UNITED STATES GOVERNMENT MEMORANDUM

To: Public Information (MS 5030)

Plans Section, Office of Field Operations (MS 5231)

Public Information copy of Exploration Plan

Control # - N-09745

Type - Initial Exploration Plan

Lease(s) - OCS-G34032 Block - A 588 High Island Area OCS- Block - A 581 High Island Area

Operator - Walter Oil & Gas Corporation

Wells A and B

+BDLVQBOE4FNJTVCNFSTJCMF

Attached is a copy of the subject plan for public comments on issues that
should be addressed in an Environmental Assessment.

It has been deemed submitted as of this date and is under review for approval.

Chiquita Hill

Plan Coordinator Description -

Rig Type - Subject: From: November 14, 2013Public Information August, 2013

INITIAL EXPLORATION PLAN

Lease Number(s): OCS-G 34032

Area/Block: High Island Block A-588

Prospect Name: NA

Offshore: Texas

Submitted by: Walter Oil & Gas Corporation
1100 Louisiana
Suite 200 Houston, Texas 77002

Paul Rodriguez (713) 659-1221 prodriguez@walteroil.com

Estimated start-up date: December 1, 2013

Authorized Representative: No. Copies Being Submitted: Judy Davidson Proprietary: 1 Copy & CD J. Connor Consulting, Inc. Public Info: 1 Copy & CD 16225 Park Ten Place, Suite 700 Houston, Texas 77084 For BOEM: (281) 578-3388 Plan No. judy.davidson@jccteam.c om Assigned to:Record of Changes
OCS-G 34032 High Island Block a-588
Control Number N-9745

Date Section Page Remarks

09-05-2013 Section 14 Attachment 14- A Signed Texas CZM CertificationSECTION ATTACHMENTS

Section 1 Plan Contents

1-A OCS Plan Information Form

1-B Well Location Plat
1-C Bathymetry Map

1-D Pay.gov Receipt
Section 2 General Information

2-B Blowout Assumptions and Worst Case Discharge Calculations Section 3 Geological, Geoph ysical Information
3-D Shallow Hazard Assessment Section 6 Wastes and Discharges Information
6-A Wastes You Will Gener ate, Treat and Downhole Dispose or Discharge to the GOM Section 8 Oil Spill Information
8-A Oil Spil l Response Discussion Section 12 Support Vessels an d Aircraft Information
12-A Waste You Will Tr ansport and/or Dispose Onshore 12-B Vicinity Map Section 14 Coastal Zone Management Act Information 14-A Coastal Zone Consistency Certification Section 15 Environmental Impact Analysis (EIA)
15-A Environmental Impact Analysis (EIA)TABLE OF CONTENTS

SECTION 1 PLAN CONTENTS ..................................................................................... 4

1.1 PLAN INFORMATION ............................................................................................ 4

1.2 LOCATION ............................................................................................................. 4

1.3 SAFETY AND POLLUTION PREVENTION FEATURES ....................................... 4

1.4 STORAGE TANKS AND PRODUCTION VESSELS .............................................. 5

1.5 POLLUTION PREVENTION MEASURES ............................................................. 5

1.6 ADDITIONAL MEASURES .................................................................................... 5

1.7 COST RECOVERY FEE ........................................................................................ 5

SECTION 2 GENERAL INFORMATION ........................................................................ 6

2.1 APPLICATIONS AND PERMITS ........................................................................... 6

2.2 DRILLING FLUIDS ................................................................................................. 6

2.3 NEW OR UNUSUAL TECHNOLOGY .................................................................... 6

2.4 BONDING STATEMENT ........................................................................................ 6

2.5 OIL SPILL FINANCIAL RESPONSIBILITY (OSFR) ............................................... 6

2.6 DEEPWATER WELL CONTROL STATEMENT .................................................... 6

2.7 BLOWOUT SCENARIO AND WORST CASE DISCHARGE CALCULATIONS ..... 7

SECTION 3 GEOLOGICAL AND GEOPHYSICAL INFORMATION ............................. 8

3.1 GEOLOGICAL DESCRIPTION .............................................................................. 8

3.2 STRUCTURE CONTOUR MAP ............................................................................. 8

3.3 INTERPRETED 2-D and / Or 3-D SEISMIC LINE(S) ............................................. 8

3.4 GEOLOGICAL STRUCTURE CROSS-SECTIONS ............................................... 8

3.5 SHALLOW HAZARDS REPORT ........................................................................... 8

3.7 HIGH-RESOLUTION SEISMIC LINES ................................................................... 8

3.8 STRATIGRAPHIC COLUMN ................................................................................. 8

3.9 TIME VERSUS DEPTH TABLES ........................................................................... 8

SECTION 4 HYDROGEN SULFIDE INFORMATION .................................................... 9

4.1 CONCENTRATION ................................................................................................ 9

TOC Pg 1 of 254.2 CLASSIFICATION ................................................................................................. 9

SECTION 5 BIOLOGICAL, PHYSICAL AND SOCIOECONOMIC INFORMATION .... 10

5.1 DEEPWATER BENTHIC COMMUNITIES ........................................................... 10

5.2 TOPOGRAPHIC FEATURES (BANKS) ............................................................... 10

5.3 TOPOGRAPHIC FEATURES STATEMENT (SHUNTING) .................................. 10

5.4 LIVE BOTTOMS (PINNACLE TREND FEATURES) ............................................ 10

5.5 LIVE BOTTOMS (LOW RELIEF) ......................................................................... 10

5.6 POTENTIALLY SENSITIVE BIOLOGICAL FEATURES MAP .............................. 10

5.7 REMOTELY OPERATED VEHICLE (ROV) SURVEYS ....................................... 10

5.8 THREATENED AND EN DANGERED SPECIES, CRI TICAL HABITAT, AND

MARINE MAMMAL INFORMATION .......................................................................... 10

5.9 ARCHAEOLOGICAL REPORT ............................................................................ 12

5.10 AIR AND WATER QUALITY INFORMATION .................................................... 12

5.11 SOCIOECONOMIC INFORMATION .................................................................. 12

SECTION 6 WASTES AND DISCHARGES INFORMATION ...................................... 13

6.1 PROJECTED GENERATED WASTES ................................................................ 13

6.2 MODELING REPORT .......................................................................................... 13

SECTION 7 AIR EMISSIONS INFORMATION ............................................................ 14

7.1 EMISSIONS WORKSHEETS AND SCREENING QUESTIONS .......................... 14

7.2 SUMMARY INFORMATION ................................................................................. 14

SECTION 8 OIL SPILLS INFORMATION .................................................................... 15

8.1 OIL SPILL RESPONSE PLANNING .................................................................... 15

8.2 SPILL RESPONSE SITES ................................................................................... 15

8.3 OSRO INFORMATION ........................................................................................ 15

8.4 WORST CASE SCENARIO DETERMINATION ................................................... 15

8.5 OIL SPILL RESPONSE DISCUSSION ................................................................ 16

SECTION 9 ENVIRONMENTA L MONITORING INFORMATION ................................ 17

9.1 MONITORING SYSTEMS .................................................................................... 17

9.3 FLOWER GARDEN BANKS NATIONAL MARINE SANCTUARY ....................... 17

SECTION 10 LEASE STIPULATIONS INFORMATION .............................................. 18

10.1 MARINE PROTECTED SPECIES ..................................................................... 18

TOC Pg 2 of 25TOC Pg 3 of 25 SECTION 11 ENVIRONMENTAL MITI GATION MEASURES INFORMATION ........... 19

11.1 MEASURES TAKEN TO AVOID, MI NIMIZE, AND MITIGATE IMPACTS .......... 19

11.2 INCIDENTAL TAKES ......................................................................................... 19

SECTION 12 SUPPORT VESSEL S AND AIRCRAFT INFORMATION ...................... 20

12.1 GENERAL .......................................................................................................... 20

12.2 DIESEL OIL SUPPLY VESSELS ....................................................................... 20

12.3 DRILLING FLUID TRANSPORTATION ............................................................. 20

12.4 SOLID AND LIQUID WASTE TRANSPORTATION ........................................... 20

12.5 VICINITY MAP ................................................................................................... 20

SECTION 13 ONSHORE SUPPORT FACILITIES INFORMATION ............................ 21

13.1 GENERAL .......................................................................................................... 21

13.2 SUPPORT BASE CONSTRUCTION OR EXPANSION ..................................... 21

13.3 SUPPORT BASE CONSTRUCTION OR EXPANSION TIMETABLE ................ 21

13.4 WASTE DISPOSAL ........................................................................................... 21

SECTION 14 COASTAL ZONE MANAG EMENT ACT (CZMA) INFORMATION ........ 22

SECTION 15 ENVIRONMENTAL IMPACT ANALYSIS .............................................. 24

SECTION 16 ADMINISTRATIVE INFORMATION ....................................................... 25

16.1 EXEMPTED INFORMATION DESCRIPTION .................................................... 25

16.2 BIBLIOGRAPHY ................................................................................................ 25Walter Oil & Gas Corporation Section 1 – Pg. 4 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 

### SECTION 1

PLAN CONTENTS

1.1 PLAN INFORMATION Walter Oil & Gas Corporation (Walter) pr oposes to drill and complete two wells, Locations A and B, in High Isla nd Block A-588. Well location A will be drilled with a moored semi-submersible rig, and Well Locati on B will be drilled with a jackup. A rightof-use and easement is being submitted under separate cover for Well Location B's surface location in High Island Block A-581.

