U.S. Department of the Interior

Minerals Management Service 

Gulf of Mexico OCS Region 

OCS EIS/EA 

MMS 2004-068 

Environmental Assessment 

Proposed OCS Lease Sale 194, 

Central Gulf of Mexico 
U.S. Department of the Interior

Minerals Management Service 

Gulf of Mexico OCS Region 

OCS EIS/EA 

MMS 2004-068 

Environmental Assessment 

Proposed OCS Lease Sale 194, 

Central Gulf of Mexico 

Author 

Minerals Management Service 

Gulf of Mexico OCS Region 

Published by 

New Orleans

November 2004 

Environmental Assessment iii 

TABLE OF CONTENTS 

Page 

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

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

2. PURPOSE OF AND NEED FOR THE PROPOSED ACTION.............................................................1

3. ALTERNATIVES INCLUDING THE PROPOSED ACTION .............................................................2

3.1. Alternative A—Proposed Action ................................................................................................2

3.2. Alternatives to the Proposed Action ...........................................................................................2

3.3. Mitigation Measures ...................................................................................................................3

3.3.1. Protected Species Stipulation .......................................................................................3

3.3.2. Notices to Lessees and Operators.................................................................................4

4. IMPACT ANALYSIS.............................................................................................................................8

4.1. Update of Projections of Potential Activity from the Proposed Action......................................8

4.1.1. Resource Estimates and Timetables.............................................................................8

4.1.2. Hurricane Lili ...............................................................................................................9

4.1.3. Louisiana’s Artificial Reef Program ............................................................................9

4.1.4. Geological and Geophysical Activities........................................................................9

4.1.5. Structure Removal Operations ...................................................................................10

4.2. Update of Information on the Affected Environment...............................................................10

4.2.1. Marine Mammals .......................................................................................................10

4.2.2. Sea Turtles..................................................................................................................11

4.2.3. Gulf Sturgeon Critical Habitat Designation ...............................................................11

4.2.4. Snowy Plover .............................................................................................................12

4.3. Update of Potential Cumulative Activities ...............................................................................12

4.3.1. Liquefied Natural Gas Projects ..................................................................................12

4.3.2. Sand Dredging Projects..............................................................................................13

4.4. Impacts from Alternative A—The Proposed Action ................................................................14

4.4.1. Summary of Analysis Incorporated by Reference from the Multisale EIS................14

4.4.1.1. Impacts on Coastal Resources...................................................................15

4.4.1.2. Impacts on Offshore Environments ..........................................................16

4.4.2. Updated Impact Analysis for the Proposed Action ....................................................18

4.4.2.1. Marine Mammals......................................................................................18

4.4.2.2. Sea Turtles.................................................................................................19

4.4.2.3. Gulf Sturgeon Critical Habitat Designation..............................................19

4.4.2.4. Snowy Plover............................................................................................20

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

Topographic Features................................................................................................................20

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

Baldwin County, Alabama, Coast.............................................................................................21

4.7. Alternative D—No Action........................................................................................................21

4.8. Cumulative Analysis.................................................................................................................21

4.8.1. Marine Mammals .......................................................................................................21

4.8.2. Sea Turtles..................................................................................................................22
Environmental Assessment iv 

4.8.3. Gulf Sturgeon Critical Habitat Designation ...............................................................22

4.8.4. Snowy Plover .............................................................................................................23

4.8.5. Liquefied Natural Gas Projects ..................................................................................24

4.8.6. Sand Dredging Projects..............................................................................................24

5. CONSULTATION AND COORDINATION ......................................................................................25

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

Sale 194.....................................................................................................................................25

5.2. Consultation and Coordination Calendar..................................................................................28

6. REFERENCES .....................................................................................................................................29

APPENDIX A. NOTICES TO LESSEES AND OPERATORS (NOVEMBER 2002 — PRESENT)....31

APPENDIX B. PUBLICATIONS OF THE ENVIRONMENTAL STUDIES PROGRAM, GULF OF 

MEXICO OCS REGION (NOVEMBER 2002 — PRESENT)......................................34
Environmental Assessment v 

FIGURES 

 Page 

Figure 1. GOM OCS Planning Areas and CPA Offshore Subareas.......................................................2

Figure 2. Snowy Plover Habitat. ..........................................................................................................12

Figure 3. Satellite Image of Coastal Louisiana Shoreline Showing (1) the Location of the Isles 

Dernieres Barrier Island Arc, (2) the Whiskey Island/New Cut Tidal Channel Locations 

for Beach Restoration Projects, and (3) the Proposed OCS Sand Borrow Polygons............14

Figure 4. Probability of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days Known 

Locations of Gulf Sturgeon as a Result of the Proposed Action...........................................20

TABLES 

Page 

Table 1 Estimated Abundance of Cetaceans in the Northern GOM Oceanic Waters........................11

Table 2 LNG Applications in the GOM.............................................................................................13
Environmental Assessment vi 

ABBREVIATIONS AND ACRONYMS 

5-Year Program Outer Continental Shelf Oil 

and Gas Leasing Program 

2002-2007

ADCP Acoustic Doppler Current 

Profile 

bbl barrel 

BBO billion barrels of oil 

BML below mud line 

BO Biological Opinion 

Btu British thermal unit 

Call Call for Information and 

Nominations 

CD Consistency Determination 

COE United States Army Corps of 

Engineers 

CPA Central Planning Area 

CWPPRA Coastal Wetlands Planning, 

Protection, and Restoration 

Act 

CZM Coastal Zone Management 

DWPA Deepwater Ports Act 

EA Environmental Assessment 

EFH essential fish habitat 

EIS Environmental Impact 

Statement 

EPA Eastern Planning Area 

ESA Endangered Species Act of 

1973 

FONSI Finding of No Significant 

Impact 

FWS U.S. Fish and Wildlife 

Service 

G&G geological and geophysical 

GBS gravity-based structure 

GOM Gulf of Mexico 

ITS Incidental Take Statement 

LARI Louisiana Artificial Reef 

Initiative 

LCA Louisiana Coastal Area 

LDWF Louisiana Department of 

Wildlife and Fisheries 

LNG liquefied natural gas 

MARAD Maritime Administration 

MMPA Marine Mammal Protection 

Act of 1972 

MMS Minerals Management 

Service 

MODU mobile offshore drilling unit 

NEPA National Environmental 

Policy Act 

NOAA National Oceanic and 

Atmospheric 

Administration 

NOI Notice of Intent to Prepare an 

EIS 

NOx nitrogen oxide 

NPDES National Pollution Discharge 

Elimination System 

NTL Notice to Lessees and 

Operators 

OCS Outer Continental Shelf 

OSRA Oil-Spill Risk Analysis 

PEA Programmatic Environmental 

Assessment 

PEIS Programmatic EIS 

PM10 particulate matter smaller 

than 10 microns 

ROV remotely operated vehicle 

SBF synthetic-based drilling fluids 

Secretary Secretary of the Interior 

SOx sulphur oxide 

SWAMP Sperm Whale Acoustic 

Monitoring Program 

SWSS Sperm Whale Seismic Survey 

TAOS Technical Assessment and 

Operation Support 

Tcf trillion cubic feet 

USCG United States Coast Guard 

USDOI United States Department of 

the Interior 

USDOT United States Department of 

Transportation 

USEPA United States Environmental 

Protection Agency 

WPA Western Planning Area 
Environmental Assessment 1 

1. OBJECTIVES OF THE ENVIRONMENTAL ASSESSMENT 

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

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

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

2002-2007 (5-Year Program) (USDOI, MMS, 2002a). This EA incorporates by reference all of the 

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

Mexico OCS Oil and Gas Lease Sales: 2003-2007; Central Planning Area Sales 185, 190, 194, 198, and 

201; Western Planning Area Sales 187, 192, 196, and 200; Final Environmental Impact Statement; 

Volumes I and II (USDOI, MMS, 2002b)). The EA has been prepared to aid in the determination of 

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

significant impacts not addressed in the multisale EIS. 

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

Service (MMS) reexamined the potential environmental effects of the proposed action and the alternatives 

based on any new information regarding potential impacts and issues not available at the time MMS 

prepared the multisale EIS in November 2002. New information was reviewed to determine if any 

resources should be reevaluated or if the new information would alter conclusions of the multisale EIS. It 

was determined that four resources (marine mammals, sea turtles, Gulf sturgeon, and snowy plover) 

should be reevaluated because of new information. The new information for these four resources is the 

mitigation measures for protected species, the designation of critical habitat for the Gulf sturgeon, and a 

revised oil-spill probability for the snow plover. 

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

1502.4). Since the CPA Lease Sales 185, 190, 194, 198, and 201 and their projected activities are very 

similar, if not almost identical, MMS prepared a single EIS for the five lease sales. The multisale 

approach focuses the National Environmental Policy Act (NEPA) EIS process on the differences between 

the proposed lease sales and new information and issues. Although the multisale EIS addressed five 

proposed CPA lease sale actions, the Secretary of the Interior (Secretary) makes a separate decision for 

each lease sale. 

The multisale EIS can be obtained from the Minerals Management Service, Gulf of Mexico OCS 

Region, Attention: Public Information Office (MS 5034), 1201 Elmwood Park Boulevard, Room 114, 

New Orleans, Louisiana 70123-2394 (1-800-200-GULF) or viewed on the MMS website at 

http://www.gomr.mms.gov. A list of libraries that have copies of the multisale EIS and their locations is 

also available on the MMS Internet website. 

2. PURPOSE OF AND NEED FOR THE PROPOSED ACTION 

Purpose of the Proposed Action 

The purpose of this proposed action (CPA Lease Sale 194) is to offer for lease all unleased blocks in 

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

resources. The proposed lease sale would provide qualified bidders the opportunity to bid upon and lease 

acreage in the proposed lease sale area in order to explore, develop, and produce oil and natural gas. 

Need for the Proposed Action 

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

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

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

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

terms of both production and consumption. 
Environmental Assessment 2 

3. ALTERNATIVES INCLUDING THE PROPOSED ACTION 

3.1. ALTERNATIVE A—PROPOSED ACTION

Alternative A—The Proposed Action: Under proposed CPA Lease Sale 194, MMS would offer for 

lease all unleased blocks within the CPA for oil and natural gas operations, with the following exceptions: 

Lund South (Area NG16-07) Blocks 172, 173, 213-217, 252-261, 296-305, and 349; Amery Terrace 

(Area NG15-09) Blocks 280, 281, 318-320, and 355-359; and portions of Amery Terrace (Area NG15-

09) Blocks 235-238, 273-279, and 309-359, which are deferred from the proposed action under the 

“Treaty Between the Government of the United States of America and the Government of the United 

Mexican States on the Delimitation Of The Continental Shelf in the Western Gulf of Mexico Beyond 200 

Nautical Miles.” The CPA encompasses about 47.8 million ac in water depths ranging from 4 to 3,400 m 

(Figure 1). The estimated amount of resources projected to be developed as a result of proposed CPA 

Lease Sale 194 is 0.276-0.654 billion barrels of oil (BBO) and 1.590-3.300 trillion cubic feet (Tcf) of 

natural gas. 

In the multisale EIS, a proposed action is presented as a set of ranges for resource estimates, projected

exploration and development activities, and impact-producing factors. All of the proposed CPA lease 

sales analyzed in the multisale EIS is expected to be within the scenario ranges presented for a typical 

CPA lease sale; therefore, a proposed action is representative of each proposed lease sale. 

Figure 1. GOM OCS Planning Areas and CPA Offshore Subareas. 

3.2. ALTERNATIVES TO THE PROPOSED ACTION

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

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

described for the proposed action, with the exception of any unleased blocks within the 167 blocks

subject to the Topographic Features Stipulation. 

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

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

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

County, Alabama, coast. 

Alternative D — No Action: This alternative is equivalent to the cancellation of the proposed CPA 

Lease Sale 194. The opportunity for development of the estimated 0.276-0.654 BBO oil and 1.590-3.300

Tcf of natural gas resources that could have resulted from the proposed action would be precluded or 
Environmental Assessment 3 

postponed. Any potential environmental impacts resulting from the proposed action would not occur or 

would be postponed. 

3.3. MITIGATION MEASURES

The proposed action and all subsequent activities resulting from it are subject to the existing 

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

legally binding restrictions and operating requirements that are made a part of every oil and gas lease 

document. Six stipulations will be applied to leases resulting from CPA Lease Sale 194 as and if 

appropriate. Five of the stipulations (Topographic Features; Live Bottom (Pinnacle Trend); Military 

Areas; Blocks South of Baldwin County, Alabama; and Law of the Sea Convention Royalty Payment 

Stipulations) are included in the multisale EIS. Chapter 2.3.1.3. of the multisale EIS discusses the 

effectiveness of these stipulations. 

Following the completion of the multisale EIS, an additional stipulation, Protected Species, was 

adopted for CPA Lease Sale 185 (March 2003), which was the first CPA lease sale held under the 

multisale EIS. Its requirements, which are described below in Chapter 3.3.1., also apply to CPA Lease 

Sale 194. The Protected Species Stipulation was developed in consultation with the National Oceanic and 

Atmospheric Administration (NOAA) and the U.S. Fish and Wildlife Service (FWS). A seventh 

stipulation is in development and will be recommended to apply to portions of Vermilion Blocks 139 and 

140 that are involved with approved liquefied natural gas (LNG) projects. Instead of deferring these 

blocks, all exploration, development, and production activities or operations must take place from outside 

the lease by the use of directional drilling or other techniques. 

The MMS has also issued 35 Notices to Lessees and Operators (NTL) since the completion of the 

multisale EIS in order to 

• clarify, describe, or interpret regulation or OCS standards; 

• provide guidelines on the implementation of a special lease stipulation or regional 

requirement; 

• provide a better understanding of the scope and meaning of a regulation by 

explaining MMS interpretation of a requirement; or 

• transmit administrative information. 

A list of the new NTL’s can be found in Appendix A, while the actual NTL’s are on the MMS 

Internet website at www.gomr.mms.gov/homepg/regulate/regs/ntls/ntl_lst.html. The requirements 

addressed in these NTL’s apply to all existing and future oil and natural gas operations on the GOM OCS. 

Five of the new NTL’s (Vessel Strike Avoidance and Injured/Dead Protected Species Reporting; Marine 

Trash and Debris Awareness and Elimination; Implementation of Seismic Survey Mitigation Measures 

and Protected Species Observer Program; Biologically Sensitive Areas of the Gulf of Mexico; and 

Structure-Removal Operations) and the proposed Deepwater Ocean Current Monitoring on Floating 

Facilities NTL are discussed in Chapter 3.3.2.

3.3.1. Protected Species Stipulation 

The Protected Species Stipulation is designed to minimize or avoid potential adverse impacts to 

federally protected species (e.g., sea turtles, marine mammals, Gulf sturgeon, and other listed species). 

To reduce the potential taking of federally protected species 

(1) The MMS conditions all permits issued to lessees and their operators to require them 

to collect and remove flotsam resulting from activities related to exploration, 

development, and production of this lease. 

