161, 4-162, 4-184, 4-189, 4-191, 4-192, 4-193, 4-194, 4-200, 

4-207, 4-209, 4-210, 4-211, 4-212, 4-258, 4-342, 4-351, 4-356, 4-366, 4-381, 4-399, 4-439, 4-464, 

4-484

Pipelines, xvi, xxi, xxv, xxvii, xxx, xxxii, 1-12, 1-17, 2-29, 2-30, 2-31, 2-32, 2-34, 2-40, 2-41, 2-45, 

2-47, 2-50, 2-52, 3-3, 3-4, 3-5, 3-9, 3-10, 3-12, 3-16, 3-17, 3-31, 3-32, 3-33, 3-34, 3-37, 3-38, 3-39, 

3-40, 3-41, 3-42, 3-43, 3-44, 3-50, 3-53, 3-54, 3-55, 3-56, 3-68, 3-76, 3-79, 3-80, 3-81, 3-82, 3-88, 

3-89, 3-90, 3-91, 3-96, 3-101, 3-102, 3-103, 3-104, 3-105, 3-106, 3-107, 3-108, 3-109, 3-110, 

3-113, 3-114, 3-115, 3-116, 3-119, 3-122, 3-123, 3-124, 3-125, 3-127, 3-128, 3-132, 3-134, 3-135, 
Keyword Index Keywords-9 

3-158, 3-159, 3-161, 3-163, 3-166, 3-168, 3-172, 3-179, 3-180, 3-181, 3-182, 3-183, 3-184, 3-185, 

3-188, 3-191, 3-192, 3-203, 3-205, 3-208, 3-209, 4-8, 4-9, 4-11, 4-12, 4-25, 4-31, 4-49, 4-54, 4-58, 

4-62, 4-67, 4-68, 4-69, 4-70, 4-76, 4-77, 4-80, 4-81, 4-83, 4-84, 4-87, 4-88, 4-89, 4-90, 4-93, 4-94, 

4-96, 4-97, 4-102, 4-103, 4-105, 4-107, 4-111, 4-113, 4-120, 4-132, 4-173, 4-188, 4-197, 4-224, 

4-233, 4-245, 4-247, 4-250, 4-255, 4-257, 4-292, 4-293, 4-326, 4-361, 4-377, 4-394, 4-400, 4-404, 

4-406, 4-407, 4-408, 4-409, 4-410, 4-411, 4-412, 4-414, 4-415, 4-423, 4-425, 4-426, 4-427, 4-428, 

4-431, 4-437, 4-444, 4-446, 4-472, 4-485, 4-487, 4-488, 4-489, 4-490, 4-491

Port Fourchon, 3-88, 3-92, 3-144, 4-78, 4-86, 4-423, 4-424, 4-428

Produced Waters, 2-33, 3-66, 3-212, 4-61, 4-88, 4-120, 4-131, 4-157, 4-189, 4-196, 4-198, 4-204, 

4-245, 4-247, 4-249, 4-486

Public Services, 2-34

Recreational Fishing, xvi, xviii, xxv, xxix, xxx, 2-35, 2-37, 2-44, 2-49, 3-171, 3-191, 3-201, 4-3, 4-4, 

4-89, 4-169, 4-205, 4-218, 4-229, 4-230, 4-250, 4-296, 4-298, 4-299, 4-330, 4-367, 4-368, 4-373, 

4-375, 4-376, 4-377, 4-378, 4-379, 4-380, 4-381, 4-385, 4-388, 4-391, 4-394, 4-396, 4-397, 4-398, 

4-421, 4-423, 4-433, 4-446, 4-488, 4-490, 4-492

Recreational Resources, xvi, xviii, xxx, 2-35, 2-37, 2-49, 4-3, 4-4, 4-104, 4-110, 4-248, 4-252, 4-379, 

4-381, 4-382, 4-387, 4-388, 4-390, 4-391, 4-392, 4-393, 4-394, 4-395, 4-396, 4-397, 4-398, 4-399, 

4-446, 4-479, 4-489

Renewable Energy, 1-5, 1-16, 1-18, 3-81, 3-185, 3-186, 3-187, 3-192, 4-421, 4-478, 4-479, 4-491

Resource Estimates, xv, 1-22, 2-8, 2-9, 2-10, 3-5, 3-6, 3-122, 3-124, 3-125, 4-255, 4-257, 4-258

Sargassum, xvi, xvii, xxii, 1-21, 2-22, 2-23, 2-35, 2-37, 2-42, 4-3, 4-4, 4-145, 4-146, 4-147, 4-148, 