The OCS Plan Information Form – Form BOEM-137 is included as Attachment 1-A

.

1.2 LOCATION A Well Location Plat depicting the proposed surface and bottomhole locations of the proposed wells is included as Attachment 1-B . A Bathymetry Map is included as

Attachment 1-C which includes water depths and anchor radius.

1.3 SAFETY AND POLLUTION PREVENTION FEATURES Safety of personnel and protection of the environment during the pr oposed operations is one of the primary co ncerns of Walter.

The Bureau of Ocean Energy Management (BOEM) mandates t hat the operations described in this Initial EP comply with well control, pollution prevention, construction, welding procedures, and training described in BSEE regulati ons 30 CFR 250 C, D, E, O and S; and as further clarified by BSEE Notices to Lessees.

The Bureau of Safety and Environmental Enforcement (BSEE) conducts periodic announced and unannounced onsite inspections of offshore facilities to confirm operators are complying with lease stipul ations, operating r egulatory regulations, approved plans, and other conditions; as well as to assure safety and pollution prevention requirements are being met. The National Potential Incident of Noncompliance (PINC) List serves as the baseline for these inspections.

U.S. Coast Guard regulati ons contained in Title 33 CFR Part 144 mandate the appropriate life rafts, life jackets, ring buoys, et c. be maintained on the facilities at all

times.

U.S. Environmental Protecti on Agency regulations contai ned in the NPDES General Permit GMG290000 mandate that supervisory and certain designated personnel on-Walter Oil & Gas Corporation Section 1 – Pg. 5 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 board the facility be familiar with the effluent limitations and guidelines for overboard discharges into the receiving waters.

A description of the dr illing unit is included on the OCS Plan Information Form which complies with all relevant regulations. Rig specifications will be made part of each Application for Permit to Drill. Walter wil l drill Well Location A with a semi-submersible which is equipped with a Surf ace BOP. Once a rig is c ontracted, BOP information and schematics will be included as a part of t he Application for Permit to Drill.

Safety features on the drilli ng unit will include we ll control, pollution prevention, and blowout prevention equipment as described in BSEE regulations 30 CF R 250 C, D, E, O
and S; and as further clarifi ed by BSEE Notices to Lessees, and current policy making invoked by the BSEE, Environmental Protec tion Agency and the U.S. Coast Guard. Appropriate life rafts, life jackets, ring buoys, et c., will be maintained on the facility at all

times.

Pollution prevention measures include installation of cu rbs, gutters, drip pans, and drains on drilling deck areas to co llect all contaminants and debris.

1.4 STORAGE TANKS AND PRODUCTION VESSELS All facility tanks with capacity of 25 barrels or more.

Type of Storage Tank Type of Facility Tank Capacity

(bbls) Number
of
Tanks Total Capacity

(bbls) Fluid Gravity

(API) Fuel Oil (Marine Diesel) SemiSubmersible Rig 18,000 5 70,000 32.5 0

Fuel Oil (Marine Diesel) Jackup 5,000 3 15,000 32.5 0

1.5 POLLUTION PREVENTION MEASURES These operations do not propose activities for wh ich the State of Florida is an affected

state.

1.6 ADDITIONAL MEASURES Walter does not propose any addi tional safety, pollution prevention, or early spill detection measures beyond those required by 30 CFR 250.

1.7 COST RECOVERY FEE A pay.gov receipt in the amount of $7,346.00 is included as Attachment 1-D.U.S. Department of the Interior Bureau of Ocean Energy Management OMB Control Number: 1010-0151 OMB Approval Expires: 12/31/14

OCS PLAN INFORMATION FORM

General Information

Type of OCS Plan: x Exploration Plan (EP) Develo pment Operations Coordination Document (DOCD)

Company Name: Walter Oil & Gas Corporation BOEM Operator Number: 00730

Address: 1100 Louisiana, Suite 200 Contact Person: Paul Rodriguez/Judy Archer

Houston, Texas 77002-5299 Phone Number: 713-659-1221

E-Mail Address: prodriguez@walte roil.com / jarcher@walteroil.com

If a service fee is required under 30 CFR 550.125(a), provide the Amount paid 7,346.00 Receipt No. 25AVOFMR NA
Project and Worst Case Discharge (WCD) Information

Lease(s): G-34032 Area: HI Block(s) A-588 Project Name (If Applicable): NA

Objective(s) x Oil x Gas Sulphur Salt Onshore Support Base(s): Freeport, Texas

Platform / Well Name: B Total Volume of WCD: 66,105 bbls. API Gravity: 32 0

Distance to Closest Land (Miles): 91 Volume from uncontrolled blowout: 4,495,140

Have you previously provided informa tion to verify the calculations and assumptions for your WCD? Yes x No

If so, provide the Control Number of the EP or DOCD with which this information was provided

Do you propose to use new or unusual technol ogy to conduct your activities? Yes x No

Do you propose to use a vessel with anchors to install or modify a structure? Yes x No

Do you propose any facility that will serve as a host f acility for deepwater subsea development? Yes x No
Description of Proposed Activities and Tentative Schedule (Mark all that apply)

Proposed Activity Start Date End Date No. of Days

Exploration drilling Well Loca tion A 12-01-2013 01-16-2014 46

Well completion Well Location A 01-17-2014 02-08-2014 22

Exploration drilling Well Loca tion B 02-09-2014 03-27-2014 46

Well Completion Well Location B 03-28-2014 04-18-2014 22

Installation or modification of structure

Installation of production facilities

Installation of subsea wellheads and/or manifolds

Installation of lease term pipelines

Commence production

Other (Specify and att ach description) Description of Drilling Rig Description of Structure

Jackup Drillship Caisson Tension leg platform

x Gorilla Jackup Platform rig Fixed platform Compliant tower

x Semisubmersible Submersible Spar Guyed tower

DP Semisubmersible Other (Attach description) Floating production
system Other (Attach description) Drilling Rig Name (If known):
Description of Lease Term Pipelines

From (Facility/Area/Block) To (Facility/Area /Block) Diameter (Inches) Length (Feet)

Form BOEM- 0137 (December 2011 – Supersedes all previ ous editions of this form which may not be used.) Page 1 of 4OCS PLAN INFORMATION FORM (CONTINUED) Include one copy of this page for each proposed well/structure

Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): A Previously reviewed under an a pproved EP or DOCD? Yes x No

Is this an existing well or

structure? Yes x No If this is an existing well or structure, list the Complex ID

or API No.