(2) The MMS conditions all permits issued to lessees and their operators to require them 

to post signs in prominent places on all vessels and platforms used as a result of 
Environmental Assessment 4 

activities related to exploration, development, and production of this lease detailing 

the reasons (legal and ecological) why the release of debris must be eliminated. 

(3) The MMS requires that vessel operators and crews watch for marine mammals and 

sea turtles, reduce vessel speed to 10 kt or less when assemblages of cetaceans are 

observed, and maintain a distance of 90 m or greater from whales and a distance of 

45 m or greater from small cetaceans and sea turtles. 

(4) The MMS requires that all seismic surveys employ mandatory mitigation measures 

including the use of a 500-m “exclusion zone” based upon the appropriate water 

depth, ramp-up and shut-down procedures, visual monitoring, and reporting. Seismic 

operations must immediately cease when whales are detected within the 500-m 

exclusion zone. Ramp-up procedures and seismic surveys may be initiated only 

during daylight unless alternate monitoring methods approved by MMS are used. 

(5) The MMS requires lessees and operators to instruct offshore personnel to 

immediately report all sightings and locations of injured or dead protected species 

(marine mammals and sea turtles) to the appropriate stranding network. If oil and gas 

industry activity is responsible for the injured or dead animals (e.g., because of a 

vessel strike), the responsible parties should remain available to assist the stranding 

network. If the injury or death is caused by a vessel collision, the responsible party 

must notify MMS within 24 hours of the strike. 

(6) The MMS requires oil-spill contingency planning to identify important habitats, 

including designated critical habitat, used by listed species (e.g., sea turtle nesting 

beaches, and piping plover critical habitat) and will require the strategic placement of 

spill cleanup equipment to be used only by personnel trained in less intrusive cleanup 

techniques on beach and bay shores. 

The analyses of potential proposed action impacts to marine mammals, sea turtles, Gulf sturgeon, and 

snowy plover are presented in Chapter 4.2. of this EA. 

3.3.2. Notices to Lessees and Operators 

Vessel Strike Avoidance and Injured/Dead Protected Species Reporting (NTL 2003-G10) 

The Vessel Strike Avoidance and Injured/Dead Protected Species Reporting NTL (NTL 2003-G10) 

provides the following guidelines to minimize the risk of vessel strikes to protected species and report 

observations of injured or dead protected species. 

Protected Species Identification Training 

Vessel crews are to use a GOM reference guide to identify marine mammals and sea turtles. 

Vessel Strike Avoidance 

The following guidelines are included: 

(1) Vessel operators and crews should maintain a vigilant watch for marine mammals 

and sea turtles and slow down or stop their vessels to avoid striking protected species. 

(2) When a whale is sighted, a distance of 90 m or greater from the whale should be 

maintained. 

(3) When sea turtles or small cetaceans are sighted, there should be an attempt to 

maintain a distance of 45 m or greater whenever possible. 
Environmental Assessment 5 

(4) When cetaceans are sighted while a vessel is underway, there should be an attempt to 

remain parallel to the animals’ course. Excessive speed or abrupt changes in 

direction until the cetaceans have left the area should be avoided. 

(5) Vessel speed should be reduced to 10 kt or less when pods or large assemblages of 

cetaceans are observed near an underway vessel. Cetaceans at the surface may 

indicate the presence of submerged animals near the vessel. 

(6) Whales may surface in unpredictable locations or approach slowly moving vessels. 

When animals are sighted in the vessel’s path or in close proximity to a moving 

vessel, speed should be reduced and the engine shifted to neutral. Engines should not 

be engaged until the animals are clear of the area. 

Injured/Dead Protected Species Reporting 

Vessel crews must report sightings of any injured or dead protected species (marine mammals and sea 

turtles) immediately to the Marine Mammal and Sea Turtle Stranding Hotline or the Marine Mammal 

Stranding Network. If oil and gas industry activity is responsible for the injury or death of a protected 

species, MMS must be notified within 24 hours and the responsible parties should remain available to 

assist the respective salvage and stranding network as needed. 

Marine Trash and Debris Awareness and Elimination (NTL 2003-G11) 

The Marine Trash and Debris Awareness and Elimination NTL (NTL 2003-G11) provides guidance 

to reduce the accidental introduction of marine trash and debris into the GOM. This NTL requires the 

placement of marine debris elimination placards, with specified language, in prominent places on all fixed 

and floating production facilities that have sleeping or food preparation capabilities, and on all mobile 

drilling units engaged in oil and gas operations in the GOM OCS. This NTL also requires marine debris 

awareness training for all offshore employees and contractors actively engaged in offshore operations. 

This training includes viewing a training video or slide show and receiving an explanation from the 

company’s management that emphasizes their commitment to achieve the objectives of the trash and 

debris containment requirement. This NTL describes certification guidelines including the preparation of 

an annual report to MMS from a company official that describes the marine trash and debris awareness 

training process and certifies that the training process has been followed for the previous calendar year. 

Implementation of Seismic Survey Mitigation Measures and Protected Species Observer 

Program (NTL 2004-G01) 

The MMS superseded NTL 2003-G08, Implementation of Seismic Survey Mitigation Measures and 

Protected Species Observer Program, with NTL 2004-G01. The new NTL, which expands application of 

the seismic survey mitigation measures to include additional marine mammal species, became effective 

March 1, 2004. 

The Implementation of Seismic Survey Mitigation Measures and Protected Species Observer Program 

NTL (NTL 2004-G01) details information on ramp-up procedures, observation methods, and reporting 

requirements to be followed by the seismic industry during certain geological and geophysical (G&G) 

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

nearby marine mammals and sea turtles. The report data received from the companies will be used to 

increase the knowledge base on species habitat. 

For all seismic operations in water depths >200 m in the Western Planning Area (WPA) and CPA, 

and all water-depths in the Eastern Planning Area (EPA), this NTL requires the use of soft start or rampup and visual observers as required in the previous NTL’s. This NTL includes requirements for 

(1) seismic vessels to have at least two visual observers on watch during all daylight 

hours when geophysical operations are being conducted; 

(2) visual observers to have completed a training course; 

(3) no additional duties to be assigned to visual observers during their watch; 
Environmental Assessment 6 

(4) limiting watch and duty hours for observers; 

(5) elements that must be included in the training course; 

(6) methods to be employed for visual observations; 

(7) “all clear” prior to ramp-up; 

(8) shutdown of seismic airguns when whales are within 500 m of the center of the 

airgun array; 

(9) restart of survey after shutdown; and 

(10) reporting required information, including types of reports and submission of reports 

to MMS. 

This NTL also contains special provisions for borehole, or vertical seismic profiling, operations and a 

special mitigation exception for seismic vessels that employ experimental passive acoustic monitoring. 

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

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

embodied in the more comprehensive NTL 2004-G05, Biologically Sensitive Areas of the Gulf of 

Mexico. In addition to existing stipulated areas for biological features, a new category of protected area 

has been established under NTL 2004-G05 termed “Potentially Sensitive Biological Features.” These are 

hard-bottom features not protected by a biological lease stipulation that are of moderate to high relief 

(about 8 ft or higher), provide surface area for the growth of sessile invertebrates, and can attract large 

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

topographic features (banks) or the 70 live-bottom (pinnacle trend) stipulated blocks. 

Structure-Removal Operations (NTL 2004-G06) 

The Structure-Removal Operations NTL (NTL 2004-G06) provides lessees with updated information 

on Endangered Species Act (ESA) consultations and the monitoring and reporting requirements to be 

followed by the operators and severance subcontractors during decommissioning operations. This NTL 

also addresses MMS’s position on decommissionings using explosive-severance tools in light of the 

recent expiration of Marine Mammal Protection Act (MMPA) take-regulations (50 CFR 216.141-147). 

As detailed in the NTL, MMS currently permits decommissioning operations conditional on two 

Biological Opinions (BO) from NOAA Fisheries subsequent to consultations conducted under Section 7 

of the ESA. Issued in July 1988, the “generic” consultation BO and its Incidental Take Statement (ITS) 

identifies the terms and conditions of operation for explosive-severing activities using charges that range 

from >5 to 50 lb (http://www.gomr.mms.gov/homepg/regulate/environ/generic-consultation.pdf). 

In October 2003, NOAA Fisheries issued a second BO, the “de minimus” BO, that lists 

minimization measures that apply to explosive-severing charges ≤0-5 lb (http://www.gomr.mms.gov/

homepg/regulate/environ/de-minimus-consultation.pdf). Both BO’s define specific operational criteria 

that explosive-severing activities must follow. These criteria include 

(1) the use of high-velocity explosives (i.e., detonation rates >7,600 m per second); 

(2) a maximum of eight individual blasts per group of detonations; 

(3) blast staggering at an interval of 0.9 seconds (900 milliseconds); 

(4) charge placement no less than 15 ft below the mudline (BML); and 

(5) maximum charge sizes of either 5 lb (for the “de minimus” consultation) or 50 lb (for 

the “generic” consultation). 

This NTL contains special provisions to lessees applying for permits on decommissioning operations 

suggesting activities that do not fall within the above-listed criteria. Discussion is also made on the 
Environmental Assessment 7 

specific penalties prescribed under the ESA and MMPA when an unauthorized take (i.e., harassment, 

harm, injury, or mortality) of a marine mammal or sea turtle occurs. Ultimately, the conditions described 

under and referenced within this NTL aid in reducing the chance of harassment or injury to marine 

mammals and sea turtles in the vicinity of removal activities. 

Deepwater Ocean Current Monitoring on Floating Facilities (Proposed NTL) 

Recently a limited number of high-speed, ocean water current events, at times approaching 2 kt, were 

observed at depths exceeding 1,500 m in the northern GOM (Hamilton et al., 2003; USDOI, MMS 2002 

and 2003). Similar high-speed current events have been identified in ongoing MMS current measurement 

studies in the north-central GOM. In addition, high-speed current events do not appear to be an isolated 

or exceptionally unusual occurrence in the northern GOM. Mega-furrows on the seafloor have been 

discovered in the northern GOM, apparently because of the erosional effects of high-speed currents. 

Further, several deepwater oil and gas operators also have observed very high-speed midwater jets 

exceeding 150 cm per second over the upper continental slope. Causes of these jet events remain 

uncertain until further data is collected (Dimarco et al., 2004). 

Ocean current speeds used by industry in the design, operation, and function of mobile offshore 

drilling units (MODU’s), floating production platforms, and their ancillary equipment (i.e., drilling and 

production risers, tendons, and mooring systems) may have been underestimated in the past. At some 

locations in the GOM, 10-year Loop Current events have been exceeded and, in certain instances, deep 

ocean currents were not measured or underestimated current speeds were considered in designs. Recent 

incidents have demonstrated to the MMS GOM Region a need for more site-specific data for use in 

hindcasting and forecasting ocean currents that may affect structural design, fatigue criteria, or daily 

operations. 

The MMS has drafted a new NTL (Deepwater Ocean Current Monitoring on Floating Facilities) 

relevant to these concerns; it is expected to be issued October 2004 and effective April 2005. The new 

NTL establishes and implements the following program to monitor ocean currents and share the data for 

all floating MODU’s and production facilities operating or installed in waters depths >400 m (1,312 ft). 

Floating MODU’s 

(1) Floating MODU’s will continuously monitor and gather ocean current data on a realtime basis from near the ocean surface (~30 m (100 ft)) to ~1,000 m (3,280 ft) using 

an Acoustic Doppler Current Profile (ADCP) current monitoring system or 

comparable equipment, mounted as near to the ocean surface as practicable. 

(2) During drilling operations, if currents are measured with speeds >0.75 kt at the 

maximum range of the ADCP (or comparable equipment) for more than 24 hours, all 

current data below the maximum range of the ADCP will be monitored and gathered 

while any remotely operated vehicle (ROV) operations or inspections are conducted. 

An ADCP or point current meter installed on the ROV will be used to obtain data on 

all ROV operations or inspections until the well is completed. 

(3) In water depths >1,100 m (3,608 ft), a current meter, preferably an upward looking 

ADCP, must be installed near the ocean bottom (~100 m (328 ft) from the seafloor). 

Data collected by floating MODU’s must be recorded and reported to an industryaccessible Internet website. 

Planned Floating Production Facilities 

Prior to installing a planned floating production facility, a full water-column mooring must be 

deployed to collect at least one year of site-specific current data at the planned floating production facility 

location. These current data must extend from near the ocean surface (~30 m (100 ft)) to near the ocean 

bottom (~100 m (328 ft) from the seafloor). The moorings should include point current meters spaced no 

more than 500 m (1,640 ft) apart, an ADCP array, or some combination of point current meters and 

ADCP’s. Data should be time averaged as specified in the NTL, which also describes what must be 
Environmental Assessment 8 

reported to an industry-accessible Internet website. Data collected during the drilling phase may be used 

as part of the one year of site-specific current data. 

Existing Floating Production Facilities 

(1) An ADCP current monitoring system or comparable equipment must be used to 

continuously monitor and gather ocean current data on a real-time basis from near the 

surface (~30 m (100 ft)) to ~1,000 m (3,280 ft) for existing floating production 

facilities. The ADCP (or comparable equipment) must be mounted as near to the 

ocean surface as possible. Details of time averaging, data processing, and reporting 

to an industry-accessible Internet website are discussed in the NTL. 

(2) Floating production facilities located in water depths >1,100 m (3,608 ft) must install 

a current meter, preferably an upward looking ADCP, to continuously monitor and 

record speed and direction of the near-bottom current (~100 m (328 ft) from the 

seafloor). Once every 6 months and whenever a near-bottom current event >1 kt is 

presumed to have occurred, the data must be retrieved and examined. Whenever 

average currents >1 kt are measured for more than 24 hours by any component, the 

MMS GOM Region Technical Assessment and Operation Support (TAOS) Section 

must be immediately notified and a full water-column mooring must be installed that 

contains point current meters spaced no more than 500 m (1,640 ft) apart, an ADCP 

array, or some combination of point current meters and ADCP’s. Details of time 

averaging, data processing, and reporting to an industry-accessible Internet website 

are discussed in the NTL. 

(3) Operators of existing floating production facilities must provide to the MMS GOM 

Region TAOS Section by January 1, 2005, the monitoring equipment type, the date 

of installation, the depth range of the monitoring equipment, and the Internet website 

address where the operator proposes to publish the data. 

Suggested methods for data time averaging and the reporting of any current data that is not required 

are specified in the NTL. The NTL also lists exclusions from the above requirements and other details 

related to data collection and reporting. 

4. IMPACT ANALYSIS 

4.1. UPDATE OF PROJECTIONS OF POTENTIAL ACTIVITY FROM THE PROPOSED 

ACTION

4.1.1. Resource Estimates and Timetables 

The multisale EIS discusses projections for activities associated with a typical proposed CPA lease 

sale. The estimated amounts of resources projected to be leased, discovered, developed, and produced as 

a result of the proposed CPA Lease Sale 194 are 0.276-0.654 BBO and 1.590-3.300 Tcf of natural gas. 