4-149, 4-150, 4-151, 4-152, 4-153, 4-154, 4-155, 4-156, 4-157, 4-158, 4-159, 4-160, 4-161, 4-216, 

4-219, 4-220, 4-228, 4-236, 4-259, 4-310, 4-311, 4-313, 4-315, 4-316, 4-318, 4-325, 4-329, 4-361, 

4-487, 5-10

Sea Turtles, ix, xvi, xviii, xxvi, xxvii, 2-3, 2-20, 2-22, 2-23, 2-31, 2-34, 2-35, 2-37, 2-46, 3-97, 3-136, 

3-156, 3-200, 3-203, 4-3, 4-75, 4-100, 4-102, 4-150, 4-151, 4-152, 4-154, 4-156, 4-259, 4-260, 

4-263, 4-277, 4-281, 4-308, 4-309, 4-310, 4-311, 4-312, 4-313, 4-314, 4-315, 4-316, 4-317, 4-318, 

4-319, 4-320, 4-321, 4-322, 4-323, 4-324, 4-325, 4-326, 4-327, 4-328, 4-329, 4-330, 4-331, 4-332, 

4-333, 4-334, 4-335, 4-336, 5-10

Seagrass Communities, 2-26, 3-151, 3-156, 4-69, 4-70, 4-74, 4-75, 4-85, 4-91, 4-92, 4-94, 4-99, 

4-102, 4-310, 4-327, 4-329, 4-332

Service Base, 3-55, 3-56, 3-57, 3-76, 3-82, 3-86, 3-88, 3-165, 4-78, 4-87, 4-95, 4-114, 4-416, 4-423, 

4-424, 4-425, 4-431

Site Clearance, xxxiii, 1-12, 2-30, 2-50, 3-76, 4-415, 4-489

Smalltooth Sawfish, 4-215
Keywords-10 Gulf of Mexico Multisale EIS

Soft Bottoms, xxii, xxiv, 2-42, 2-44, 3-169, 3-213, 4-119, 4-132, 4-161, 4-167, 4-187, 4-199, 4-203, 

4-218, 4-225

Stipulation, x, xiii, xiv, xv, xviii, xxiii, xxiv, xxvi, xxviii, xxxii, xxxiii, 1-12, 1-21, 2-3, 2-4, 2-6, 2-10, 2-11, 

2-12, 2-13, 2-15, 2-19, 2-25, 2-26, 2-27, 2-28, 2-29, 2-30, 2-38, 2-43, 2-44, 2-46, 2-48, 3-24, 

3-172, 3-181, 3-182, 4-8, 4-12, 4-53, 4-68, 4-96, 4-106, 4-114, 4-120, 4-144, 4-155, 4-161, 4-162, 

4-165, 4-166, 4-167, 4-170, 4-173, 4-174, 4-175, 4-176, 4-177, 4-178, 4-180, 4-182, 4-183, 4-184, 

4-188, 4-189, 4-190, 4-195, 4-196, 4-198, 4-199, 4-200, 4-203, 4-204, 4-208, 4-209, 4-211, 4-212, 

4-213, 4-258, 4-262, 4-263, 4-281, 4-283, 4-288, 4-296, 4-303, 4-307, 4-319, 4-321, 4-324, 4-328, 

4-332, 4-334, 4-336, 4-339, 4-342, 4-351, 4-354, 4-355, 4-356, 4-366, 4-381, 4-393, 4-396, 4-399, 

4-439, 4-464, 4-484, 4-490

Submerged Vegetation, xxi, 2-40, 4-69, 4-70, 4-74, 4-76, 4-80, 4-81, 4-83, 4-89, 4-91, 4-95, 4-96, 

5-10

Synthetic-Based Drilling Fluids, 2-33, 3-58, 3-63, 3-64, 3-74, 3-137, 3-138, 4-60, 4-63, 4-67, 4-160

Topographic Features, xiii, xiv, xv, xvi, xvii, xxiii, xxxiii, 2-3, 2-10, 2-11, 2-12, 2-13, 2-15, 2-19, 2-25, 

2-26, 2-29, 2-30, 2-31, 2-35, 2-37, 2-43, 3-55, 4-3, 4-8, 4-53, 4-68, 4-96, 4-114, 4-119, 4-144, 

4-161, 4-162, 4-163, 4-164, 4-165, 4-166, 4-167, 4-168, 4-169, 4-170, 4-171, 4-172, 4-173, 4-174, 