Do you plan to use a subsea BOP or a surface BOP on a floating facility to conduct your proposed activities? x Yes No

WCD Info For wells, volume of uncontrolled blowout (Bbls/Day): 66,105 For structures, volume of all storage and pipelines (Bbls): API Gravity of fluid 32 0

Surface Location Bottom-Hole Location (For Wells) Completion (For multiple completions, enter separate lines)

Lease No. G-34032 OCS

OCS

Area Name HI

Block No. A-588

Blockline Departures (in feet) N/S Departure 4295' FNL N/S Departure F __ L N/S Departure F __ L N/S Departure F __ L

E/W Departure 5827.19 FWL E/W Departure F __ L E/W Departure F __ L E/W Departure F __ L

Lambert X-Y
coordinates X: 3,497,463' X:

X:

X:

Y: 51,145.00' Y:

Y:

Y:

Latitude/ Longitude Latitude 27 0 53' 32.469" N Latitude

Latitude

Latitude

Longitude 94 0 21' 50.411" W Longitude Longitude Longitude

Water Depth (Feet): 492' MD (Feet): TVD (Feet): MD (Feet): MD (Feet): MD (Feet): TVD (Feet): TVD (Feet): TVD (Feet): Anchor Radius (if applicable) in feet: 4,000'

Anchor Locations for Drilling Rig or Construction Barge (If anchor radius supplied above, not necessary)

Anchor Name or No. Area Block X Coordinate Y C oordinate Length of Anch or Chain on Seafloor

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

Form BOEM- 0137 (December 2011 – Supersedes all previ ous editions of this form which may not be used.) Page 2 of 4OCS PLAN INFORMATION FORM (CONTINUED) Include one copy of this page for each proposed well/structure

Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): B Previously reviewed under an a pproved EP or DOCD? Yes x No

Is this an existing well or

structure? Yes x No If this is an existing well or structure, list the Complex ID

or API No.

Do you plan to use a subsea BOP or a surface BOP on a floating facility to conduct your proposed activities? Yes x No

WCD Info For wells, volume of uncontrolled blowout (Bbls/Day): For structures, volume of all storage and pipelines (Bbls): API Gravity of fluid

Surface Location Bottom-Hole Location (For Wells) Completion (For multiple completions, enter separate lines)

Lease No. OCS

OCS

Area Name HI

Block No. A-581

Blockline Departures (in feet) N/S Departure 3500' FSL N/S Departure F __ L N/S Departure F __ L N/S Departure F __ L

E/W Departure 6250' FWL E/W Departure F __ L E/W Departure F __ L E/W Departure F __ L

Lambert X-Y
coordinates X: 3,497,885.81' X:

X:

X:

Y: 58,940' Y:

Y:

Y:

Latitude/ Longitude Latitude 27 0 54' 49.416" N Latitude

Latitude

Latitude

Longitude 94 0 21' 42.260" W Longitude Longitude Longitude

Water Depth (Feet): 430' MD (Feet): TVD (Feet): MD (Feet): MD (Feet): MD (Feet): TVD (Feet): TVD (Feet): TVD (Feet): Anchor Radius (if applicable) in feet: NA

Anchor Locations for Drilling Rig or Construction Barge (If anchor radius supplied above, not necessary)

Anchor Name or No. Area Block X Coordinate Y C oordinate Length of Anch or Chain on Seafloor

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

Form BOEM- 0137 (December 2011 – Supersedes all previ ous editions of this form which may not be used.) Page 2 of 4Walter Oil & Gas Corporation Section 2 – Pg. 6 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 

### SECTION 2

GENERAL INFORMATION

2.1 APPLICATIONS AND PERMITS Following is a table listing all additional applications/permits which will require approval prior to conducting the operations proposed in this plan.

Application/Permit Issu ing Agency Status

Application for Permit to
Drill BSEE To be submitted

2.2 DRILLING FLUIDS The table below provides information on the types and amounts of the drilling fluids Walter plans to use to drill the proposed wells.

Type of Drilling Fluid Estimated Volume of Drilling Fluid to be Used per Well
Water-based 5,000 bbls Oil-based (diesel, minerals) 0 Synthetic-based 0

2.3 NEW OR UNUSUAL TECHNOLOGY No new or unusual technology is proposed to carry out activities in th is in this Initial Exploration Plan.

2.4 BONDING STATEMENT The bond requirements for the activities and facilities proposed in th is EP are satisfied by an areawide bond, furnished and maintained according to 30 CFR 256, subpart I;
NTL No. 2000-G16, "Guidelines for General Lease Surety Bonds."

2.5 OIL SPILL FINANCIAL RE SPONSIBILITY (OSFR) Walter, Operator number 730 has demonstrated oil spill financ ial responsibility for the facilities proposed in this EP according to 30 CFR Part 253; and NTL 2008-N05, "Guidelines for Oil Spill Financial Responsibility for Covered Facilities."

2.6 DEEPWATER WELL CONTROL STATEMENT Operations proposed in this pl an are located in water depths less than 300 meters (984 feet); therefore, a deepw ater well control statem ent is not provided.Walter Oil & Gas Corporation Section 2 – Pg. 7 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 2.7 BLOWOUT SCENARIO AND WORS T CASE DISCHARGE CALCULATIONS
In accordance with NTL 2010-N06, “Informa tion Requirements for Exploration Plans, Development and Production Plans, and De velopment Operations Coordination
Documents on the OCS,” the blowout scenario and worst case disch arge calculations

are included as Attachment 2-A. The wo rst case discharge rate for these proposed operations is 66,105 bbls/day.

### Attachment 2-A

OCS-G 34032, High Island Block A-588
Blowout Scenario and WCD Data

Blowout Scenario:

Due to the Gulf slowdown there are currently six (6) moored semi-submersible drilling rigs that could drill the relief well. There are no other jack-ups that have the leg lengths to work in this water depth. These six (6) moored semi-submersible rig can work in this water depth with capabilities available for relief well drilling. It is estimated that a contract could be administered and additional equipment procured to drill the relief well in sixty eight days (68). Proximity, availability and safety will be the predominant factor for selecting the relief well rig.

Measure to prevent Blowout:

This well is an exploratory well with close offsets. MWD/PWD will provide downhole pressure information to mitigate risk of blowout. The use of MWD will also provide accurate location of the zone if an incident occurs. Casing will be set above the pay zone of interest to further mitigate any incident.

Additional precautions and safety procedures:

1. Complete detailed well design program for drilling operations including mud program and cement program. Safety meeting will be conducted every to ur to communicate importance of operations.

2. Maintain mud properties consistent with offset wells.

3. Flow monitoring equipment for the rigs mud re turn system with real time data provided to supervisory personnel.

4. Real-time gas monitoring for the purpose of me asuring gas units contained in the mud system for supervisory personnel.

5. Drilling breaks monitored and check for flow. In the event of flow, mud weight will be increased to
control the well.

6. Monitoring of trip volumes both pulling in and out of the hole. Proper fill up volumes will be
measured.

7. Control surge and swab pressures.

8. Circulate bottoms up before trips to insure the well is stable and free of gas.

9. Testing of BOP’s at a minimum of every tw o weeks when rams are changed or BOP’s repaired.

Measures to reduce the likelihood of a blowout:

1. Contractor personnel (driller and tool pusher) have t he authority to shut well(s) in should a well flow be encountered. Company personnel will be informed of the situation.

2. Company personnel will go to the floor immediately to assist Contractor personnel in industry-best practices kill procedure.

3. Proper API casing design and cementing prac tices using centralizers as recommended by simulation to insure centralized casing and 360 degree annular fill up of cement.4. Production casing will have two barriers (float collar and float shoe).

5. Upon bumping the plug in cement operations, float s will be checked. In t he event the floats do not hold, pressure will be maintained for 6-8 hours, an d then shoe tract will be rechecked. Remedial cementing or setting of bridge plug will be taken if necessary to isol ate the shoe tract.

6. Run cement bond log to verify cement quality before displacing well with completion fluid.

Arrangements for drilling relief wells:

1. Review shallow hazards survey to determine positioning of relief well.

2. Contract and mobilize relief well rig.

3 Contract relief well directional drilling company and relief well drilling experts. Incorporate relief well trajectory and well plan

4. Prepare drilling program based on optimum rig position relative to targeted wellbore to optimize intervention. Incorporate relief well trajectory in well plan.

5. Well control experts may attempt to board the vessel and contain the blowout from the surface provided sufficient safety. HFRS equipment may be required to remove debris and provide fire fighting boats for access.

Note: Walter O&G is a member of Clean Gulf and the Helix Well Containment Group and will employ the HFPS (Helix Fast Response System ) in the event the is a spill.

Discussion potential for well to bridge over.

Walter does not have sufficient information to anticipat e that this well would likely bridge over; therefore, discussion of the likelihood of the well to bridge over is not included in this plan. Walter does not have any empirical data.

Discussion of likelihood for surface intervention to stop blowout.