The oil and gas resource projections and associated activities used in the multisale EIS are based on the 

2000 Assessment of Conventionally Recoverable Hydrocarbon Resources of the Gulf of Mexico and 

Atlantic Outer Continental Shelf as of January 1, 1999 (Lore et al., 2001). The MMS is currently in the 

process of updating the 2000 National Resource Assessment and has recently revised the deep gas 

resource estimate on the shelf. This revision is based on knowledge gained from recent deep drilling 

activity in this area, prompting the addition of a new “Deep Shelf Mesozoic” play to the assessment. 

Although MMS anticipates a significant increase in total undiscovered conventionally recoverable deep 

gas resources on the shelf as reported, a significant portion of these newly assessed deep gas resources are 

either currently under lease or are uneconomic at this time. The MMS GOM Region’s Office of Resource 

Evaluation reviewed the oil and natural gas resource projections and associated activities for CPA Lease 

Sale 194 and confirmed that they are still valid; they are therefore incorporated by reference. 
Environmental Assessment 9 

4.1.2. Hurricane Lili

As discussed in Chapter 1.5. of the multisale EIS, criteria, models, and procedures for shutdown 

operations and the orderly evacuation of personnel prior to a pending hurricane have been in place on the 

GOM OCS for more than 30 years. Operating experience from extensive drilling activities and the 

presence of more than 4,000 platforms during the 30-plus years of the GOM OCS Program has proven the 

effectiveness and safety of securing wells and evacuating a facility in advance of severe weather 

conditions. This was evident in early October 2002 when Hurricane Lili, a Category 4 hurricane, passed 

near 800 OCS structures in the GOM. Of 800 structures, 6 were seriously damaged. All six were more 

than 20 years old. Of the 99 drilling rigs in the GOM at that time, 4 sustained substantial damage. About 

25,000 offshore workers were safely evacuated (USDOI, MMS, 2002c). 

Nine pollution events occurred as a result of Hurricane Lili. The only significant incident was a 350-

barrel (bbl) oil spill at Ship Shoal Block 119. The other eight pollution events ranged from 0.14 gal to 3 

bbl. In August 2003, MMS published a report that recorded the transport and fate of oil spilled at Ship 

Shoal Block 119 during Hurricane Lili (USDOI, MMS, 2003a). The report states that the lessee mounted 

an appropriate response and the response was complicated by hurricane-related onshore conditions. 

Approximately 145 bbl of oil were recovered and 205 bbl of oil dissipated. No shoreline or wildlife 

impacts were reported. No birds were fouled. The unrecovered oil was removed from the surface of the 

water by natural weathering processes including evaporation, dissolution in the water, adsorption to 

particulate material, and biodegradation. The lessee, Murphy Exploration and Production Company, the 

U.S. Coast Guard, the Louisiana Oil Spill Coordinator’s Office, oil-spill-response organizations, and 

MMS have discussed the response (Bedell, 2004). 

4.1.3. Louisiana’s Artificial Reef Program 

Louisiana passed legislation in 2002 requiring that the Louisiana Artificial Reef Program be reviewed 

and recommendations be made to improve and revise the program where necessary. Public hearings were 

held in March and April 2003 for offshore shrimpers to identify areas where artificial reefs would not 

interfere with shrimping. The 2003 public hearings, held across the state by the Louisiana Department of 

Wildlife and Fisheries (LDWF), were reported to be poorly attended. 

In response to the State legislation, the LDWF reconvened a Louisiana Artificial Reef Initiative 

(LARI) committee to review, discuss, and provide recommendations to the Louisiana Artificial Reef 

Council in an effort to update the LDWF Artificial Reef Program. Four recommendations to the Council 

were made by the LARI committee: 

(1) establish deepwater (>400 ft) artificial reef sites; 

(2) reconfigure the existing nine artificial reef planning areas; 

(3) establish a committee to evaluate the Special Artificial Reef Sites (SARS) — 

Amendment 2; and 

(4) establish an inshore (shore to 100 ft) artificial reef working group. 

The Artificial Reef Council approved deepwater reef sites and an inshore reef working group. The 

Council deferred the LARI committee’s recommendation to reconfigure the existing reef planning areas 

to create smaller planning areas, which would target areas of higher density of platforms. No action was 

taken by the Council on the LARI committee’s recommendation to establish a committee comprised of 

representatives of the shrimping industry, oil and gas industry, MMS, biologists, and various other user 

groups for evaluation of the permitting of SARS. 

4.1.4. Geological and Geophysical Activities 

Geological and geophysical activities are performed to obtain information on surface and near-surface 

geology and on subsurface geologic formations. The MMS has completed a programmatic EA (PEA) on 

G&G activities in the GOM (USDOI, MMS, 2004a). The activities analyzed in the PEA include seismic 

surveys, deep-tow side-scan surveys, electromagnetic surveys, geological and geochemical sampling, and 
Environmental Assessment 10 

remote-sensing surveys. The impact-producing factors considered in the PEA include seismic survey 

noise, vessel and aircraft noise, seafloor disturbance, and space-use conflicts with seismic arrays. The 

notice of availability of the PEA was published in the Federal Register on July 30, 2004. The results of 

the analyses in the PEA are that G&G activities are not expected to result in significant adverse impacts to 

any of the potentially affected resources. The EA resulted in a Finding of No Significant Impact. 

4.1.5. Structure Removal Operations 

The MMS is preparing a PEA to assess the potential impacts that decommissioning activities, related 

to the severing and removal of seafloor obstructions and facilities (i.e., wellheads, caissons, casing strings, 

platforms, mooring devices, etc.) and subsequent salvage operations, have on the GOM. Preparation of 

the PEA is an important step in the decision process for future permitting for the removal of offshore 

structures and for further consultation and coordination with other Federal agencies. The PEA will be 

used as part of the rulemaking process by NOAA for incidental take regulations under Subpart I of the 

MMPA and to initiate consultation for explosive severance activities under Section 7 of the ESA. Topics 

of primary concern to be addressed in the PEA include pre-severance operations, severance technologies, 

industry needs related to water depth and location, and the potential impacts of decommissioning 

operations on the marine environment. On April 16, 2003, MMS published a Notice of Preparation in the 

Federal Register requesting information or issues that should be addressed in the PEA. Several 

comments were received with most centering on the need for increased “rigs-to-reef” options and 

concerns over NEPA procedure. The PEA is scheduled for completion in the Fall of 2004. 

4.2. UPDATE OF INFORMATION ON THE AFFECTED ENVIRONMENT

Chapter 3 and Appendix 9 of the multisale EIS provide a complete description as of 2002 of the 

affected environment for the proposed lease sale and are incorporated by reference (USDOI, MMS, 

2002b). For a number of resources (geology, meteorology, air quality, water quality, coastal barrier 

beaches and associated dunes, wetlands, deepwater benthic communities, topographic features, sea turtles, 

coastal and marine birds, fish resources, public services, infrastructure, land-use plans, sociocultural 

issues and environmental justice, commercial fisheries, recreational resources and beach use, 

archaeological resources, and coastal zone management plans), MMS has identified no new information 

since completion of the multisale EIS. 

The following summarizes the affected environment for resources MMS has determined should be 

reevaluated because of new information that was unavailable during the preparation of the multisale EIS. 

This includes information on protective measures for protected species, estimated population numbers of 

cetaceans in the GOM, designation of critical habitat for the Gulf sturgeon, a revised oil-spill probability 

for the snowy plover, proposed liquefied natural gas (LNG) projects, and proposed sand dredging 

projects. 

4.2.1. Marine Mammals 

Chapter 3.2.4. of the multisale EIS discusses nonendangered/nonthreathened and endangered/ 

threatened species of marine mammals known to occur in the GOM. Five mysticete (or baleen) whales 

(the northern right, blue, fin, sei, and humpback), one odontocete (or toothed) whale (the sperm whale), 

and one sirenian (the West Indian manatee) are listed as endangered. Sperm whales are common in the 

oceanic waters of the northern GOM. Sightings in all seasons and recent tag results indicate that there 

may be a resident population in the GOM in addition to migratory visitors. Baleen whales are not 

common. All five of the endangered baleen whales that occur in the GOM are considered rare or 

extralimital (Würsig et al., 2000). The most frequently observed baleen whale in the GOM is the 

nonendangered Bryde’s whale; it is considered uncommon in GOM waters. The West Indian manatee 

(Trichechus manatus) inhabits only coastal marine, brackish, and freshwater areas. 

For over a decade, MMS has funded and participated in research on marine mammals in the GOM. 

This research has included the GulfCet I and GulfCet II studies conducted in 1992-1999, the Sperm 

Whale Acoustic Monitoring Program (SWAMP) in 2000-2001, and the ongoing Sperm Whale Seismic 

Survey (SWSS) study initiated in 2002. Through these studies, the diverse cetacean community of the 
Environmental Assessment 11 

GOM has been documented, including the year-round sperm whale population. Many of these cruises 

included tissue sampling of numerous GOM cetacean species for genetic analysis. 

New information from NOAA Fisheries concerning estimated population numbers for cetaceans in 

the northern GOM is presented in Table 1 (USDOC, NOAA Fisheries, 2004). This is the first update by 

NOAA Fisheries in several years and more specific than the relative occurrence estimates provided in the 

multisale EIS. 

Since the new estimates are in agreement with the relative occurrence estimates presented in the 

multisale EIS, no new analysis is required as a result of the new estimates. Chapter 4.3.2.1. of this EA 

reevaluates the proposed action’s potential impact on marine mammals with the Protected Species 

Stipulation and NTL’s described in Chapter 3.3. 

Table 1 

Estimated Abundance of Cetaceans in the Northern GOM Oceanic Waters 

Species Common Name 

Estimated Number of 

Individuals 

Balaenoptera edeni Bryde’s whale 42 

Physeter macrocephalus Sperm whale 1,315 

Kogia spp. Dwarf or pygmy sperm whale 809 

Ziphius cavirostris Cuvier’s beaked whale 88 

Unidentified ziphiid Unidentified beaked whales 98 

Feresa attenuata Pygmy killer whale 443 

Pseudorca crassidens False killer whale 1,515 

Orcinus orca Killer whale 180 

Globicephala sp. Pilot whale 3,252 

Peponocephala electra Melonheaded whale 3,320 

Grampus griseus Risso’s dolphin 1,777 

Tursiops truncatus Bottlenose dolphin 26,852 

Steno bredanensis Rough-toothed dolphin 2,469 

Lagenodelphis hosei Fraser’s dolphin 698 

Stenella frontalis Atlantic spotted dolphin 39,545 

Stenella longirostris Spinner dolphin 11,550 

Stenella attenuate Pantropical spotted dolphin 93,174 

Stenella clymene Clymene dolphin 16,439 

Stenella coeruleoalba Striped dolphin 6,258 

Source: USDOC, NOAA Fisheries, 2004. 

4.2.2. Sea Turtles 

Five species of sea turtles are known to inhabit the waters of the GOM: the green, the loggerhead, the 

hawksbill, the Kemp’s ridley, and the leatherback (Pritchard, 1997). All sea turtle species inhabiting the 

GOM are listed as either endangered or threatened under the ESA of 1973 (Pritchard, 1997). Chapter 

3.2.5. of the multisale EIS presents information on the distribution, habitat, feeding, and nesting of sea 

turtles. Chapter 4.4.2.2. of this EA reevaluates the proposed action’s potential impact on sea turtles with 

the Protected Species Stipulation and NTL’s described in Chapter 3.3. 

4.2.3. Gulf Sturgeon Critical Habitat Designation 

In 1991, the Gulf sturgeon (Acipenser oxyrinchus desotoi) was listed as threatened. A recovery plan 

was developed to ensure the preservation and protection of Gulf sturgeon spawning habitat (USDOI, 

FWS, and Gulf States Marine Fisheries Commission, 1995). On April 18, 2003, critical habitat for the 

Gulf sturgeon was designated in Louisiana, Mississippi, Alabama, and Florida. The designation was 

published in the Federal Register on March 19, 2003. Critical habitat identifies specific areas that are 

essential to the conservation of Gulf sturgeon and that may require special management considerations or 
Environmental Assessment 12 

protections. Fourteen geographic areas among the GOM rivers and tributaries were designated critical 

habitat. These areas encompass approximately 2,783 river km (1,730 river mi) and 6,042 km2

 (2,333 mi

2

) 

of estuarine and marine habitat. The estuarine and marine critical habitat units extend from Lake Borgne 

in Louisiana to Suwannee Sound in Florida. Major shipping channels have been excluded in the Lake

Borgne and Pensacola Bay critical habitat units. Gulf sturgeon are discussed in Chapter 3.2.8. of the 

multisale EIS. Chapter 4.4.2.3. of this EA evaluates the proposed action’s potential impact on Gulf 

sturgeon critical habitat and reevaluates the potential impact with the Protected Species Stipulation and 

NTL’s described in Chapter 3.3. 

4.2.4. Snowy Plover 

Coastal and marine birds are discussed in Chapter 3.2.7. of the multisale EIS. The snowy plover

inhabits the areas identified in Figure 3. When commenting on the Draft EIS for EPA Lease Sales 189

and 197, published after the multisale EIS, FWS stated that snowy plover are present year round (USDOI, 

MMS, 2003b) as opposed to the period (February to August) that was used for the multisale EIS and the

EPA Draft EIS. Chapter 4.4.2.4. of this EA reevaluates the proposed action’s potential impact on snowy 

plover given this new information. 

Figure 2. Snowy Plover Habitat.

4.3. UPDATE OF POTENTIAL CUMULATIVE ACTIVITIES

4.3.1. Liquefied Natural Gas Projects 

Chapter 4.1.1.3.8.6., Alternative Transportation Methods of Natural Gas, of the multisale EIS 

discusses LNG. In late 2002, the Deepwater Ports Act (DWPA) was modified to include the 

establishment of natural gas ports on the OCS (the Maritime Transportation Security Act of 2002, Public 

Law 107-295, November 2002). The DWPA requires an applicant to file a deepwater port license 

application with the Secretary of the U.S. Department of Transportation (USDOT). The USDOT

Secretary has delegated the authority to process an application to the U.S. Coast Guard (USCG) and to the 

Maritime Administration (MARAD). To date, these agencies have received six applications for LNG

ports in the GOM. All of the proposed receiving terminals are located within the CPA. Table 2 provides

a brief description of each of the proposed projects. 

Specific information about each application can be obtained from the USDOT Internet website 

(http://www.dms.dot.gov) by using the USDOT Docket Number provided in Table 2 or by using the

project name in a “simple search.” All of the proposed LNG receiving terminals, except the Energy 

Bridge, plan to use a gravity-based structure (GBS) to store LNG and to support regasification equipment.

The Energy Bridge Project proposes to use a floating system. 
Environmental Assessment 13 

Table 2 

LNG Applications in the GOM 

Project Name Affiliations 

Preferred Location 

(Area and Block) 

Projected StartUp Date USDOT Docket 

Number 

Port Pelican ChevronTexaco Vermilion 140 2Q 2006 14134 

Energy Bridge Excelerate Energy West Cameron 603 1Q 2005 14294 

Gulf Landing Shell US Gas & 

Power 

West Cameron 213 Jan 2009 16860 

Compass Port ConocoPhillips Mobile Pass 910 Early 2009 17659 

Main Pass Energy Hub Freeport McMoRan 

Energy 

Main Pass 299 Dec 2007 17696 

Pearl Crossing ExxonMobil West Cameron 220 4Q 2008 18474 

4.3.2. Sand Dredging Projects 

The MMS has evaluated the use of sand resources from Ship Shoal Blocks 87, 88, 89, 94, and 95, and 

South Pelto Blocks 12, 13, 14, 18, and 19 for levee and barrier island restoration projects. As a result, 

MMS may enter into noncompetitive, negotiated sand and gravel leases with a third party on these blocks. 