4-175, 4-176, 4-177, 4-178, 4-179, 4-180, 4-181, 4-182, 4-183, 4-184, 4-188, 4-189, 4-191, 4-195, 

4-211, 4-212, 4-218, 4-258, 4-264, 4-278, 4-342, 4-351, 4-353, 4-354, 4-355, 4-356, 4-366, 4-381, 

4-399, 4-439, 4-464, 4-484, 5-10

Tourism, ix, xxi, xxii, 2-32, 2-34, 2-41, 3-191, 4-94, 4-102, 4-110, 4-248, 4-329, 4-333, 4-379, 4-383, 

4-384, 4-389, 4-392, 4-396, 4-399, 4-420, 4-421, 4-478, 4-479, 4-492, 5-13

Trash, xvi, 2-22, 2-33, 2-34, 3-4, 3-73, 3-74, 3-138, 3-163, 3-171, 3-177, 4-62, 4-83, 4-88, 4-96, 

4-102, 4-106, 4-107, 4-119, 4-153, 4-154, 4-188, 4-249, 4-250, 4-255, 4-263, 4-289, 4-296, 4-307, 

4-328, 4-329, 4-336, 4-338, 4-339, 4-341, 4-349, 4-350, 4-391, 4-392, 4-393, 4-488

Unified Area Command, 3-115

Waste Disposal, 3-38, 3-75, 3-82, 3-89, 3-90, 3-174, 4-79, 4-83, 4-88, 4-233, 4-416, 4-417, 4-423, 

4-425, 4-426, 4-428, 4-430, 4-431

Wastes, xxv, xxvii, 2-33, 2-34, 2-45, 2-47, 3-3, 3-25, 3-26, 3-58, 3-70, 3-72, 3-73, 3-74, 3-75, 3-76, 

3-89, 3-165, 3-171, 3-173, 3-174, 3-177, 3-210, 4-9, 4-54, 4-58, 4-59, 4-60, 4-62, 4-67, 4-69, 4-70, 

4-76, 4-79, 4-97, 4-196, 4-233, 4-245, 4-254, 4-284, 4-297, 4-319, 4-321, 4-332, 4-348, 4-425, 

4-428

Water Quality, xvi, xvii, xx, xxiii, xxvii, 1-21, 2-3, 2-21, 2-33, 2-35, 2-37, 2-40, 2-42, 2-47, 3-58, 3-59, 

3-64, 3-66, 3-67, 3-76, 3-120, 3-171, 3-173, 3-177, 3-201, 3-213, 4-3, 4-4, 4-53, 4-54, 4-55, 4-56, 

4-57, 4-58, 4-60, 4-61, 4-62, 4-63, 4-64, 4-65, 4-66, 4-67, 4-68, 4-69, 4-75, 4-132, 4-134, 4-147, 

4-156, 4-158, 4-159, 4-165, 4-181, 4-198, 4-200, 4-214, 4-226, 4-245, 4-249, 4-250, 4-254, 4-263, 

4-284, 4-292, 4-321, 4-329, 4-331, 4-348, 4-349, 4-396, 4-432, 4-478, 4-486, 4-487, 4-488, 4-493
Keyword Index Keywords-11

Wetlands, ix, xvi, xxi, 2-31, 2-32, 2-35, 2-40, 3-42, 3-89, 3-152, 3-188, 3-191, 3-196, 3-197, 3-198, 

3-199, 3-203, 3-204, 3-205, 4-7, 4-56, 4-69, 4-70, 4-71, 4-72, 4-73, 4-75, 4-76, 4-77, 4-78, 4-79, 

4-80, 4-81, 4-82, 4-83, 4-84, 4-85, 4-86, 4-87, 4-88, 4-89, 4-90, 4-91, 4-92, 4-93, 4-94, 4-95, 4-96, 

4-99, 4-100, 4-111, 4-216, 4-230, 4-233, 4-236, 4-247, 4-248, 4-251, 4-252, 4-255, 4-343, 4-346, 

4-347, 4-348, 4-350, 4-378, 4-379, 4-393, 4-395, 4-396, 4-397, 4-418, 4-421, 4-426, 4-480, 4-482, 

4-486, 4-487, 4-489, 4-490, 4-493, 5-9, 5-10, 5-11, 5-13


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The Department of the Interior protects and manages the Nation’s natural 

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about those resources; and honors the Nation’s trust responsibilities or 

special commitments to American Indians, Alaska Natives, and affiliated 

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The Bureau of Ocean Energy Management (BOEM) is responsible for 

managing development of U.S. Outer Continental Shelf energy and mineral 

resources in an environmentally and economically responsible way.