An ongoing operation for surface intervention will wo rk in parallel to the relief well operations. “Well Control” experts will board the rig, provide there is sufficient safety, to review the possibility of surface containment; or coordinate with relief well operations to contain the blowout. Firefighting boats and derrick barges will be employed to control the heat/fi re and strip away surfac e equipment that prohibit
successful surface intervention. A capping stack/diverter arrangement could potentially be used provided wellbore/casing integrity is verified during the operation.

Relief Well

Rig package constraints

No constraints.

Estimated time to drill relief well, including:

Estimated 68 days Time to acquire a rig (days) : 4 days Time to move rig onsite (days) : 14 days Drilling time (days) : 50 days to drill relief wellStatement whether the possibility of us ing a nearby platform was considered

. No nearby platform.

Measure to enhance ability to conduct effective a nd early intervention in the event of a blowout.

Walter Oil & Gas Corporation is a member of He lix Well Control Group and the equipment is on standby
in case of an incident.Walter Oil &Gas Corporation Section 3 – Pg. 8 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 

### SECTION 3

GEOLOGICAL AND GEOP HYSICAL INFORMATION

3.1 GEOLOGICAL DESCRIPTION Proprietary

3.2 STRUCTURE CONTOUR MAP Proprietary

3.3 INTERPRETED 2-D and / Or 3-D SEISMIC LINE(S) Proprietary

3.4 GEOLOGICAL STRUCTURE CROSS-SECTIONS Proprietary

3.5 SHALLOW HAZARDS REPORT In accordance with NTL 2008-G05, “Shal low Hazards Program” (Extended by NTL BOEM 2013-G02, “Extens ion of Prior Notices to Lessees”), a 3-D seismic shallow hazards assessment has been prepared for each proposed surface location, evaluating seafloor and subsurface ge ological and manmade features and conditions that may adversely affect drilling operations. One har d copy and one CD of the shallow hazards report are being submitt ed under separate cover.

3.6 SHALLOW HAZARDS ASSESSMENT In accordance with NTL 2008-G05, “Shal low Hazards Program” (Extended by NTL
BOEM 2013-G02, “Extens ion of Prior Notices to Lessees”), a 3-D seismic shallow hazards assessment has been prepared for each proposed surface location, evaluating seafloor and subsurface ge ological and manmade features and conditions that may adversely affect drilling operations. A s hallow hazards assessment is included as

Attachment 3-D

.

3.7 HIGH-RESOLUTION SEISMIC LINES High resolution seismic lines are incl uded in the Shallow Hazards Report.

3.8 STRATIGRAPHIC COLUMN Proprietary

3.9 TIME VERSUS DEPTH TABLES ProprietaryWalter Oil & Gas Corporation Section 4– Pg. 9 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 

### SECTION 4

HYDROGEN SULFIDE INFORMATION

4.1 CONCENTRATION

Walter does not antici pate encountering any H 2 S during the proposed operations.

4.2 CLASSIFICATION In accordance with Title 30 CFR 550.215, Walter requests that High Island Block A-588 be classified by the BOEM as H 2 S absent.Walter Oil & Gas Corporation Section 5– Pg. 10 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 

### SECTION 5 BIOLOGICAL, PHYSICAL AND SO CIOECONOMIC INFORMATION

5.1 DEEPWATER BENTHIC COMMUNITIES High Island Block A-588 is located in less t han 300 meters (984') of water; therefore, information concerning deepwater benthic comm unities is not included in this plan.

5.2 TOPOGRAPHIC FE ATURES (BANKS) Activities proposed in this EP do not fall within 305 meters (1000 feet) of a topographic “no activity zone;” therefore, no map is required per NTL 2009- G39, “Biologically

Sensitive Underwater Features and Areas.”

5.3 TOPOGRAPHIC FEATURES STATEMENT (SHUNTING) All activities proposed under this EP will be conducted outsi de all Topographic Feature
Protective Zones; therefore shunt ing of drill cuttings and drilling fluids is not required per NTL 2009-G39, “Biologically Sensitive Underwater Features and Areas.”

5.4 LIVE BOTTOMS (PINNACLE TREND FEATURES) High Island Block A-588 is not located within 61 meters (200 feet) of any pinnacle trend
feature; therefore, a separate bathymetric map is not required per NTL 2009-G39, “Biologically Sensitive Under water Features and Areas.”

5.5 LIVE BOTTOMS (LOW RELIEF) High Island Block A-588 is not located within 30 meters (100 feet) of any pinnacle trend

feature with vertical relief e qual to or greater than 8 fee t; therefore, live bottom (low relief) maps are not required per NTL 2009- G39, “Biologically Sensitive Underwater

Features and Areas.”

5.6 POTENTIALLY SENSITIVE BIOLOGICAL FEATURES MAP High Island Block A-588 is not located wit hin 30 meters (100 feet) of potentially sensitive biological features ; therefore, biologically s ensitive area maps are not required.

5.7 REMOTELY OPERATED VEHICLE (ROV) SURVEYS ROV surveys are not required to be submitted with this plan.

5.8 THREATENED AND ENDANGERED SPECIES, CRITICAL HABITAT, AND

MARINE MAMMAL INFORMATION In accordance with 30 CFR 550, Subpar t B, and further outlined in NTL 2008-G04, “Information requirements for Explorat ion Plans and Development Operations Coordination Documents” (Extended by NT L BOEM 2013-G02, “Extension of PriorWalter Oil & Gas Corporation Section 5– Pg. 11 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 Notices to Lessees”), and NTL 2012-JOINT-G01,”Vessel Strike Avoidance and Injured/Dead Protected Species Reporting,” lessees/operators are required to address site-specific information on the presence of federally listed th reatened or endangered species and critical habita t designated under the ESA and marine mammals protected under the Marine Mammal Protection Act (MMPA) in the area of proposed activities under this plan.

There are five (5) species of sea turtles t hat may be found in the Gu lf of Mexico (see table below). NOAA fisheries currently list all five of these turtles as endangered (E) or threatened (T).

Species Scientific Name Status Potential
Presence Critical
Habitat Designated in

the Gulf of
Mexico Lease

Area Coastal

Sea Turtles Loggerhead Carettsa caretta T x x None
Green Chelonia mydas T,E x x None
Leatherback Dermochelys coriacea E x x None
Hawksbill Eretmochelys
imbricata E x x None

Kemp’s Ridley Lepidochelys kempli E x x None

In addition, there are 28 species of marine mammals that may be found in the Gulf of Mexico. The table provided below identifies the seven (7) species of marine mammals

that are listed as enda ngered or threatened. Cu rrently, there are no designated critical habitats for the listed species in the Gulf of Mexico Outer Continen tal Shelf; however, it is possible that one or more of these species could be seen in the area during operations.

Species Scientific Name Status Potential
Presence Critical
Habitat Designated in

the Gulf of
Mexico Lease

Area Coastal

Marine Mammals Sperm
Whale Physeter macrocephalus E x -- None

WesIndian
Manatee Trichechus manatus
latirostris E -- x Florida (Peninsular)
Blue Whale Balaenoptera E x -- NoneWalter Oil & Gas Corporation Section 5– Pg. 12 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 masculus
Fin Whale Balaenoptera physalus E x -- None

Humpback
Whale Megaptera novaeangliae E x -- None

NorthAtlantic Right Whale Eubalaena glacialis E x -- None

Sei Whale Balaenopiera borealis E x -- None

5.9 ARCHAEOLOGICAL REPORT In accordance with NTL 2005-G07 “Archaeological Surveys and Reports,” and NTL
2011-JOINT-G01, “Revisions to the List of OCS Lease Blocks Requiring Archaeological Resource Surveys and Reports,” an Archaeolog ical Survey Report is being submitted under separate cover.

5.10 AIR AND WATER QUALITY INFORMATION Air and water quality information is not required to be included in this plan per NTL 2008-G04, “Information Requirements for Exploration Plans and Development Operations Coordi nation Documents.”

5.11 SOCIOECONOMIC INFORMATION Socioeconomic Information is not required to be included in this plan per NTL 2008- G04, “Information Requirement s for Exploration Plans and Development Operations
Coordination Documents.”Walter Oil & Gas Corporation Section 6 – Pg. 13 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 

### SECTION 6

WASTES AND DISCHARG ES INFORMATION

6.1 PROJECTED GENERATED WASTES

Generated wastes that will be treated and disposed of downhole are included in

Attachment 6-A.