In CPA Lease Sale 190, held in March 2004, MMS leased Ship Shoal Blocks 87, 88, and 89 with a 

stipulation to mitigate possible conflicts between sand dredging and oil and gas activities. The stipulation 

requires lessees to notify MMS in writing and to consult with the Chief, MMS Leasing Division, prior to 

construction or placement of any structure for exploration and development in areas leased for sand 

dredging. These activities include, but are not limited to, anchoring, well drilling, and pipeline and 

platform emplacement. 

The MMS will determine whether the planned activities conflict with ongoing or planned sand 

dredging operations. If MMS determines that a lessee’s planned activities conflict with sand dredging, 

MMS will require the lessee to conduct its operations in a manner to avoid such conflicts. The MMS will 

coordinate the activities of dredge and service vessels in order to minimize conflicts. The other blocks 

listed above (Ship Shoal Blocks 94 and 95 and South Pelto Blocks 12, 13, 14, 18, and 19) are also 

currently under lease. Should they become available for oil and gas leasing in the future, MMS would 

consider adoption of this stipulation for those blocks. 

Ship Shoal Multi-Project EA 

On July 6, 2004, MMS announced in the Federal Register the availability of an EA examining three 

separate sand dredging projects in the CPA (USDOI, MMS, 2004b). The EA resulted in a finding of no 

significant impact (FONSI). The proposed actions are to dredge approximately 15.5 million yd3 of OCS 

sand from Ship Shoal, an ancient and submerged barrier island. Two potential borrow areas are located 

approximately 10 mi (16 km) south of Isle Dernieres and the central coast of Louisiana (Figure 3). Each 

borrow polygon is approximately 10 mi2

. 

Two of the proposed leases are intended for the Louisiana Department of Natural Resources or 

Terrebonne Parish, Louisiana, for up to 3.5 million yd3

 of sand for the beach nourishment projects at New 

Cut and Whiskey Island in the Isles Dernieres barrier arc (Figure 3). These restoration projects are 

expected to benefit a maximum total of 1,341 ac (543 ha) of beach and adjacent tidal marsh and wetlands. 

The expected commencement dates for these projects are Spring of 2005. 

One proposed lease is intended for the U.S. Army Corps of Engineers (COE) for 12 million yd3

 of 

sand for the Morganza levee project. This project is scheduled to begin late in 2004 and involves sand 

removal during 20 months of continuous dredging and temporary storage inland at two impoundment 

sites in Terrebonne Parish near Houma, Louisiana. Levee construction would proceed over 12 years. 

Mitigations for the multiple Ship Shoal projects are discussed in Chapter 4.8.6. below. 
Environmental Assessment 14 

Figure 3. Satellite Image of Coastal Louisiana Shoreline Showing (1) the Location of the Isles Dernieres

Barrier Island Arc, (2) the Whiskey Island/New Cut Tidal Channel Locations for Beach 

Restoration Projects, and (3) the Proposed OCS Sand Borrow Polygons. 

Pelican Island and Pass La Mer to Chaland Pass EA 

The MMS participated as a cooperating agency in the preparation of an EA by NOAA Fisheries for a 

barrier island restoration project in western Plaquemines Parish, Louisiana (USDOC, NMFS, 2003). The 

project (Pelican Island and Pass La Mer to Chaland Pass) proposes to use approximately 2.6 million yd3

of sand for beach nourishment and wetland reconstruction as part of the Barataria Barrier Island Complex

Project under the 1990 Coastal Wetlands Planning, Protection, and Restoration Act (CWPPRA). It is 

expected to benefit a total of 868 ac (351 ha). Sand borrow locations would be located in West Delta

Blocks 25 and 49. The MMS anticipates entering into noncompetitive, negotiated leases with the State of 

Louisiana to use OCS sand resources for this CWPPRA project. The project was scheduled to begin in 

Spring 2004; because of the ongoing mitigation discussions between MMS and NOAA Fisheries, a delay

of 6-12 months is expected. 

4.4. IMPACTS FROM ALTERNATIVE A—THE PROPOSED ACTION

4.4.1. Summary of Analysis Incorporated by Reference from the Multisale EIS 

The multisale EIS analyzed the effects of a typical CPA lease sale by presenting a set of ranges for

resource estimates, projected exploration and development activities, and impact-producing factors for 

any of the proposed CPA lease sales held over the 5-year period. This EA tiers off the multisale EIS and
Environmental Assessment 15 

incorporates that document by reference. All unleased blocks in the CPA will be available for lease under 

the proposed action (as described in Chapter 3.1.). The MMS expects only a small percentage of blocks 

would be leased, and an even smaller percentage would actually produce oil and gas. The following is a 

summary of impacts to resources taken from the multisale EIS. 

4.4.1.1. Impacts on Coastal Resources 

No significant impacts to the physical shape and structure of barrier beaches and associated dunes are 

expected to occur as a result of the proposed action. Should a spill contact a barrier beach, sand removal 

during cleanup activities is expected to be minimal. 

Adverse initial impacts and more importantly secondary impacts of pipeline and navigation canals are 

considered the most significant proposed-action-related impacts to wetlands. Although initial impacts are 

considered locally significant and are largely limited to where OCS-related canals and channels pass 

through wetlands, secondary impacts may have substantial, progressive, and cumulative adverse impacts 

to the hydrologic basin or subbasin in which they are found. Offshore oil spills resulting from the 

proposed action are not expected to significantly damage inland wetlands. The greatest threat to wetland 

habitat is from an inland spill from a vessel accident or pipeline rupture. While a resulting slick may 

cause minor impacts to wetland habitat, equipment and personnel used to clean up a slick over the 

impacted area may generate the greatest direct impacts to the area. 

Normal OCS activities are expected to have little adverse impact on seagrass communities. Impacts 

from pipeline installation activities are expected to be very small and short-term. Inshore spills from 

vessel collisions or pipeline ruptures pose the greatest potential threat to seagrass communities. 

No significant impacts to listed beach mice are expected to occur as a result of the proposed action. 

Adverse impacts to Alabama, Choctawhatchee, St. Andrew, and Perdido Key beach mice are unlikely. 

Impacts may result from consumption of beach trash and debris. No direct impacts from oil spills are 

expected. Protective measures required under the ESA should prevent any oil-spill-response and cleanup 

activities from having significant impact to the beach mice and their habitat. 

Adverse impacts on endangered/threatened and nonendangered/nonthreatened coastal and marine 

birds are expected to be sublethal. These effects include behavior changes, eating OCS-related 

contaminants or discarded debris, and displacement of localized groups from optimal habitats. Chronic 

sublethal stress, however, is often undetectable in birds. As a result of stress, individuals may weaken 

and be prone to infection or disease, have reduced reproductive success, or have disturbed migration 

patterns. Oil spills pose the greatest potential direct and indirect impacts to coastal and marine birds. If 

physical oiling of individuals or local groups of birds occurs, some degree of both acute and chronic 

physiological stress associated with direct and secondary uptake of oil would be expected. Low levels of 

oil could stress birds by interfering with food detection, feeding impulses, predator avoidance, territory 

definition, homing of migratory species, susceptibility to physiological disorders, disease resistance, 

growth rates, reproduction, and respiration. Reproductive success can be affected by the toxins in oil. 

Indirect effects occur by fouling of nesting habitat, and displacement of individuals, breeding pairs, or 

populations to less favorable habitats. Dispersants used in spill cleanup activity can have toxic effects 

similar to oil on the reproductive success of coastal and marine birds. The air, vehicle, and foot traffic 

that takes place during shoreline cleanup activity can disturb nesting populations and degrade or destroy 

habitat. 

Routine activities resulting from the proposed action are expected to have little impact on Gulf 

sturgeon. Impacts on Gulf sturgeon may occur from resuspended sediments and OCS-related discharges. 

Contact with spilled oil could cause irritation of gill epithelium and production of metabolites toxic to the 

liver in Gulf sturgeon. 

Impacts to coastal water quality from the proposed action are expected to be minimal. The primary 

impacting sources to water quality in coastal waters are point-source and nonpoint-source discharges from 

OCS support facilities and support-vessel discharges. 

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

are not projected to have significant impacts on onshore air quality. Emissions from OCS activity are not 

expected to have concentrations that would change onshore air-quality classifications. Increases in 

onshore annual average concentrations of NOx, SOx, and PM10 are estimated to be less than the maximum 

increases allowed in the PSD Class I or II areas. 
Environmental Assessment 16 

The impact from the proposed action on Gulf Coast recreational beaches is expected to be minimal. 

The proposed action may result in an incremental increase in noise from helicopter and vessel traffic, 

nearshore operations that may adversely affect the enjoyment of some Gulf Coast beach uses, and some 

increases in beached debris; these impacts are expected to have little effect on the number of beach users. 

Impacts from oil spills are expected to be short-term and localized; a large volume of oil contacting a 

recreational beach could close the area to recreational use for up to 30 days. 

Routine activities associated with the proposed action are not expected to impact coastal historic 

archaeological resources. It is very unlikely that an oil spill would occur and contact coastal historic 

archaeological sites from accidental events associated with the proposed action. The major effect from an 

oil spill impact would be visual contamination of a historic coastal site, such as a historic fort or 

lighthouse. As historic archaeological sites are protected under law, it is expected that any spill cleanup 

operations would be conducted in such a way as to cause little or no impacts to historic archaeological 

resources. These impacts would be temporary and reversible. 

The proposed action is not expected to result in impacts to coastal prehistoric archaeological sites; 

however, should such an impact occur, unique or significant archaeological information could be lost. It 

is very unlikely that an oil spill would occur and contact coastal, barrier island prehistoric sites as a result 

of the proposed action. Should a spill contact a prehistoric archaeological site, unique or significant 

archaeological information could be irreversibly damaged or lost; damage might include loss of 

radiocarbon-dating potential, direct impact from oil-spill cleanup equipment, and/or looting. Previously 

unrecorded sites could be impacted by oil-spill cleanup operations on beaches. 

Some economic indicators in the GOM Region have changed since the multisale EIS. Both oil and 

natural gas prices have increased substantially, with natural gas prices more than doubling. As of July 21, 

2004, Henry Hub Natural Gas closed at $5.895 per million British thermal unit (Btu) and West Texas 

Intermediate at $40.83 per barrel (Oilnergy, 2004). While activity in the ultra-deep waters of the GOM 

(>5,000 ft) has remained fairly strong, the number of rigs operating in the region and the number of wells 

drilled have continued a downward trend. Since 2002, the average number of rigs operating in water 

depths of 1,000-4,999 ft has declined by 29 percent and the number of wells drilled is down by 37 

percent. Offshore service vessel utilization and day rates have also declined, with supply boats 

experiencing the most dramatic change. Supply boat average day rates in May 2004 ranged from $3,875 

for boats <200 ft and $5,010 for boats ≥ 200 ft, with utilization rates of 70 and 73 percent, respectively 

(Greenberg, 2004). In contrast, the July 2001 rates ranged from $7,718 for boats <200 ft and $10,950 for 

boats ≥ 200 ft, with utilization rates of 89 and 100 percent, respectively. 

Activities resulting from the proposed action are expected to minimally affect the analysis area’s land 

use, infrastructure, or demographic characteristics of the Gulf coastal communities. The proposed action 

is expected to generate less than a 1 percent increase in employment in the Texas, Louisiana, Mississippi, 

and Alabama subareas. Nowhere would these impacts be significant because demand will be met 

primarily with the existing population and available labor force. Accidental events such as oil or 

chemical spills, blowouts, and vessel collisions would have no effects on land use or demographics. 

Coastal or nearshore spills could have short-term adverse effects on coastal infrastructure requiring 

cleanup of any oil or chemicals spilled. The opportunity costs associated with oil-spill cleanup activities 

are expected to be temporary and of short duration. 

Five different classes of relevant OCS activities exist in the region: transportation corridors, oil and 

natural gas pipelines, petroleum bulk storage facilities, shipyards, and a natural gas processing plant. A 

large portion of OCS-related infrastructure is located in south Lafourche Parish where the Houma Indian 

population is clustered (Hemmerling et al., 2003; USDOI MMS; 2003). Proposed CPA Lease Sale 194 

would not significantly alter this pre-existing situation where onshore cumulative effects already exist. 

Therefore, since the preexisting situation would not be significantly altered, minority and low-income 

populations would not sustain disproportionate adverse effects from the proposed action. 

4.4.1.2. Impacts on Offshore Environments 

Adverse impacts to pinnacles or topographic features from routine activities resulting from the 

proposed action are not expected because the Live Bottom (Pinnacle Trend) and Topographic Features 

Stipulations establish requirements for setbacks from these features. Adverse impacts from accidental 

seafloor oil releases or blowouts are expected to be rare because drilling and pipeline operations are not 

permitted in the vicinity of pinnacles or topographic features and because both pinnacles and topographic 
Environmental Assessment 17 

features are small in size and dispersed within the areas that they occur; no community-wide impacts are 

expected. If contact were to occur between diluted oil and adult sessile biota, including coral colonies in 

the case of the Flower Garden Banks, the effects would be primarily sublethal and there would be limited 

incidents of mortality. 

No adverse impacts to the ecological function or biological productivity of the widespread, lowdensity chemosynthetic communities or to the widespread, typical, deep-sea benthic communities are 

expected to occur as a result of routine activities or accidental events resulting from the proposed action. 

The potential for adverse impacts to the rarer, widely scattered, high-density, Bush Hill-type 

chemosynthetic communities are expected to be greatly reduced by the requirement for OCS activities to 

avoid potential chemosynthetic communities by a minimum of 1,500 ft (NTL 2000-G20). High-density 

chemosynthetic communities could experience minor impacts from drilling discharges or resuspended 

sediments located at more than 1,500 ft away. 

Impacts to marine water quality occur from discharges of drilling fluids and cuttings during 

exploration and produced water during production. Impacts to marine water quality are expected to be 

minimal as long as all regulatory requirements are met. Spills <1,000 bbl are not expected to significantly 

impact marine water quality. Larger spills, however, could impact marine water quality. Chemical spills, 

the accidental release of synthetic-based drilling fluids (SBF), and blowouts are expected to have 

temporary localized impacts on marine water quality. The U.S. Environmental Protection Agency 

(USEPA) National Pollution Discharge Elimination System (NPDES) general permit for the CPA expired 

November 3, 2003, and is in the process of being reissued. The draft general permit was published July 7, 

2004; a 3-year permit rather than a 5-year permit has been proposed. A study will be conducted during 

the 3-year permit term to learn more about the potential impacts of increased produced-water discharge to 

the hypoxic zone in the future. The final permit issuance is expected before the end of 2004. 