6.2 MODELING REPORT Modeling reports are not required to be submitted with this plan.please specify if the amount reported is a total orper well amountProjected generated waste Projected ocean dischargesType of Waste Composition Projected Amount Discharge rate Discharge Method Answer yes or noWill drilling occur ? If yes, you should list muds and cuttingsEXAMPLE: Cuttings wetted with syntheticbased fluidCuttings generatedwhileusing synthetic baseddrilling fluid.X bbl/well X bbl/day/well discharge overboard NoWater-based drilling fluidWater based drillingfluids 5,000 bbls/well 200 bbls /day/well Discharge overboard NoCuttings wetted with water-based fluidCuttings generatedwhile using waterbased drilling fluids 3,800 bbls/well 120 bbls/day/well Discharge overboard NoWill humans be there? If yes, expect conventional wasteEXAMPLE: Sanitary waste waterSanitary waste fromliving quartersX bbl/well X bbl/hr/wellchlorinate and discharge overboardNoDomestic waste Gray Water 15,128 bbls/well 122 bbls/day/well(2x) Hamworthy Super Trident 8 biological SewageTreatment Plants, IMO & MED certified & accepted byUSCG for non-US flagged vessels in US waters.Discharge through Port side caisson (cutting chute)below sea level. Note Based on Max POBNoSanitary wasteHuman body treatwaste discharged fromtoilets 1849 bbls/well 15 bbls/day/wellUSCG approved treatment tank anddischarged, Omni-Pure Model 12MC,discharged overboard NoIs there a deck? If yes, there will be Deck DrainageDeck DrainageRain water and rigwash6530 bbls/well15 bbls/hr /dependent onrainfallOil Water Seperator, Recovered Energy, Inc.,Model Boss 45T/107 discharge overboardNoATTACHMENT 6-AWASTES YOU WILL GENERATE, TREAT AND DOWNHOLE DISPOSE OR DISCHARGE TO THE GOMProjectedDownholeDisposalDeckDrainagewash6530bbls/wellrainfallModelBoss45T/107,dischargeoverboardNoWill you conduct well treatment,completion, or workover?Well treatment fluidsViscous and csg washspacers using HEC andsmall amounts sodium 200bbls/well 50 bbls/day/well discharge overboardNoWell completion fluids Calcium Chloride 500 bbls/well 50 bbld/day/well discharge overboardNoCompletion wash fluids from tank cleaningseawater 200 bbls/well 50 bbls/day/well discharge overboardNoMiscellaneous discharges. If yes, only fill in those associated with your activity.Desalinization unit dischargeNA 106,764 bbls/well 891 bbls/well/day overboardNoBlowout prevent fluidNA NA NA NANoBallast waterNA NA NA NANoBilge waterNA NA NA NANoExcess cement at seafloorNANA NANANoFire waterNA NA NA NANoCooling water NA NANA NANoWill you produce hydrocarbons? Ifyes fill in for produced water.Produced water NA NANANANAWill you be covered by an individual or general NPDES permit ? GeneralNOTE: If you will not have a type of waste, enter NA in the row.Walter Oil & Gas Corporation Section 7 – Pg. 14 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 

### SECTION 7

AIR EMISSIONS INFORMATION

7.1 EMISSIONS WORKSHEETS AND SCREENING QUESTIONS

Screen Procedures for EP’s Yes No Is any calculated Complex Total (C T) Emission amount (tons) associated with your proposed exploration activi ties more than 90% of the amounts calculated using the following formulas: CT = 3400D 2/3 for CO, and CT = 33.3D for the other air pollutants (wher e D = distance to shore in miles)? x

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

Are your proposed exploration activities located east of 87.5° W longitude? x Do you expect to encounter H 2 S at concentrations greater than 20 parts per million (ppm)? x

Do you propose to flare or vent na tural gas for more than 48 continuous hours from any proposed well? x

Do you propose to burn produced hydrocarbon liquids? x

7.2 SUMMARY INFORMATION Summary information regarding the peak year emissions that will be generated by and

associated with the Plan Emi ssions and Complex Total Emi ssions are provided in the

table below.

Air Pollutant Plan Emission
Amounts (tons) Calculated Exemption
Amounts

(tons) Calculated Complex

Total
Emission
Amounts

(tons) Carbon Monoxide (CO) 140.31 68,751.74 140.31 Particular matter (PM) 18.71 3027.97 18.71 Sulphur dioxide (SO 2 ) 85.82 3027.97 85.82 Nitrogen oxides (NO
x ) 643.08 3027.97 643.08 Volatile organic compounds (VOC) 19.29 3027.97 19.29

This information was calculated by: Judy Davidson (281) 578-3388 judy.davidson@jccteam.comWalter Oil & Gas Corporation Section 8 – Pg. 15 of 25 Initial Exploration Plan August, 2013 High Island Block A-588 (OCS-G 34032) 

### SECTION 8

OIL SPILLS INFORMATION

8.1 OIL SPILL RESPONSE PLANNING All the proposed activities and facilities in the EP will be covered by Walter Oil & Gas Corporation's last approved O il Spill Response Plan (OSR P) dated July, 2011 and last approved on April 19, 2013 (OSRP Control Number 0-370).

8.2 SPILL RESPONSE SITES Primary Response Equipment
Location Preplanned Staging Location

Houma, LA Houma, LA Harvey, LA Harvey, LA Galveston, TX Galveston, TX

8.3 OSRO INFORMATION Walter's primary equipment prov ider is Clean Gulf Associat es (CGA). CGA will also provide closest available personnel, as well as supervisors to opera te the equipment.

8.4 WORST CASE SCENARIO DETERMINATION

Category Regional OSRP
WCD EP
WCD

Type of Activity Drilling Drilling

Facility Location (Area/Block) EW 834 HI A-581 Surface
Location

Facility Designation A B

Distance to Nearest Shoreline (miles) 64 90.93 miles

Volume Storage Tanks (Total)
Uncontrolled blowout
Total Volume 169,488 bbls 169,488 bbls 66,105 66,105 Type of Oil(s) (crude, condensate, diesel) Crude Oil Crude Oil

API Gravity 24 0 32 0Walter Oil & Gas Corporation Section 8 – Pg. 16 of 25 Initial Exploration Plan August, 2013 High Island Block A-588 (OCS-G 34032) Walter's WCD was verified and approved in Plan Control Number S-7359. Walter has
determined that the worst-case scenario from the activities propos ed in this EP do not supersede the worst-case scenario from our approved Regional OSRP.

Since Walter has the capability to respond to the worst-case spill scenario included in our Regional OSRP, and since the worst-ca se scenario determined for our EP does not replace the worst-case scenario in our Regi onal OSRP, Walter hereby certifies that Walter has the capability to respond, to the maximum extent practicable, to a worstcase discharge, or a substantia l threat of such a discharge, resulting from the activities proposed in our EP.

8.5 OIL SPILL RESPONSE DISCUSSION An oil spill response discussion is included as Attachment 8-A.Attachment 8-A

For the purpose of NEPA and Coastal Zone Mana gement Act analysis, the largest spill volume originating from the proposed activity would be a well bl owout during drilling operations, estimated to be 66,105 barrels of crud e oil with an API gravity of 32°.

Land Segment and Resource Identification

Trajectories of a spill and the probability of it impacting a land segment have been projected utilizing information in the BS EE Oil Spill Risk Analysis Model (OSRAM) for the Central and
Western Gulf of Mexico available on the BSEE website. The results are shown in Figure 1. The BSEE OSRAM identifies a 15% probabi lity of impact to the shor elines of Matagorda County, Texas within 30 days. Matagorda County stretc hes from Matagorda Bay, across the Colorado River and up to the border of San Bernard Wildli fe Refuge (immediately we st of the San Bernard River). The county includes Ma tagorda Peninsula on the Gulf coast and Matagorda Bay. This area is primarily open beach. However, marshland exists along the east si de of Matagorda Bay. Several bird rookeries are present around the peni nsula. Seagrass is present off of Matagorda Peninsula on the bay side.

Response

Walter will make every effort to respond to th e Worst Case Discharge as effectively as practicable. A description of the response equipment under contra ct to contain and recover the Worst Case Discharge is shown in Figure 2.

Using the estimated chemical and physical charact eristics of crude oil, an ADIOS weathering model was run on a similar product from the ADIO S oil database. The results indicate 23% or approximately 15,204 barrels of crude oil would be evaporated/dispersed w ithin 24 hours, with approximately 50,901 barrels remaining.

Spill Response HI A-581, Well Location B Barrels of Oil

WCD Volume 66,105

Less 23% natural evaporation/dispersion 15,204

Remaining volume 50,901

Figure 2 outlines equipment, personnel, materials and support vessels as well as temporary storage equipment available to respond to a spill of approximately 50,901 barrels. The volume accounts for the amount remaining after evaporatio n/dispersion at 24 hours. The list estimates individual times needed for proc urement, load out, travel time to the site and deployment. Figure

2 also indicates how operations will be supported.

Walter’s Oil Spill Response Plan includes alternative response technologies such as dispersants and in-situ burn. Strategies will be decided by Unified Command based on the size of the spill, weather and potential impacts. If aerial dispersants are utili zed, 8 sorties (9,600 gallons) fromtwo of the DC-3 aircrafts and 4 sorties (8,000 gall ons) from the Basler ai rcraft would provide a daily dispersant capability of 7,540 barrels. If th e conditions are favorable for in-situ burning, the proper approvals have been obtained and the prope r planning is in place, in-situ burning of oil may be attempted. Slick containment boom woul d be immediately calle d out and on-scene as soon as possible. Offshore response strategies may include attempting to skim utilizing the HOSS Barge, nine Fast Response Units (FRUs) , and two sets of Aqua Guard Triton RBS skimmers, with a total dera ted skimming capacity of 126,819 barrels. Temporary storage associated with skimming equipm ent equals 9,700 barrels. If addi tional storage is needed, a 47,000 barrel storage barge, a 25,000 barrel storage barge, and two 23,000 barrel storage barges may be mobilized and centrally located to provide temporary storage allowing the skimmers to stay in the area of operations as much as possible. Safety is first priority. Air monitoring will be accomplished and operations deemed safe prio r to any containment/skimming attempts.

If the spill went unabated, s horeline impact in Matagorda County, Texas would depend upon existing environmental conditions. Shoreline prot ection would include the use of CGA’s near
shore and shallow water skimmers with a tota led derated skimming capacity of 8,891 barrels. Temporary storage associated with skimming equipment equals 210 barrels. If additional storage is needed, a 20,000 barrel storage barge may be mobilized and centrally located to provide temporary storage allowing the skimmers to stay in the area of operations as much as possible. Onshore response may include the deployment of shoreline boom on beac h areas, or protection and sorbent boom on vegetated areas. A Master Service Agreement with Miller Environmental will ensure access to 88,000 feet of 18” shoreline protection boom. Figure 2 outlines individual times needed for procurement, load out, travel ti me to the site and depl oyment. Strategies would be based upon surveillance and real time trajectorie s that depict areas of potential impact given actual sea and weather conditions. Applicable Area Contingency Plans (ACPs), Geographic Response Plans (GRPs), and Unifie d Command would be consulted to ensure that environmental and special economic resources woul d be correctly identified and prioritized to ensure optimal protection. Shoreline protect ion strategies depict the protecti on response modes applicable for oil spill clean-up operations. Each response mode is schematically represented to show optimum deployment and operation of the equipment in ar eas of environmental concern. Supervisory personnel have the option to modify the deploym ent and operation of equipment allowing a more effective response to site-specific circumstan ces. Walter’s contract Spill Management Team holds copies of the applicable ACPs and GRPs..

Based on the anticipated worst case discharge scen ario, Walter can be onsite with contracted oil spill recovery equipment with adequate response capacity to contain and recover surface hydrocarbons, and prevent land impact, to the maximum extent practicable, within an estimated 50 hours (based on the equipment’s Effectiv e Daily Recovery Capacity (EDRC)).Initial Response Considerations Actual actions taken during an oil spill response will be based on many factors which include but

are not limited to:

• Weather

• Equipment and materials availability

• Ocean currents and tides

• Location of the spill

• Product spilled

• Amount spilled

• Environmental risk assessments

• Trajectory and product analysis

• Well status, i.e., shut in or continual release

Walter will take action to provide a safe, aggressive response to co ntain and recover as much of the spilled oil as quickly as it is safe to do so. In an effort to protect the environment, response actions will be designed to provide an “in-depth” protection strategy meant to recover as much oil as possible as far from environmentally se nsitive areas as possible. Safety will take precedence over all other considerations during these operations.

Coordination of response assets will be supe rvised by the designation of a SIMOPS group as necessary for close quarter vessel response activitie s. Most often, this gr oup will be used during source control events that require a significant nu mber of large vessels operating independently, but in coordination to complete a common objec tive, in a small area and in close coordination and support of each other. This group must also monitor the subsurface activ ities of each vessel (ROV, dispersant application, well control sup port, etc.). The SIMOPS group leader reports to
the Source Control Section Chief.

In addition, these activities will be monitored by the spill mana gement team (SMT) and Unified
Command via a structured Common Operating Picture (COP) esta blished to track resource and
slick movement in real time.

Upon notification of a spill, the following actions will be taken:

• Information will be confirmed

• An assessment will be made and initial objectives set

• OSROs and appropriate agen cies will be notified

• ICS 201, Initial Report Form will be completed

• Initial Safety plan will be written and published

• Unified Command will be established

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

o Areas of responsibility esta blished for Source Control a nd each surface operational

site

o On-site command and control establishedDecanting Strategy Recovered oil and water mixtures will typically se parate into distinct phases when left in a quiescent state. When separati on occurs, the relatively clean water phase can be siphoned or decanted back to the recovery point with minima l, if any, impact. Decan ting therefore increases the effective on-site oil storage capacity a nd equipment operating time. FOSC/SOSC approval will be requested prior to decanting operations. This practice is routinely used for oil spill

recovery.

Offshore Response Actions

Equipment Deployment
Surveillance

• Surveillance Aircraft will be deployed within two hours of Qu alified Individual (QI) notification, or at first light

• Provide trained observer to pr ovide on site status reports

• Provide command and control platfo rm at the site if needed

• Continual surveillance of oil movement by remote sensing systems, aerial photography
and visual confirmation

• Continual monitoring of vessel assets using vessel monitoring systems

Dispersant application assets

• Put Airborne Support In c. (ASI) on standby

• With the Federal On-Scene Coordinator (FOSC), conduct analysis to determine appropriateness of dispersant application

• Gain FOSC approval for use of dispersants on the surface

• Deploy aircraft in accordance with a plan developed for the actual situation

• Coordinate movement of dispersants, ai rcraft, and support equipment and personnel

• Confirm dispersant availability fo r current and long range operations

• Start ordering dispersa nt stocks required for expected operations

Containment boom

• Call out early and expedite deployment to be on scene ASAP

• Ensure boom handling and mooring equipment is deployed with boom

• Provide continuing reports to vessels to expedite their arrival at sites that will provide for
their most effective containment

• Use Vessels of Opportunity (VOO) to deploy and maintain boom

Dedicated off-shore skimming systems
General

• Deployed to the highest concentration of oil

• Assets deployed at safe distance from aer ial dispersant and in-situ burn operationsCGA HOSS Barge

• Use in areas with heaviest oil concentrations

• Consider for use in areas of known debris (seaweed, and other floating materials)

CGA FRUs

• To the area of the thickest oil

• Use as far off-shore as allowed

• VOOs 140’ – 180’ in length

• VOOs with minimum of 18’ x 38’ or 23’ x 50’ of optimum deck space

• VOOs in shallow water should have a dr aft of <10 feet when fully loaded

Storage Vessels

• Establish availability of CGA contracted assets

• Early call out (to allow for tug boa t acquisition and deployment speeds)

• Phase mobilization to allow storage vessels to arrive at the same time as skimming
systems

• Position as closely as possible to ski mming assets to minimize offloading time

Vessels of Opportunity (VOO)

• Use Walter’s contracted re sources as applicable

• Industry vessels are usually best for deployment of Vessel of Opportunity Skimming Systems (VOSS)