The NPDES general permit has been administratively continued until reissuance of the new permit so 

that operators with existing permit coverage remained covered. Operators without existing permit 

coverage can eliminate discharges by barging waste to shore, reinjecting the waste, or seeking coverage in 

one of three ways. Operators can apply directly to USEPA for an individual permit. Operators can obtain 

coverage through a Transfer Agreement in which an operator with permit coverage transfers coverage to 

the noncovered operator. Lastly, operators who discharge without a NPDES permit, but meet the terms 

and conditions of the expired permit, can apply for an Administrative Compliance Order. Under this 

case, the operator has committed a minor paperwork violation and would possibly incur penalties of 

$2,000/month. 

Emissions of pollutants into the atmosphere from offshore facilities are not expected to impact 

significantly offshore air quality because of emission heights and rates. Accidents involving high 

concentrations of H2S could result in deaths as well as environmental damage. Other emissions of 

pollutants into the atmosphere from accidental events as a result of the proposed action are not projected 

to have significant impacts. 

The routine activities related to the proposed action are not expected to have long-term adverse 

effects on the size and productivity of any marine mammal species or population stock endemic to the 

northern GOM. Routine OCS activities are expected to have impacts that are sublethal. A small number 

of marine mammals could be harmed or killed by chance collisions with service vessels or by eating 

indigestible trash and debris from proposed-action-related activities. Lethal “takes” as a result of 

explosive removal of OCS platform or production facilities are not expected because of established 

mitigation measures. While no adverse impacts of seismic operations have been documented in the 

GOM, MMS and NOAA Fisheries have established mitigation measures as a precaution to reduce the 

potential for injury to protected species. Populations of marine mammals in the northern Gulf are 

expected to be exposed to residuals of oils spilled as a result of the proposed action during their lifetimes. 

Chronic or acute exposure may result in the harassment, harm, or mortality to marine mammals occurring 

in the northern Gulf. In most foreseeable cases, exposure to hydrocarbons persisting in the sea following 

the dispersal of an oil slick will result in sublethal impacts to marine mammals. 

The routine activities resulting from the proposed action are unlikely to have significant adverse 

effects on the size and recovery of any sea turtle species or population in the GOM. Routine activities are 

expected to have sublethal impacts. Adverse impacts are localized degradation of water quality from 

operational discharges near platforms; noise from helicopters, service vessels, platform, and drillship 

operations; and hatchling disorientation caused by brightly-lit platforms. Sea turtles could be harmed or 
Environmental Assessment 18 

killed from chance collisions with service vessels and from eating floating debris from proposed-actionrelated activities. Lethal “takes” because of explosive removals of OCS facilities are expected to be rare 

because of established mitigation measures (e.g., NOAA Fisheries Observer Program). Accidental 

blowouts, oil spills, and spill-response activities resulting from the proposed action have the potential to 

impact small to large numbers of sea turtles in the GOM. Populations of sea turtles in the northern Gulf 

will be exposed to residuals of oils spilled as a result of the proposed action during their lifetimes. 

Chronic or acute exposure may result in the harassment, harm, or mortality to sea turtles occurring in the 

northern Gulf. In most foreseeable cases, exposure to hydrocarbons persisting in the sea following the 

dispersal of an oil slick will result in sublethal impacts to sea turtles. Death would likely occur to sea 

turtle hatchlings exposed to, becoming fouled by, or consuming tarballs. 

A less than 1-percent decrease in fish resources and/or standing stocks or in essential fish habitat 

(EFH) would be expected as a result of the proposed action. Coastal and marine environmental 

degradation resulting from the proposed action is expected to have little effect on fish resources or EFH. 

Recovery of fish resources and EFH can occur from more than 99 percent, but not all, of the expected 

coastal and marine environmental degradation. Fish populations, if left undisturbed, would regenerate in 

one generation, but any loss of wetlands as EFH would be permanent. Impacts are expected to result in 

less than a 1-percent change in commercial fishing “pounds landed” or in the value of landings. Oil spills 

estimated to result for the proposed action would cause less than a 1-percent decrease in standing stocks 

of any population, commercial fishing efforts, landings, or value of those landings. The resultant impact 

on fish populations and commercial fishing activities within the CPA would be negligible and 

indistinguishable from variations due to natural causes. Any affected commercial fishing activity would 

recover within 6 months. 

Routine activities associated with the proposed action are not expected to impact offshore historic or 

prehistoric archaeological resources. The greatest potential impact to an offshore historic archaeological 

resource would result from direct contact between an offshore activity and a historic shipwreck. Offshore 

oil and gas activities resulting from the proposed action could contact a shipwreck because of incomplete 

knowledge on the location of shipwrecks in the Gulf. Although this occurrence is not probable, such an 

event could result in the disturbance or destruction of important historic archaeological information. 

Should an offshore prehistoric archaeological site be contacted by proposed-action-related activities, 

unique or significant archaeological information could be lost. 

4.4.2. Updated Impact Analysis for the Proposed Action 

The following chapters describe the potential impacts as a result of the proposed action for those 

resources (marine mammals, sea turtles, Gulf sturgeon, and snowy plover) where new information 

became available after MMS prepared the multisale EIS. The analyses for these resources have been 

reevaluated taking into consideration the new information. 

4.4.2.1. Marine Mammals 

The Protected Species Stipulation and the three related NTL’s (Chapters 3.3.1-3.3.2.) were not 

analyzed in the multisale EIS because they were not in place at the time the EIS was completed. The 

purpose of the Protected Species Stipulation is to reduce the potential taking of federally protected 

species, while the three NTL’s serve to provide detailed guidance relative to the requirements of the 

Protected Species Stipulation. These mitigation measures are precautionary and intended to further 

reduce the potential for any impacts related to the proposed action to occur. The environmental impacts 

of the proposed action on marine mammals given the Protected Species Stipulation and NTL’s remain the 

same as presented in the multisale EIS. 

The multisale EIS stated that small numbers of marine mammals could potentially be killed or injured 

by chance collision with service vessels and by eating indigestible debris, particularly plastic items, lost 

from service vessels, drilling rigs, and fixed and floating platforms. Deaths as a result of structure 

removals are not expected because of existing mitigation measures or those being developed for structures 

placed in oceanic waters. There is no conclusive evidence whether anthropogenic noise has or has not 

caused long-term displacements of, or reductions in, marine mammal populations. Contaminants in waste 

discharges and drilling muds might indirectly affect marine mammals through food-chain 

biomagnification, although the scope of effects and their magnitude are not known. The routine activities 
Environmental Assessment 19 

of the proposed action are not expected to have long-term adverse effects on the size and productivity of 

any marine mammal species or population stock endemic to the northern GOM. 

Accidental blowouts, oil spills, and spill-response activities resulting from the proposed action have 

the potential to impact marine mammals in the GOM. Characteristics of impacts (i.e., acute vs. chronic 

impacts) depend on the magnitude, frequency, location, and date of accidents; characteristics of spilled 

oil; spill-response capabilities and timing; and various meteorological and hydrological factors. 

Populations of marine mammals in the northern GOM will be exposed to residuals of oils spilled as a 

result of the proposed action during their lifetimes. Chronic or acute exposure may result in the 

harassment, harm, or mortality to marine mammals occurring in the northern GOM. In most foreseeable 

cases, exposure to hydrocarbons persisting in the sea following the dispersal of an oil slick will result in 

sublethal impacts (e.g., decreased health, reproductive fitness, and longevity; and increased vulnerability 

to disease) to marine mammals. 

4.4.2.2. Sea Turtles 

The Protected Species Stipulation and the three related NTL’s (Chapters 3.3.1-3.3.2.) were not 

analyzed in the multisale EIS because they were not in place at the time the EIS was completed. The 

purpose of the Protected Species Stipulation is to reduce the potential taking of federally protected 

species, while the three NTL’s serve to provide detailed guidance relative to the requirements of the 

Protected Species Stipulation. These mitigation measures are precautionary and intended to further 

reduce the potential for any impacts related to the proposed action to occur. The environmental impacts 

of the proposed action on sea turtles given the Protected Species Stipulation and NTL’s remain the same 

as presented in the multisale EIS. 

The multisale EIS stated that routine activities resulting from the proposed action have the potential to 

harm individual sea turtles. These animals could be impacted by the degradation of water quality 

resulting from operational discharges; noise generated by helicopter and vessel traffic, platforms, and 

drillships; brightly-lit platforms; explosive removals of offshore structures; vessel collisions; and jetsam 

and flotsam generated by service vessels and OCS facilities. Lethal effects are most likely to be from 

chance collisions with OCS service vessels and ingestion of plastic materials. “Takes” as a result of 

explosive removals are expected to be rare because of mitigation measures already established (e.g., 

NOAA Fisheries Observer Program) and in development. Most OCS activities are expected to have 

sublethal effects. Contaminants in waste discharges and drilling muds might indirectly affect sea turtles 

through food-chain biomagnification, although there is uncertainty concerning the possible effects. 

Chronic sublethal effects (e.g., stress) resulting in persistent physiological or behavioral changes and/or 

avoidance of impacted areas could cause declines in survival or fecundity, and population; however, such 

declines are not expected. The routine activities of the proposed action are unlikely to have significant 

adverse effects on the size and recovery of any sea turtle species or population in the GOM. 

4.4.2.3. Gulf Sturgeon Critical Habitat Designation 

 The Protected Species Stipulation and the three related NTL’s (Chapters 3.3.1-3.3.2.) were not 

analyzed in the multisale EIS because they were not in place at the time the EIS was completed. The 

purpose of the Protected Species Stipulation is to reduce the potential taking of federally protected 

species, while the three NTL’s serve to provide detailed guidance relative to the requirements of the 

Protected Species Stipulation. These mitigation measures are precautionary and intended to further 

reduce the potential for any impacts related to the proposed action to occur. The environmental impacts 

of the proposed action on Gulf sturgeon and critical habitat given the Protected Species Stipulation and 

NTL’s remain the same as presented in the multisale EIS. 

The multisale EIS stated that Gulf sturgeon critical habitat in the GOM has been designated in 

Louisiana, Mississippi, Alabama, and Florida. The estuarine and marine critical habitat units extend from 

Lake Borgne in Louisiana to Suwannee Sound in Florida. The coastal area analyzed in the multisale EIS 

comprises the known locations of Gulf sturgeon (Figure 5). This area is slightly larger and encompasses 

the Gulf sturgeon critical habitat. The probability of an oil spill ≥1,000 bbl occurring and contacting 

known locations of the Gulf sturgeon within 10 days as a result of the proposed action is 2-5 percent. 

Contact with spilled oil could cause irritation of gill epithelium and production of metabolites toxic to the 

liver in Gulf sturgeon. Other potential impacts on Gulf sturgeon and critical habitat may occur from 
Environmental Assessment 20 

resuspended sediments (channel dredging and coastal pipeline installation) and OCS-related discharges, 

as well from nonpoint runoff from estuarine OCS-related facilities. Should a spill occur and contact the 

Gulf sturgeon habitat, it is expected to minimally impact the Gulf sturgeon because of the low toxicity of 

this pollution and almost absent overlap between individual Gulf sturgeon and occurrence of

contamination. Routine activities resulting from the proposed action are expected to have little potential 

effect on Gulf sturgeon and critical habitat. 

Figure 4. Probability of Oil Spills (≥1,000 bbl) Occurring and Contacting within 10 Days Known

Locations of Gulf Sturgeon as a Result of the Proposed Action.

4.4.2.4. Snowy Plover 

According to FWS, the snowy plover is present at its identified habitats year round as opposed to only 

February through August. Therefore, the oil-spill probability for the snowy plover was recalculated for 

this EA. The recalculated probability of an oil spill ≥1,000 bbl occurring and contacting snowy plover 

habitat within 10 days as a result of the proposed action is 2-5 percent. While this is an increase from the 

February through August probability (2-4%) as shown on Figure 4-21 of the multisale EIS, the 

environmental impacts of the proposed action remain the same as presented in the multisale EIS. 

The multisale EIS stated that oil spills from the proposed action pose the greatest potential direct and 

indirect impacts to snowy plover. Birds that are heavily oiled usually die. If physical oiling of 

individuals or local groups of birds occurs, some degree of both acute and chronic physiological stress 

associated with direct and secondary uptake of oil would be expected. Small coastal spills, pipeline spills, 

and spills from accidents in navigated waterways can contact and affect the snowy plover. Lightly oiled 

birds can sustain tissue and organ damage from oil ingested during feeding and grooming or from oil that 

is inhaled. Stress and shock enhance the effects of exposure and poisoning. Low levels of oil could stress

snowy plover by interfering with food detection, feeding impulses, predator avoidance, territory

definition, susceptibility to physiological disorders, disease resistance, growth rates, reproduction, and 

respiration. Reproductive success can be affected by the toxins in oil. Indirect effects occur by fouling of 

nesting habitat, and displacement of individuals, breeding pairs, or populations to less favorable habitats. 

Dispersants used in spill cleanup activity can have toxic effects similar to oil on the reproductive success 

of snowy plover. The air, vehicle, and foot traffic that takes place during shoreline cleanup activity can

disturb nesting populations and degrade or destroy habitat. 

4.5. ALTERNATIVE B—THE PROPOSED ACTION EXCLUDING THE BLOCKS NEAR 

BIOLOGICALLY SENSITIVE TOPOGRAPHIC FEATURES

Alternative B would offer for lease all unleased blocks in the CPA, as described for the proposed 

action, with the exception of any unleased blocks within the 167 blocks in the CPA that are subject to the 

Topographic Features Stipulation. All the assumptions including the potential mitigating measures and 

resource estimates remain the same as in the proposed action. The environmental impacts of this

alternative remain the same as presented in the multisale EIS (Chapter 4.2.2.). 
Environmental Assessment 21 

4.6. ALTERNATIVE C—THE PROPOSED ACTION EXCLUDING THE UNLEASED 

BLOCKS WITHIN 15 MILES OF THE BALDWIN COUNTY, ALABAMA, COAST

Alternative C would offer for lease all unleased blocks in the CPA, as described for the proposed 

action, with the exception of any unleased blocks within 15 mi of the coast of Baldwin County, Alabama. 

Although the blocks to be excluded contain oil and/or natural gas resources, this alternative would not 

change the resource estimate and activity ranges for the overall proposed actions. The environmental 

impacts of this alternative remain the same as presented in the multisale EIS (Chapter 4.2.3.). 

4.7. ALTERNATIVE D—NO ACTION

Alternative D is equivalent to cancellation of the proposed lease sale. The opportunity for 

development of the estimated of 0.276-0.654 BBO and 1.590-3.300 Tcf of natural gas that could have 

resulted from the proposed action would be precluded or postponed, and any potential environmental 

impacts resulting from the proposed action would not occur or would be postponed. 

Canceling the proposed lease sale would eliminate the effects described for Alternative A (the 

proposed action). However, other sources of energy would substitute for the lost production. Principal 

substitutes would be additional imports, conservation, additional domestic production, and switching to 

other fuels. These alternatives, except conservation, would have substantial negative environmental 

impacts of their own. These substitutes and the effects are discussed in the multisale EIS and Energy 

Alternatives and the Environment (USDOI, MMS, 2001), and are incorporated by reference. The 

environmental impacts of this alternative remain the same as presented in the multisale EIS (Chapter 

4.2.4.). 