• Acquire additional resources as needed

• Consider use of local assets, i.e. fishing and pleasure craft

• Expect mission specific and sa fety training to be required

• Plan with the US Coast Guard for vessel inspections

In-situ Burn assets

• Determine appropriateness of in-situ burn ope ration in coordination with the FOSC and affected State On-Scene Coordinator (SOSC)

• Determine availability of fire boom and selected ignition systems

• Start ordering fire boom stocks required for expected operations

• Contact boom manufacturer to provide training if required

• Determine assets to perform on water operation

• Build operations into safety plan

• Conduct operations in accordance with an approved plan

Adverse Weather Operations: In adverse weather, when seas are > 3 feet, the use of larger recovery and storage vessels, oleophilic skimmers, and large offshore boom will be maximized. Safety will be the overriding factor in all operations and will cease at the order of the Unified Command, vessel captain, or in an emergency, ”stop work” may be directed by any crew member.Near Shore Response Actions

Timing

• Place near shore assets on standby and depl oy in accordance with planning based on the actual situation, actual traj ectories and oil budgets

• VOO identification and training in advance of spill nearing sh oreline if possible

• Outfitting of VOOs for specific missions

• Deployment of assets based on actual movement of oil

Considerations

• Water depth, vessel draft

• Shoreline gradient

• State of the oil

• Use of VOOs

• Distance of surf zone from shoreline

Equipment Deployment
Surveillance

• Provide trained observer to direct skimming operations

• Continual surveillance of oil movement by remote sensing systems, aerial photography
and visual confirmation

• Continual monitoring of vessel assets

Dispersant Use

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

• Approval would be at Regional Re sponse Team level (Region 6)

Vessel Deployment Dedicated Near Shore skimming systems

• Fast Response Vessels (FRV)

• Egmopol and Marco Shallow Water Skimmer (SWS)

• Operate with aerial spotter directi ng systems to observed oil slicks

VOO

• Use Walter’s contracted re sources as applicable

• Industry vessels are usually best for deployment of Vessel of Opportunity Skimming Systems (VOSS)

• Acquire additional resources as needed

• Consider use of local assets, i.e. fishing and pleasure craft

• Expect mission specific and sa fety training to be required

• Plan with the US Coast Guard for vessel inspections

• Operate with aerial spotter directing systems to oil patchesShoreline Protection Operations

Response Planning Considerations

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

• Time to acquire personnel and eq uipment and their availability

• Previous contingency planning contained in the appropriate Area Contingency Plan, and currently for Louisiana, The State of Loui siana Initial Oil Spill Response Plan, Deep Water Horizon, dated 2 May 2010

Actions

Placement of boom

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

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

o Trajectories

o Weather forecast

o Oil Impact forecast

o Verified spill movement

o Boom, manpower and vessel (shallow draft) availability

o Near shore boom and support material, (stakes, anchors, line)

Beach Preparation

Considerations and Actions

• Use of a 10 mile go/no go line to determine timing of beach cleaning

• Shoreline Cleanup and Assessment Team Reports and recommendations

• Determination of Archeological site s and gaining authority to enter

• Monitoring of tide tables and weather to determine extent of high tides

• Pre cleaning of beaches by moving waste above high tide lines to minimize waste

• Staging of equipment and housing of respons e personnel as close to the job site as possible to maximize on-site work time

• Boom tending, repair, replacement and security (u se of local assets may be advantageous)

• Constant awareness of weather and oil moveme nt for resource redeployment as necessary

• In-situ burn may be considered when marshes have been impacted

• Passive clean up of marshes should be consider ed and appropriate stoc ks of sorbent boom and/or sweep obtained

• Earthen berms and shoreline protection boom may be considered to protect sensitive
inland areasDecanting Strategy Recovered oil and water mixtures will typically se parate into distinct phases when left in a quiescent state. When separati on occurs, the relatively clean water phase can be siphoned or decanted back to the recovery point with minima l, if any, impact. Decan ting therefore increases the effective on-site oil storage capacity a nd equipment operating time. FOSC/SOSC approval will be requested prior to decanting operations. This practice is routinely used for oil spill

recovery.

CGA Equipment Limitations The capability for any spill response equipment, whether a dedicated or portable system, to operate in differing weather conditions will be directly in rela tion to the capabilities of the vessel the system in placed on. Most importantly, however, the decision to operate will be based on the judgment of the Unified Command a nd/or the Captain of the vessel, who will ultimately have the final say in terminating operations. Skimming equipment listed below may have operational limits which exceed those safety thresholds. As was seen in the Deepwater Horizon (DWH) oil spill response, vessel skimming opera tions ceased when seas reache d 5-6 feet and vessels were often recalled to port when those conditions were exceeded. Systems below are some of the most up-to-date systems available and were employed during the DWH spill.

Boom 3 foot seas, 20 knot winds Dispersants Winds more than 25 knots Visibility less than 3 nautical miles Ceiling less than 1,000 feet.

FRU 8 foot seas HOSS Barge/OSRB 8 foot seas Koseq Arms 8 foot seas

OSRV 4 foot seasEnvironmental Conditions in the GOM Prevailing winds, waves and curren ts along the Texas coast are from the southeast and northeast quadrants. Ten to 20 foot waves may occur dur ing hurricanes. The combined effect of the winds, surface currents, and waves refracting shoreward produce the prevailing westerly longshore currents.

Tides are semi-diurnal and diurna l, and range in height from le ss than 1 foot to 2.5 feet. The direction, force, and duration of the wind has a considerable effect on the tides and currents. Fifteen foot tides may be expe cted during severe hurricanes a nd very low tides may accompany strong northerlies of long duration.

Surface water temperature averages slightly less than 90° F and ranges between 80 and 100° F during the late summer. During the wi nter the average is slightly less than 60° F and the range is
between 35 and 80° F.

The Atlantic and Gulf of Mexico hurricane seas on is officially from 1 June to 30 November. 97% of all tropical activity occurs within this window. The Atlant ic basin shows a very peaked season from August through October, with 78% of the tropical storm days, 87% of the minor (Saffir-Simpson Scale categories 1 and 2) hurricane days, and 96% of the major (Saffir-Simpson categories 3, 4 and 5) hurricane days occurri ng then. Maximum activity is in early to mid September. Once in a few years there may be a hurri cane occurring "out of season" - primarily in May or December. Globally, September is the mo st active month and May is the least active

month.FIGURE 1
TRAJECTORY BY LAND SEGMENT

Trajectory of a spill and the probability of it impacting a land segment have been projected utilizing Walter’s WCD and information in the BSEE Oil Spill Risk Analysis Model (OSRAM) for the Central and Western Gulf of Mexico available on the BSEE website using 30 day impact. The results are tabulated below.

Area/Block OCS-G Launch

Area Land Segment and/or

Resource Conditional Probability (%) within 30 days

Drill and complete 2
wells

HI A-581,
Well Location B

90.93 miles from shore G34032 W17 Cameron, TX Kenedy, TX Kleberg, TX Nueces, TX Aransas, TX Calhoun, TX Matagorda, TX