4.8. CUMULATIVE ANALYSIS

The cumulative analysis considers the effects of impact-producing factors related to the proposed 

action, prior and future OCS sales, State oil and gas activities, other governmental and private projects 

and activities, and pertinent natural processes and events that may occur and adversely affect 

environmental and socioeconomic resources. Descriptions of these activities and the analysis of the 

cumulative effects are included in the multisale EIS. 

4.8.1. Marine Mammals 

The cumulative conclusions for marine mammals remain unchanged from the multisale EIS. 

Activities considered under the cumulative scenario could affect protected cetaceans and sirenians. These 

marine mammals could be impacted by the degradation of water quality resulting from operational 

discharges; vessel traffic; noise generated by platforms, drillships, helicopters, and vessels; seismic 

surveys; explosive structure removals; oil spills; oil-spill-response activities; loss of debris from service 

vessels and OCS structures; commercial fishing; capture and removal; and pathogens. The cumulative 

impact on marine mammals is expected to result in a number of chronic and sporadic sublethal effects 

(behavioral effects and nonfatal exposure to or intake of OCS-related contaminants or discarded debris) 

that may stress and/or weaken individuals of a local group or population and predispose them to infection 

from natural or anthropogenic sources. Few deaths are expected from oil spills, chance collisions with 

OCS service vessels, ingestion of plastic material, commercial fishing, and pathogens. Oil spills of any 

size are estimated to be recurring events that would periodically contact marine mammals. Deaths as a 

result of structure removals are not expected to occur because of mitigation measures (e.g., NOAA 

Fisheries Observer Program). Disturbance (noise from vessel traffic and drilling operations, etc.) and/or 

exposure to sublethal levels of toxins and anthropogenic contaminants may stress animals, weaken their 

immune systems, and make them more vulnerable to parasites and diseases that normally would not be 

fatal. The net result of any disturbance would be dependent upon the size and percentage of the 

population likely to be affected, ecological importance of the disturbed area, environmental and biological 

parameters that influence an animal’s sensitivity to disturbance and stress, or the accommodation time in 

response to prolonged disturbance (Geraci and St. Aubin, 1980). Collisions between cetaceans and ships, 

though expected to be rare events, could cause serious injury or mortality. 
Environmental Assessment 22 

The incremental contribution of impacts stemming from the proposed action is expected to be 

primarily sublethal (behavioral effects and nonfatal exposure to or intake of OCS-related contaminants or 

discarded debris). Effects of the incremental contribution of the proposed action combined with non-OCS 

activities may be deleterious, as stated in the multisale EIS, to cetaceans occurring in the GOM. 

Biological significance of any mortality would depend, in part, on the size and reproductive rates of the 

affected stocks, as well as the number, age, and size of animals affected. 

4.8.2. Sea Turtles 

The cumulative conclusions for sea turtles remain unchanged from the multisale EIS. Activities 

considered under the cumulative scenario may harm sea turtles and their habitats. Those activities include 

structure installation, dredging, water quality and habitat degradation, OCS-related trash and flotsam, 

vessel traffic, seismic surveys, explosive structure removals, oil spills, oil-spill-response activities, natural 

catastrophes, pollution, dredge operations, vessel collisions, commercial and recreational fishing, human 

consumption, beach lighting, and power plant entrainment. Sea turtles could be killed or injured by 

chance collision with service vessels or eating marine debris, particularly plastic items, lost from OCS 

structures and service vessels. It is expected that deaths as a result of structure removals would rarely 

occur because of mitigation measures (e.g., NOAA Fisheries Observer Program). The presence of, and 

noise produced by, service vessels and by the construction, operation, and removal of drill rigs may cause 

physiological stress and make animals more susceptible to disease or predation, as well as disrupt normal 

activities. Contaminants in waste discharges and drilling muds might indirectly affect sea turtles through 

food-chain biomagnification, although there is uncertainty concerning the possible effect. Oil spills and 

oil-spill-response activities are potential threats that may be expected to cause turtle deaths. Contact with, 

and consumption of, oil and oil-contaminated prey may seriously impact turtles. Sea turtles have been 

seriously harmed by oil spills in the past. The majority of OCS activities are estimated to be sublethal 

(behavioral effects and nonfatal exposure to intake of OCS-related contaminants or debris). Chronic 

sublethal effects (e.g., stress) resulting in persistent physiological or behavioral changes and/or avoidance 

of impacted areas could cause declines in survival or productivity, resulting in either acute or gradual 

population declines. The incremental contribution of the proposed action to cumulative impacts on sea 

turtles is slight. 

4.8.3. Gulf Sturgeon Critical Habitat Designation 

The Gulf sturgeon cumulative analysis includes analysis of the critical habitat, which was designated 

after the multisale EIS was published. However, since Gulf sturgeon critical habitat is within the area 

analyzed by the multisale EIS, the Gulf sturgeon conclusion, including the impact contribution by the 

proposed action, has not changed (Chapters 4.2.1.9. and 4.4.3.9. of the multisale EIS). The Gulf 

sturgeon can be impacted by activities considered under the cumulative scenario such as oil spills, 

alteration and destruction of habitat, and commercial fishing. The effects from contact with spilled oil 

will be sublethal and last for less than one month. Substantial damage to Gulf sturgeon critical habitat is 

expected from inshore alteration activities and natural catastrophes. The FWS (50 CFR 17) identified the 

following activities that may destroy or adversely modify Gulf sturgeon critical habitat: 

(1) Actions that would appreciably reduce the abundance of riverine prey for larval and 

juvenile sturgeon, or of estuarine and marine prey for juvenile and adult Gulf 

sturgeon, within a designated critical habitat unit. Such actions include dredging, 

dredged material disposal, channelization, in-stream mining, and land uses that cause 

excessive turbidity or sedimentation. 

(2) Actions that would appreciably reduce the suitability of Gulf sturgeon spawning sites 

for egg deposition and development within a designated critical habitat unit. Such 

actions include impoundment, hard-bottom removal for navigation channel 

deepening, dredged material disposal, in-stream mining, and land uses that cause 

excessive sedimentation. 

(3) Actions that would appreciably reduce the suitability of Gulf sturgeon riverine 

aggregation areas, also referred to as resting, holding, and staging areas, used by 
Environmental Assessment 23 

adult, subadult, and/or juveniles, believed necessary for minimizing energy 

expenditures and possibly for osmoregulatory functions. Such actions include 

dredged material disposal upstream or directly within such areas and other land uses 

that cause excessive sedimentation. 

(4) Actions that would alter the flow regime (the magnitude, frequency, duration, 

seasonality, and rate-of-change fresh water discharge over time) of riverine critical 

habitat unit such that appreciably impaired for the purposes Gulf sturgeon migration, 

resting, staging, breeding site selection, courtship, egg fertilization, egg deposition, 

and egg development. Such actions include impoundment, water diversion, and dam 

operations. 

(5) Actions that would alter water quality within a designated critical habitat unit, 

including temperature, salinity, pH, hardness, turbidity, oxygen content, and other 

chemical characteristics, such that it is appreciably impaired for normal Gulf 

sturgeon behavior, reproduction, growth, or viability. Such actions include dredging; 

dredged material disposal; channelization; impoundment; in-stream mining; water 

diversion; dam operations; land uses that cause excessive turbidity; and release of 

chemicals, biological pollutants, or heated effluents into surface water or connected 

groundwater via point sources or dispersed nonpoint sources. 

(6) Actions that would alter sediment quality within a designated critical habitat unit 

such that it is appreciably impaired for normal Gulf sturgeon behavior, reproduction, 

growth, or viability. Such actions include dredged material disposal, channelization, 

impoundment, in-stream mining, land uses that cause excessive sedimentation, and 

release of chemical or biological pollutants that accumulate in sediments. 

(7) Actions that would obstruct migratory pathways within and between adjacent 

riverine, estuarine, and marine critical habitat units. Such actions include dam 

construction, dredging, point-source-pollutant discharges, and other physical or 

chemical alterations of channels and passes that restrict Gulf sturgeon movement. 

If any of the above were to occur and result in damage to Gulf sturgeon critical habitat, it is expected 

that the Gulf sturgeon will experience a decline in population sizes and a displacement from their current 

distribution that will last more than one generation. Deaths of adult sturgeon are expected to occur from 

commercial fishing. The incremental contribution of the proposed action to the cumulative impact is 

negligible because the effect of contact between sale-specific oil spills and Gulf sturgeon is expected to be 

sublethal and last less than one month. 

4.8.4. Snowy Plover 

The cumulative conclusions for the snowy plover remain unchanged from the multisale EIS. It is 

expected that cumulative effects would be detrimental to the snowy plover; however, the majority of 

effects from the major impact-producing factors on the snowy plover are sublethal (behavioral effects and 

nonfatal exposure to or intake of OCS-related contaminants or discarded debris) and would usually cause 

temporary disturbances and displacement of localized groups inshore. The net effect of habitat loss from 

oil spills, new construction, and maintenance and use of pipeline corridors and navigation waterways 

would reduce the overall carrying capacity of disturbed area(s) in general. The incremental contribution 

of the proposed action to the cumulative impact is negligible because the effects of the most probable 

impacts, such as lease sale-related operational discharges and helicopters and service-vessel noise and 

traffic, are estimated to be sublethal with some displacement of local individuals or groups. It is expected 

that there would be little interaction between OCS-related oil spills and the snowy plover. The 

cumulative effect on snowy plover is expected to result in declines in the numbers of birds that form 

localized groups.
Environmental Assessment 24 

4.8.5. Liquefied Natural Gas Projects 

An EIS was prepared (or is currently being prepared) for all but one of the proposed LNG terminals 

located in the GOM; an EA was prepared for the Energy Bridge project. All of the proposals with a GBS 

component have similar impact-producing factors and potential effects on GOM resources. The Energy 

Bridge floating system decreases the possibility of adverse effects to the benthic communities. The 

following information examines the common factors of the proposals and briefly describes a combination 

of adverse and beneficial effects of varying duration that may occur as a result of licensing a proposed 

project. 

Long-term, minor adverse impacts on air quality would be expected; emissions though would not 

exceed annual USEPA-permitted emissions levels and not adversely affect the air quality of onshore 

nonattainment areas. Short- and long-term minor adverse effects from noise would be expected. 

However, any such effects are expected to be minimal and temporary. A combination of long-term and 

short-term, minor adverse impacts on water quality would be expected. Discharge from vessels and 

onshore facilities would be the primary sources of effects on water quality in coastal waters. 

Short- and long-term, minor adverse effects on biological resources would be expected; none of the 

expected impacts though would be significant. Long-term, minor adverse and minor beneficial impacts 

on recreational resources would be expected. These LNG projects, however, are not expected to displace 

recreational fishing in the vicinity of the deepwater ports. No impacts on shore-related recreational 

activities would be anticipated. Effects would also occur with respect to commercial fisheries. 

No effects on archaeological resources would be expected. Geotechnical surveys have been 

conducted on the preferred locations for the proposed terminal areas and pipeline routes. Local shortterm minor and long-term negligible adverse effects to geological resources would be expected. 

Deepwater port applicants have tried to choose terminal locations where the potential for hydrocarbon 

accumulations were considered to be low. 

Short- and long-term, minor adverse effects and short-term, minor beneficial effects would be 

expected on socioeconomic conditions. The proposals would not cause adverse environmental impacts or 

disproportionate human health effects on minority and/or low-income communities. 

Long-term, minor adverse impacts on transportation would be expected because of increased vessel 

and helicopter traffic. No effects would be expected in connection with reliability and safety issues. 

Applicants use hazard identification and management techniques to minimize the potential for 

unanticipated events. 

4.8.6. Sand Dredging Projects 

Multiple sand dredging projects using approximately 15.5 million yd3 of OCS sand have been 

proposed for Ship Shoal (USDOI, MMS, 2004b). Ship Shoal has an estimated 216 mi2

 of crest area with 

sand thickness >1 m. Estimates of the amount of sea bottom disturbed to remove the sand ranges from 

<900 ac (1.4 mi2

) to >6,400 ac (10 mi2) for the three projects. Neither the sand volume nor the estimated 

area disturbed are significant. Modeling indicates that very large volumes of sand could be removed from 

Ship Shoal with no adverse effects on sensitive coastal resources. 

The potential impacts from the proposed New Cut/Whiskey Island beach nourishment and Morganza 

levee projects focus on (1) sea turtles, (2) disturbance to prehistoric and historical archaeological 

resources that may be present in the shallow waters of Ship Shoal, and (3) space-use conflicts on the OCS 

because of 25 mi of existing oil and gas pipelines that cross or border the designated sand borrow 

polygons. All other physical, biological, and socioeconomic resources are expected to experience 

minimal to no impacts from these proposed projects. 

As discussed in the EA, potential impacts would be addressed by the following mitigation measures: 

(1) requiring stipulations to protect sea turtles when it is determined that there is a 

likelihood of sea turtle presence within the area during the dredging operation and a 

trailing suction hopper dredge is used; 

(2) avoiding potential historic archaeological site locations identified in both the Ship 

Shoal and South Pelto areas through a remote-sensing survey conducted previously; 
Environmental Assessment 25 

(3) sampling and monitoring dredge material from borrow sites to identify and protect 

possible prehistoric resources; 

(4) establishing a minimum ‘‘no dredge’’ setback distance of 1,000 ft (305 m) from 

existing pipelines; and 

(5) requiring the use of an electronic positioning system on the dredge vessels and 

transmittal of location and production information to MMS. 

The potential impacts from the proposed Pelican Island and Pass La Mer to Chaland Pass dredging 

and the beach restoration project are expected to be similar to those for the Ship Shoal dredging projects. 

General mitigations were identified in the EA (USDOC, NMFS, 2003; Table 13), but specific quantitative 

setbacks from OCS infrastructure, such as pipelines and platforms, are expected to be part of the 

negotiated lease agreement and a FONSI announcement. The MMS has undertaken studies to examine 

the appropriateness of various setback distances that can be used for dredging operations in proximity to 

OCS infrastructure. The 1,000-ft (305-m) setback to be used for the Ship Shoal projects is a conservative 

limitation made in the absence of a specific examination of the issue. 

5. CONSULTATION AND COORDINATION 

5.1. SCOPING FOR THE ENVIRONMENTAL ASSESSMENT FOR THE CENTRAL 

PLANNING AREA’S PROPOSED LEASE SALE 194 

The MMS performs ongoing external and internal scoping in order to determine the breadth and depth 

necessary for environmental analysis. 

External Scoping: The scoping process for this EA was formally initiated on June 4, 2004, with the 

Federal Register notice announcing the preparation of an EA. In the notice, MMS requested that 

interested parties submit comments regarding any new information or issues that should be addressed in 

the EA. The comment period closed on July 6, 2004. No responses were received. Scoping and 

coordination efforts, though, continue throughout the lease sale process and have been conducted since 

the publication of the multisale EIS: 

• On January 8 and 9, 2003, public hearings were held on the Draft EIS for EPA Lease 

Sales 189 and 197 (USDOI, MMS, 2003b) in New Orleans, Louisiana, and Mobile, 

Alabama. 

• The MMS held the GOM Region’s annual Information Transfer Meeting in 

January 14-16, 2003. Sessions pertained to MMS’s GOM OCS oil and gas program, 

as well as regional environmental, social, and economic concerns, and current OCS 

industry activities and technologies. 

• The MMS co-hosted the International Offshore Pipeline Workshop on 

February 26-28, 2003, which brought together worldwide experience in operating 

and regulating offshore oil and gas activities in order to identify/disseminate pipeline 

issues and knowledge for continued safe and pollution free operations. 

• On June 1-3, 2003, MMS participated in the Oceanology International Americas 

conference in New Orleans, Louisiana. The conference incorporated the following 

disciplines: marine science, technology, operational oceanography, policy, and 

education. 

• On June 4, 2003, MMS published a Notice of Preparation of an EA on proposed CPA 

Lease Sale 190. In the notice, MMS requested interested parties to submit comments 

regarding any new information or issues that should be addressed in the EA. No 

comments were received. 
Environmental Assessment 26 

• In June 2003, MMS requested the Gulf States’ review MMS’s GOM Region Studies 

Development Plan for FY 2004-2006. On July 16, 2003, comments were received 

from the Louisiana Department of Natural Resources. 

• To ensure conformance with State Coastal Zone Management (CZM) program 

policies and local land-use plans, MMS prepares appropriate consistency documents 

for each proposed OCS lease sale. On October 28, 2003, MMS sent the Consistency 

Determination (CD) for CPA Lease Sale 190 to the Governors of Louisiana, 

Mississippi, and Alabama, and to the head of each State’s CZM group. The States 

confirmed MMS’s Consistency Statement for CPA Lease Sale 190. On September 4, 

2003, MMS met with Louisiana’s CZM group; September 9, 2003, with Mississippi; 

and September 10, 2003, with Alabama. 

• In October 2003, MMS published the EA for CPA Lease Sale 190 (USDOI, MMS, 

2003c). No comments were received of the EA. 

• On November 18-20, 2003, MMS participated in the Thirteenth Annual Clean Gulf 

Conference along with consultants, responders, and Federal and State agencies. The 

MMS made the following presentations: “The Oil Spill Response Equipment,” “Oil 

Spill Exercises and Drills,” “Updates of the MMS Worst Case Discharge for 

Blowouts and Pipelines,” and “Ongoing Exploration Along the US/Mexican 

International Boundary.” 

• On November 19, 2003, MMS published a Notice of Preparation of an EA on 

proposed WPA Lease Sale 192. In the notice, MMS requested interested parties to 

submit comments regarding any new information or issues that should be addressed 

in the EA. No comments were received. 

• A workshop on social and economic topics related to the oil and gas industry was 

hosted by the MMS GOM Region on February 3-5, 2004, in New Orleans, Louisiana. 

Discussions were structured around the following topics: Industry Trends and 

Dynamics; Community-Level Impacts of Oil and Gas in the Gulf of Mexico Region; 

and Cultural Impacts of Oil and Gas Activity in the Gulf of Mexico. Information 

derived from the workshop will be used to shape future research projects. The 

proceedings will be published on the MMS Internet website in the near future. 

• In March 2004, MMS published the EA for WPA Lease Sale 192 (USDOI, MMS, 

2004c). No comments were received on the EA. 

• On March 3, 2004, the Louisiana Sand Management Working Group, composed of 

Federal, State, and local authorities, academia, and industry, met to provide advice to 

MMS relative to the long-term use of Federal sand offshore Louisiana. Louisiana's 

coastal landloss problem continues at a rate of more than 25-30 mi2

 per year, severely 

affecting the storm buffering capacity and the protection that nearshore barrier 

islands provide to human populations, oil and gas infrastructure, inland bays, 

estuaries, and wetlands. A major concern expressed by Louisiana is the potential 

conflict created by emplacement of oil and gas infrastructure in areas of rich sand 

deposits. The MMS is currently evaluating the issue. The MMS evaluates each 

proposal for space-use conflicts, recommends mitigations for affected resources and 

to alleviate conflicts with existing OCS infrastructure such as pipelines and 

platforms. Chapter 4.1.3.2.2. of the multisale EIS discusses MMS’s Sand Resources 

Programs. 

• On July 9, 2004, the COE released a Draft Programmatic EIS (PEIS) for the 

Louisiana Coastal Area (LCA) Ecosystem Restoration Plan with a 45-day comment 

period. The LCA Plan is designed to be a coordinated approach to alleviate and 

arrest the chronic and severe loss of wetlands along coastal Louisiana. The draft 

PEIS envisions a range of “restoration opportunities” over the next 10 years that fall 

into two categories: those that divert Mississippi River water and sediment to 
Environmental Assessment 27 

naturally replenish threatened areas and habitats, and those that reconstruct or 

enhance geomorphic barriers that dampen storm waves and tidal surge, such as 

barrier islands and levee systems. The COE’s preferred alternative, or Tentatively 

Selected Plan, is an ambitious synergistic combination of projects undertaking both 

river diversions and geomorphic restorations estimated to cost $1.9 billion over 10 

years. The MMS is commenting on the draft PEIS, focusing primarily on conflicts 

and interfaces with MMS’s OCS Program. 

• On June 4, 2004, MMS published a Notice of Preparation of an EA on proposed EPA 

Lease Sale 197. In the notice, MMS requested interested parties to submit comments 

regarding any new information or issues that should be addressed in the EA. No 

comments were received.

• On July 26, 2004, MMS met with the Florida Department of Environmental 

Protection in Tallahassee, Florida, to discuss the EA for EPA Lease Sale 197 and 

tiering the CD for the EPA Lease Sale 197 CD to the previous EPA Lease Sale 189 

CD. 

Internal Scoping: Internal scoping is an ongoing activity for all environmental projects and NEPA 

documents. Part of internal scoping involves reviewing resource estimates and oil-spill modeling results 

used in the preparation of the multisale EIS to determine if they are still valid. The MMS GOM Region’s 

Office of Resource Evaluation reviewed the oil and gas resource projections and associated activities for 

CPA Lease Sale 194 and confirmed that they remain within the range of those projected by MMS for a 

“typical CPA lease sale.” The MMS Headquarters’ Oil-Spill Risk Analysis (OSRA) group confirmed that 

results from the OSRA model summarized in the multisale EIS and presented in a separate MMS report 

(USDOI, MMS, 2002d) are still valid for the proposed lease sale. 

Internal scoping also requires MMS subject matter experts/analysts and NEPA coordinators to 

continuously update their knowledge base and incorporate three primary informational components into 

their analyses: 

(1) recent studies/reports; 

(2) monitoring results; and 

(3) related cumulative-impact data. 

The MMS’s analysts and coordinators take an active role in the preparation, execution, and peer 

review of studies and reports developed under MMS’s Environmental Studies Program. In addition, 

some analysts provide expertise and are involved in additional studies and analyses conducted by other 

Federal/State agencies and universities concerning GOM issues and interests. The information obtained 

from these studies, as well as other relevant, non-MMS research, was considered by each subject matter 

expert in their assessment for this EA. Appendix C of the multisale EIS lists the GOM Region studies 

published from 1999-2002, while Appendix B of this EA lists those GOM studies published since the 

completion of the multisale EIS. Technical summaries for these studies are available on the MMS 

Internet website (http://www.gomr.mms.gov/homepg/regulate/environ/techsumm/rec_pubs.html). 

In addition to hindcasting projections and estimates, MMS compliance monitoring tracks the status of 

mitigation and other conditions applied to approved-OCS activities. The monitoring information received 

from field inspections, office auditing, and/or mandatory reporting is reviewed by MMS analysts. 

Knowledge gained through environmental compliance monitoring forms a basis for mitigation revision 

and future mitigation development, and was ultimately incorporated by analysts into this EA. 

Cumulative analyses are prepared by MMS subject matter experts that consider activities that could 

occur and may adversely affect GOM resources, including proposed CPA Lease Sale 194, prior and 

future OCS lease sales, State oil and gas activities, and other governmental and private projects and 

activities. The MMS analysts are often responsible for reviewing GOM activities not associated with oil 

and gas operations. All information gained from cumulative analyses was considered by MMS analysts 

in their assessments for this EA. 
Environmental Assessment 28 

5.2. CONSULTATION AND COORDINATION CALENDAR

A complete description of all consultation and coordination activities and meetings is included in 

Chapter 5 of the multisale EIS. A brief summary of these events follows: 

Multisale EIS Process

September 12, 2001 The Call for Information/Notice of Intent (Call/NOI) for the proposed 2003-

2007 CPA and WPA lease sales was published in the Federal Register. The 

required 30-day comment period closed on October 12, 2001. Additional 

public notices were distributed via newspaper notices, mailed notices, and the 

Internet. The MMS received four comment letters in response to the Call. Ten 

written scoping letters were received in response to the NOI. 

October 25-22, 2001 The MMS held scoping meetings in Galveston and Houston, Texas; New 

Orleans, Louisiana; and Mobile, Alabama, to receive comments on the Draft 

EIS for the proposed 2003-2007 CPA and WPA lease sales. A summary of 

comments presented at the scoping meetings is provided in Chapter 5.3. of the 

multisale EIS. 

April 15, 2002 and 

April 17, 2002 

The MMS, by memorandum to FWS (April 15, 2002) and NOAA Fisheries 

(April 17, 2002), requested formal Section 7 consultation for CPA Lease Sales 

185, 190, 194, 198, and 201, and WPA Lease Sales 187, 192, 196, and 200. 

The consultation included all aspects of oil and gas exploration, development, 

production, and abandonment activities. The FWS concluded that the proposed 

actions are not likely to jeopardize the continued existence of listed species 

under FWS jurisdiction (whooping crane, Gulf sturgeon, brown pelican, 

Alabama beach mouse, Perdido Key beach mouse, loggerhead sea turtle, piping 

plover, and Kemp’s ridley sea turtle) and are not likely to destroy or adversely 

modify their designated critical habitat, if any. For each species with 

designated critical habitat, the adverse effects that may occur to critical habitat 

would be temporary in nature and of low probability. The NOAA Fisheries 

concluded that implementation of the proposed actions will adversely affect, 

but not likely jeopardize, the continued existence of the sperm whale; 

leatherback, green, hawksbill, Kemp's ridley, and loggerhead sea turtles; and 

the Gulf sturgeon. 

April 30—May 2, 2002 The MMS held public hearings in Houston, Texas; New Orleans, Louisiana;

and Mobile, Alabama, to receive comments on the multisale EIS for CPA 

Lease Sales 185, 190, 194, 198, and 201, and WPA Lease Sales 187, 192, 196, 

and 200. One person attended the Houston hearing, but no comments were 

presented. Seven people attended the New Orleans hearing. Three individuals 

presented comments, which are summarized in Chapter 5.5. of the multisale 

EIS. There were no attendees at the Mobile hearing. 

November 2002 The MMS completed and filed the Final EIS for CPA Lease Sales 185, 190, 

194, 198, and 201, and WPA Lease Sales 187, 192, 196, and 200 (multisale 

EIS) with USEPA. The MMS revised the document using information 

presented at the hearings and as a result of comments received on the Draft EIS 

(See Chapter 5.7. of the multisale EIS for a complete discussion of comments 

and responses.). 
Environmental Assessment 29 

CPA Lease Sale 194 EA Process 

June 4, 2004 The MMS published a Notice of Preparation of an EA on proposed Lease Sale 

194. In the notice, MMS requested interested parties to submit comments 

regarding any new information or issues that should be addressed in the EA. 

No comments were received. 

6. REFERENCES 

Bedell, C. 2004. Post-storm spill response mobilization in Louisiana. In: Proceedings, Twenty-second 

Information Transfer Meeting, January 2003. U.S. Dept of the Interior, Minerals Management 

Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2003-073. 98 pp. 

Dimarco, S.F., M.K. Howard, W.D. Nowlin, Jr., and R.O. Reid. 2004. Subsurface, high-speed current 

jets in the deepwater region of the Gulf of Mexico. U.S. Dept. of the Interior, Minerals Management 

Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2004-022. 98 pp. 

Geraci, J.R. and D.J. St. Aubin. 1980. Offshore petroleum resource development and marine mammals: 

A review and research recommendations. Marine Fisheries Review 42:1-12. 

Greenberg, J. 2004. OSV day rates. Workboat 61(7): 10, July. 

Hamilton, P., J.J. Singer, E. Waddell, and K. Donahue. 2003. Deepwater observations in the Northern 

Gulf of Mexico from in-situ current meters and PIES: Final report. Volume II: Technical report. 

U.S. Dept of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, 

LA. OCS Study MMS 2003-049. 95 pp. 

Hemmerling, S.A. and C.E. Colten. 2003. Environmental justice considerations in Lafourche Parish, 

Louisiana. U.S. Dept. of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, 

New Orleans, LA. OCS Study MMS 2003-038. 

Lore G.L., D.A. Marin, E.C. Batchelder, W.C. Courtwright, R.P. Desselles, and R.J. Klazynski. 2001. 

2000 assessment of conventionally recoverable hydrocarbon resources of the Gulf of Mexico and 

Atlantic Outer Continental Shelf as of January 1, 1999. U.S. Dept. of the Interior, Minerals 

Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Report MMS 2001-087. 

Oilnergy. 2004. Internet website: http://www.oilnergy.com. July 22, 2004. 

Pritchard, P.C.H. 1997. Evolution, phylogeny, and current status. In: Lutz, P.L. and Musivk, J. A. eds. 

The biology of sea turtles. Boca Raton, FL: CRC Press. Pp. 1-28. 

U.S. Dept. of Commerce. National Marine Fisheries Service. 2003. Barataria Plaquemines Barrier 

Island Complex Project, CWPPRA Project Fed. No./BA-38, Pass La Mer to Chaland Pass and Pelican 

Island Environmental Assessment. U.S. Dept. of Commerce, National Oceanic and Atmospheric 

Administration, National Marine Fisheries Service, prepared by Tetra Tech EM Inc. Baton Rouge, 

Louisiana, December, 2003. 89 pp. + apps. 

U.S. Dept. of Commerce. National Oceanic and Atmospheric Administration Fisheries. 2004. Draft 

2003 stock assessment reports. Internet website: http://www.nmfs.noaa.gov/prot_res/

PR2/Stock_Assessment_Program/sars_draft.html. 

U.S. Dept. of the Interior, Fish and Wildlife Service and Gulf States Marine Fisheries Commission. 1995. 

Gulf sturgeon (Acipenser oxyrinchus desotoi) recovery/management plan. Prepared by the Gulf 

Sturgeon Recovery/Management Task Team for the U.S. Dept. of the Interior, Fish and Wildlife 

Service, Southeast Region, Atlanta, GA; the Gulf States Marine Fisheries Commission, Ocean 

Springs, MS; and the U.S. Dept. of Commerce, National Marine Fisheries Service, Washington, DC. 
Environmental Assessment 30 

U.S. Dept. of the Interior. Minerals Management Service. 2001. Energy alternatives and the 

environment. U.S. Dept. of the Interior, Minerals Management Service, Herndon, VA. OCS Report 

MMS 2001-096. 

U.S. Dept. of the Interior. Minerals Management Service. 2002a. Outer continental shelf oil and gas 

leasing program: 2002-2007—final environmental impact statement; Volumes I and II. U.S. Dept. of 

the Interior, Minerals Management Service, Washington, DC. OCS EIS/EA MMS 2002-006. 

U.S. Dept. of the Interior. Minerals Management Service. 2002b. Gulf of Mexico OCS oil and gas lease 

sales: 2003-2005; Central Planning Area Sales 185, 190, 194, 198, and 201; Western Planning Area 

Sales 187, 192, 196, and 200—final environmental impact statement; Volumes I and II. U.S. Dept. of 

the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS 

EIS/EA MMS 2002-052. 

U.S. Dept. of the Interior. Minerals Management Service. 2002c. News Release: MMS preliminary 

report finds most facilities withstood Hurricane Lili; 6 platforms out of 800 with severe damage; 

MMS buoy provides important data. U.S. Dept. of the Interior, Minerals Management Service, Gulf 

of Mexico OCS Region, New Orleans, LA. October 16, 2002. 

U.S. Dept. of the Interior. Minerals Management Service. 2002d. Oil-spill risk analysis: Gulf of 

Mexico Outer Continental Shelf (OCS) lease sales, Central Planning Area and Western Planning 

Area, 2003-2007 and Gulfwide OCS Program, 2003-2042. U.S. Dept. of the Interior, Minerals 

Management Service, Washington, DC. OCS Report MMS 2002-032. 

U.S. Dept. of the Interior. Minerals Management Service. 2003a. Outer Continental Shelf oil spill 

during Hurricane Lili, Ship Shoal Block 119: Responses, fate, and effects. U.S. Dept. of the Interior, 

Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Report MMS 

2003-039. 

U.S. Dept. of the Interior. Minerals Management Service. 2003b. Gulf of Mexico OCS oil and gas lease 

sales: 2003 and 2005; Eastern Planning Area Sales 189 and 197—final environmental impact 

statement. U.S. Dept. of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, 

New Orleans, LA. OCS EIS/EA MMS 2003-020. 

U.S. Dept. of the Interior. Minerals Management Service. 2003c. Proposed OCS Lease Sale 190, 

Central Gulf of Mexico—environmental assessment. U.S. Dept. of the Interior, Minerals 

Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS EIS/EA MMS 

2003-066. 

U.S. Dept. of the Interior. Minerals Management Service. 2004a. Geological and geophysical 

exploration for mineral resources on the Gulf of Mexico outer continental shelf; final programmatic 

environmental assessment. Prepared by Continental Shelf Associates, Inc. for the U.S. Dept. of the 

Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS 

EIS/EA MMS 2004-054. 

U.S. Dept. of the Interior. Minerals Management Service. 2004b. Issuance of noncompetitive leases for 

the use of Outer Continental Shelf sand resources from Ship Shoal, offshore central Louisiana for 

coastal and barrier island nourishment and hurricane levee construction—environmental assessment. 

U.S. Dept. of the Interior, Minerals Management Service, Herndon, VA. OCS EIS/EA MMS 

2004-059. 

U.S. Dept. of the Interior. Minerals Management Service. 2004c. Proposed OCS Lease Sale 192, 

Western Gulf of Mexico—environmental assessment. U.S. Dept. of the Interior, Minerals 

Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS EIS/EA MMS 

2004-007. 

Würsig, B., T. Jefferson, and D. Schmidly. 2000. The marine mammals of the Gulf of Mexico. College 

Station, TX: Texas A&M University Press. 
Environmental Assessment 31 

APPENDIX A. NOTICES TO LESSEES AND OPERATORS 

(NOVEMBER 2002 — PRESENT) 

NTL Number Effective Date Title 

2002-G12 November 4, 2002 Revised North American Datum 83 Implementation Plan for 

the Gulf of Mexico 

2002-N13 November 1, 2002 Drilling and Well Permit and Reporting Forms 

2002-G15 December 20, 2002 Coastal Zone Management Program Requirements for OCS 

ROW Pipeline Applications 

2003-G03 January 23, 2003 Remotely Operated Vehicle Surveys in Deepwater 

2003-G05 February 15, 2003 Procedures for Submission, Inspection and Selection of 

Geophysical Data and Information Collected Under a Permit 

and Processed or Reprocessed by a Permittee or a Third 

Party 

2003-G02 March 3, 2003 Ultimate Recovery Abandonment and Bypassing of Zones 

2003-N03 March 7, 2003 Performance Measures for OCS Operators and Form MMS131 

2003-N04 May 9, 2003 Extension of Lease Terms by Production in Paying Quantities 

2003-N06 June 17, 2003 Supplemental Bond Procedures 

2003-G10 June 19, 2003 Vessel Strike Avoidance and Injured/Dead Protected Species 

Reporting 

2003-G11 June 19, 2003 Marine Trash and Debris Awareness and Elimination 

2003-G15 August 13, 2003 Contact with District Offices and the Pipeline Section Outside 

Regular Work Hours 

2003-G16 August 15, 2003 Assessment of Existing OCS Platforms 

2003-G17 August 27, 2003 Guidance for Submitting Exploration Plans and Development 

Operations Coordination Documents 
Environmental Assessment 32 

NTL Number Effective Date Title 

2003-G19 September 1, 2003 Drilling Windows, Eastern Gulf of Mexico 

2003-G20 January 1, 2004 Gas Volume Statement Requirements 

2004-N01 January 12, 2004 Revised Assessment Matrix

2004-G02 January 27, 2004 Military Warning and Water Test Areas 

2004-G03 February 6, 2004 Notification and Confirmation of Deep Gas Royalty Relief 

2004-G01 March 1, 2004 Implementation of Seismic Survey Mitigation Measures and 

Protected Species Observer Program 

2004-G04 March 7, 2004 Standard Reporting Period for the Well Activity Report 

2004-G05 April 1, 2004 Biologically Sensitive Areas of the Gulf of Mexico 

2004-G06 April 5, 2004 Structure Removal Operations 

2004-G07 April 20, 2004 Well Records Submittal 

2004-G08 April 21, 2004 Flaring and Venting Approval Guidelines 

2004-G11 May 3, 2004 Clarification of Deep Gas Royalty Relief Regulation 

Regarding Natural Gas Liquids and Pipeline (Retrograde) 

Condensate 

2004-G09 May 17, 2004 Policies for Shutting-In Producible Wells During Rig Moves 

2004-G10 June 1, 2004 Implementation of the eWell Permitting and Reporting System 

2004-G07 

Addendum 1 

June 1, 2004 Change of MMS Contractor Receiving Digital Well Log

Drilling Records and Additional Well Log Curves to Submit 

2004-N03 July 26, 2004 Directional and Inclination Survey Data Submission 

Requirements

2004-G12 June 21, 2004 Clarification of Deep Gas Royalty Suspension Provision in 

Lease Instrument Relating to Sidetrack Completions 
Environmental Assessment 33 

NTL Number Effective Date Title 

2004-G13 June 22, 2004 Replacing Deep Gas Royalty Relief Provisions in Lease 

Instrument With Regulatory Deep Gas Royalty Relief

Provisions 

2004-G14 June 23, 2004 Hurricane and Tropical Storm Evacuation and Production

Curtailment Statistics 

2004-N04 June 25, 2004 Data and Information to be Made Available to the Public 

2004-G15 August 10, 2004 Application of the Deep Gas Royalty Relief Rule to Leases 

Issued from 2001 through 2003 
Environmental Assessment 34 

APPENDIX B. PUBLICATIONS OF THE ENVIRONMENTAL STUDIES 

PROGRAM, GULF OF MEXICO OCS REGION

(NOVEMBER 2002 — PRESENT) 

Study 

Number Title 

2002-055 Northeastern Gulf of Mexico Chemical Oceanography and Hydrography Study,

Synthesis Report 

2002-063 Deepwater Program: Northern Gulf of Mexico Continental Slope Habitats and Benthic 

Ecology; Year 2: Interim Report 

2002-064 Lagrangian Study of Circulation, Transport, and Vertical Exchange in the Gulf of

Mexico 

2002-072 Effect of the Oil and Gas Industry on Commuting and Migration Patterns in Louisiana:

1960-1990 

2002-073 Emissions Inventories of OCS Production and Development Activities in the Gulf of

Mexico, Final Report 

2002-077 Offshore Petroleum Platforms: Functional Significance for Larval Fish Across 

Longitudinal and Latitudinal Gradients 

2002-078 Deepwater Program: Bluewater Fishing and OCS Activity, Interactions Between the 

Fishing and Petroleum Industries in Deepwaters of the Gulf of Mexico, Final Report 

2003-004 Dynamics of the Oil and Gas Industry in the Gulf of Mexico: 1980-2000, Final Report 

2003-005 Proceedings: Twenty-first Annual Gulf of Mexico Information Transfer Meeting, 

January 2002

2003-009 Rigs and Reefs: A Comparison of the Fish Communities at Two Artificial Reefs, a 

Production Platform, and a Natural Reef in the Northern Gulf of Mexico; Final Report 

2003-018 Modeling the Economic Impacts of Offshore Oil and Gas Activities in the Gulf of

Mexico: Methods and Applications 

2003-022 Labor Demand in the Offshore Oil and Gas Industry in the 1990’s: The Louisiana Case 

2003-029 Importance of Zooplankton in the Diets of Blue Runner (Caranx crysos) Near Offshore 

Petroleum Platforms in the Northern Gulf of Mexico 
Environmental Assessment 35 

Study 

Number Title 

2003-030 Workshop on Deepwater Environmental Studies Strategy: A Five-Year Follow-Up and

Planning for the Future; May 29-31, 2002 

2003-031 Long-Term Monitoring at the East and West Flower Garden Banks National Marine 

Sanctuary, 1998-2001; Final Report 

2003-038 Environmental Justice Considerations in Lafourche Parish, Louisiana 

2003-040 Marine and Coastal Fishes Subject to Impingement by Cooling-Water Intake Systems in 

the Northern Gulf of Mexico: An Annotated Bibliography 

2003-041 Changing Patterns of Ownership and Control in the Petroleum Industry: Implications 

on the Market for Oil and Gas Leases in the Gulf of Mexico OCS Region, 1983-1999 

2003-048 

2003-049 

Deepwater Observations in the Northern Gulf of Mexico from In-situ Current Meters

and PIES

Volume I: Executive Summary 

Volume II: Technical Report 

2003-060 

2003-061 

2003-062 

Refining and Revising the Gulf of Mexico Outer Continental Shelf Region HighProbability Model for Historic Shipwrecks, Final Report 

Volume I: Executive Summary 

Volume II: Technical Narrative 

Volume III: Appendices 

2003-063 Historical Reconstruction of the Contaminant Loading and Biological Responses in the

Central Gulf of Mexico Shelf Sediments 

2003-065 Preparation of an Interactive Key for Northern Gulf of Mexico Polychaete Taxonomy

Employing the DELTA/INTKEY System, FInal Report 

2003-069 Sperm Whale Seismic Study in the Gulf of Mexico, Annual Report: Year 1 

2003-072 Selected Aspects of the Ecology of the Continental Slope Fauna of the Gulf of Mexico:

A Synopsis of the Northern Gulf of Mexico Continental Slope Study, 1983-1988

2003-073 Proceedings: Twenty-Second Annual Gulf of Mexico Information Transfer Meeting,

January 2003

2003-074 Modeling and Data Analyses of Circulation Processes in the Gulf of Mexico, Final 

Report 
Environmental Assessment 36 

Study 

Number Title 

2004-009 Long-Term Oil and Gas Structure Installation and Removal Forecasting in the Gulf of 

Mexico: A Decision- and Resource-Based Approach 

2004-013 Intermediate Depth Circulation in the Gulf of Mexico: PALACE Float Results for the 

Gulf of Mexico Between April 1998 and March 2002 

2004-015 Minerals Management Service Environmental Studies Program: A History of 

Biological Investigations in the Gulf of Mexico, 1973-2000 

2004-016 Fiscal System Analysis: Concessionary and Contractual Systems Used in Offshore 

Petroleum Arrangements 

2004-017 Cross-Shelf Exchange Processes and the Deepwater Circulation of the Gulf of Mexico: 

Dynamical Effects of Submarine Canyons and Interactions of Loop Current Eddies with 

Topography, Final Report 

2004-022 Subsurface, High-Speed Current Jets in the Deepwater Region of the Gulf of Mexico, 

Final Report 

2004-027 Deepwater Program: OCS-Related Infrastructure in the Gulf of Mexico Fact Book 

2004-040 Strong Mid-Depth Currents and a Deep Cyclonic Gyre in the Gulf of Mexico 

2004-041 Economic Impact in the U.S. of Deepwater Projects: A Survey of Five Projects 

2004-047 Supply Network for Deepwater Oil and Gas Development in the Gulf of Mexico: An 

Empirical Analysis of Demand for Port Services, Final Report 

2004-049 

2004-050 

2004-051 

History of the Offshore Oil and Gas Industry in Southern Louisiana: Interim Report 

Volume I: Papers on the Evolving Offshore Industry 

Volume II: Bayou Lafourche — An Oral History of the Development of the Oil and 

Gas Industry 

Volume III: Samples of Interviews and Ethnographic Preferences 

2004-057 Labor Migration and the Deepwater Oil Industry 
The Department of the Interior Mission

As the Nation's principal conservation agency, the Department of the Interior has responsibility 

for most of our nationally owned public lands and natural resources. This includes fostering 

sound use of our land and water resources; protecting our fish, wildlife, and biological diversity; 

preserving the environmental and cultural values of our national parks and historical places; 

and providing for the enjoyment of life through outdoor recreation. The Department assesses 

our energy and mineral resources and works to ensure that their development is in the best 

interests of all our people by encouraging stewardship and citizen participation in their care. 

The Department also has a major responsibility for American Indian reservation communities 

and for people who live in island territories under U.S. administration. 

The Minerals Management Service Mission 

As a bureau of the Department of the Interior, the Minerals Management Service's (MMS) 

primary responsibilities are to manage the mineral resources located on the Nation's Outer 

Continental Shelf (OCS), collect revenue from the Federal OCS and onshore Federal and Indian 

lands, and distribute those revenues. 

Moreover, in working to meet its responsibilities, the Offshore Minerals Management Program 

administers the OCS competitive leasing program and oversees the safe and environmentally 

sound exploration and production of our Nation's offshore natural gas, oil and other mineral 

resources. The MMS Minerals Revenue Management meets its responsibilities by ensuring the 

efficient, timely and accurate collection and disbursement of revenue from mineral leasing and 

production due to Indian tribes and allottees, States and the U.S. Treasury. 

The MMS strives to fulfill its responsibilities through the general guiding principles of: (1) being 

responsive to the public's concerns and interests by maintaining a dialogue with all potentially 

affected parties and (2) carrying out its programs with an emphasis on working to enhance the 

quality of life for all Americans by lending MMS assistance and expertise to economic 

development and environmental protection.