Brazoria, TX Galveston, TX Jefferson, TX Cameron, LA Vermilion, LA 1

2

2

2

3

5
15

8

12

5

7

1WCD Scenario–BASED ON WELL BLOWOUT DURING DRILLING OPERATIONS(90.93 miles from shore)50,901 bbls of crude oil (Volume considering natural weathering)API Gravity 32°FIGURE 2 – Equipment Response Time to HI A-581, Well Location BDispersants/SurveillanceDispersant/SurveillanceDispersantCapacity (gal)StorageCapacityPersons Req.FromHrs toProcureHrs toLoadoutTravel tositeTotal HrsCGABasler 67T2000NA2Houma111.33.3ASIDC 31200NA2Houma111.73.7DC 31200NA2Houma111.73.7Aero CommanderNANA2Houma111.33.3Offshore ResponseOffshore Equipment NoStagingEDRCStorageCapacityVOOPersons Req.FromHrs toProcureHrs toLoadoutHrs toGOMTravel toSpill SiteHrs toDeployTotalHrsCGAHOSS Barge4300040003 Tugs5Harvey70528.8141.8Boom Barge (CGA-300)42” Auto Boom (25000’)NANA1 Tug50 Crew4 (Barge)2 (Per Crew)Leeville40637.91.549.4Recovered Oil Storage NoStagingEDRCStorageCapacityVOOPersons Req.FromHrs toProcureHrs toLoadoutHrs toGOMTravel toSpill SiteHrs toDeployTotalHrsEnterprise Marine Services LLC (available through contract with CGA)CTCo 2603NA250001 Tug6Amelia412425146CTCo 2607NA230001 Tug6Amelia412425146CTCo 2608NA230001 Tug6Amelia412425146CTCo 5001NA470001 Tug6Amelia412425146Staging Area: GalvestonOffshore Equipment WithStagingEDRCStorageCapacityVOOPersonsReq.FromHrs toProcureHrs toLoadoutTravel toStagingTravel toSiteHrs toDeployTotalHrsT&T Marine (available through contract with CGA)Aqua Guard Triton RBS (2)4556040002 Utility12Galveston41207.9124.9CGAFRU (1) + 100 bbl Tank (2)42512001 Utility6Galveston1207.9111.9FRU (1) + 100 bbl Tank (1)42511001 Utility6Harvey126.57.9118.4FRU (1) + 100 bbl Tank (2)42512001 Utility6Ingleside1247.9115.9FRU (1) + 100 bbl Tank (2)42512001 Utility6Lake Charles1237.9114.9FRU (2) + 100 bbl Tank (2)85024002 Utility12Leeville1277.9118.9FRU (1) + 100 bbl Tank (2)42512001 Utility6Morgan City125.257.9117.2FRU (2) + 100 bbl Tank (4)85024002 Utility12Venice1287.9119.9Hydro-Fire BoomNANA8 Utility40Harvey (HFB)146.57.9625.4Nearshore ResponseNearshore Equipment NoStagingEDRCStorageCapacityVOOPersonsRequiredFromHrs toProcureHrs toLoadoutHrs toGOMTravel toSpill SiteHrs toDeployTotalHrsCGA46’ FRV500065NA4Galveston100203Enterprise Marine Services LLC (available through contract with CGA)CTCo 2604NA200001 Tug6Amelia412431.25152.25Staging Area: GalvestonNearshore and Inland SkimmersWith StagingEDRCStorageCapacityVOOPersonsReq.FromHrs toProcureHrs toLoadoutTravel toStagingTravel toDeploymentHrs toDeployTotalHrsCGASWS Egmopol3000100NA3Galveston120205Foilex Skim Package (TDS 150)89145NA3Galveston120208Shoreline ProtectionStaging Area: GalvestonShoreline Protection BoomVOOPersons Req.Storage/WarehouseLocationHrs toProcureHrs toLoadoutTravel toStagingTravel toDeploymentHrs toDeployTotalHrsMiller Environmental (available through MSA)14,000’ 18” Boom6 Crew12Sulphur, LA.512.75228.2514,000’ 18” Boom6 Crew12Beaumont, TX.512227.560,000’ 18” Boom10 Crew20Corpus Christi, TX.524.252816.75Beach BoomEDRCStorageCapacityVOOPersonsReq.FromHrs toProcureHrs toLoadoutTravel toStagingTravel toDeploymentHrs toDeployTotalHrsCGABeach Boom (2000’)NANANA6Galveston120126Beach Boom (1000’)NANANA4Ingleside1241210Beach Boom (2000’)NANANA6Pascagoula127.51213.5Wildlife ResponseEDRCStorageCapacityVOOPersonsReq.FromHrs toProcureHrs toLoadoutTravel toStagingTravel toDeploymentHrs toDeployTotalHrsCGAWildlife Support TrailerNANANA2Houma1261212Bird Scare Guns (24)NANANA2Belle Chasse126.51212.5Bird Scare Guns (12)NANANA2Galveston120126Bird Scare Guns (24)NANANA2Houma1261212Bird Scare Guns (12)NANANA2Ingleside1241210Bird Scare Guns (24)NANANA2Lake Charles123129Bird Scare Guns (24)NANANA2Pascagoula127.51213.5Response AssetTotalOffshore EDRC126,819Offshore Recovered Oil Storage127,700Nearshore / Shallow Water EDRC8,891Nearshore / Shallow Water Recovered Oil Storage20,210Walter Oil & Gas Corporation Section 9 – Pg. 17 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 

### SECTION 9

ENVIRONMENTAL MONITORING INFORMATION

9.1 MONITORING SYSTEMS

There are no environmental m onitoring systems currently in place or planned for the proposed activities.

9.2 INCIDENTAL TAKES There is no reason to believe that any of the endangered species or marine mammals

as listed in the ESA will be “taken as a result of the operations proposed under this plan.

It has been documented that the us e of explosives and or seismic devices can affect marine life. Operations proposed in this plan will not be utilizing either of these devices.

Walter will adhere to the requi rements as set forth in the following documents, as applicable, to avoid or minimize impacts to any of the species listed in the Endangered Species Act (ESA) as a result of the operations conducted herein:

• NTL 2012-JOINT-G01, “Vessel Strike Avoidance and Injured/Dead Protected Species Reporting”

• NTL 2012 BSEE G01, "Mari ne Trash and Debris Aware ness and Elimination"

• NTL 2012-JOINT-G02, “Implementation of Seismic Survey Mitigation Measures and Protected Species Observer Program”

9.3 FLOWER GARDEN BANKS NAT IONAL MARINE SANCTUARY High Island Block A-588 is not located in the Flower Garden Banks National Marine Sanctuary; therefore, t he requested information is not required in this EP.Walter Oil & Gas Corporation Section 10 – Pg. 18 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 

### SECTION 10

LEASE STIPULATIONS INFORMATION

Exploration activities are subject to the following stipulation attached to High Island
Block A-588.

10.1 MARINE PROTECTED SPECIES The Marine Protected Species lease stipulat ion is meant to reduce the potential taking of marine protected species. Walter will operate in accordance with NTL 2012-JOINTG01, “Vessel Strike Avoidance and Injur ed/Dead Protected Species Reporting,” to minimize the risk of vessel strikes to prot ected species and report observations of injured or dead protected spec ies, and the prevention of in tentional and/or accidental

introduction of debris into the marine environment.Walter Oil & Gas Corporation Section 11 – Pg. 19 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 

### SECTION 11

ENVIRONMENTAL MITIGATION MEASURES INFORMATION

11.1 MEASURES TAKEN TO AVOID, MI NIMIZE, AND MITIGATE IMPACTS High Island Block A-588 is not located offs hore Florida; theref ore, the information requested is not required in this plan.

11.2 INCIDENTAL TAKES Walter will adhere to the requi rements as set forth in the following documents, as applicable, to avoid or minimize impacts to any of the species listed in the Endangered Species Act (ESA) as a result of the operations conducted herein:

• NTL 2012-JOINT -G01, “Vessel Strike Avoidance and Injured/Dead Protected Species Reporting”

• NTL 2012 BSEE G01, "Mari ne Trash and Debris Aware ness and Elimination"

• NTL 2012-JOINT-G02, “Implementation of Seismic Survey Mitigation Measures and Protected Species Observer Program”Walter Oil & Gas Corporation Section 12– Pg. 20 of 25 Initial Exploration Plan August, 2013 High island Block A-588, OCS-G 34032 

### SECTION 12

SUPPORT VESSELS AND AIRCRAFT INFORMATION

12.1 GENERAL The most practical, direct route from the shore base as permitted by weather and traffic

conditions will be utilized.

Type Maximum Fuel Tank Capacity Maximum
Number in Area at Any Time Trip Frequency
or Duration Tug Boats 3000 bbls 3 2 days

Anchor Handling Boat 1500 bbls 2 As needed

Crew Boat 500 bbls 1 4 trips/week

Supply Boat 500 bbls 1 2 trips/week
Helicopters 560 bbls 1 As needed

12.2 DIESEL OIL SUPPLY VESSELS

Size of Fuel Supply Vessel Capacity of Fuel Supply Vessel Frequency of Fuel
Transfers Route Fuel Supply
Vessel Will Take
180’ 1500 Once per week Shortest route from
Shore base to
block.

12.3 DRILLING FLUID TRANSPORTATION Drilling fluid transportation information is not required to be submitted with this plan.

12.4 SOLID AND LIQUID WASTE TRANSPORTATION A table, “Wastes You Will Transpor t and/or Dispose of Onshore,” is included as

Attachment 12-A.

12.5 VICINITY MAP A vicinity map showing the location of the activities proposed herein relative to the shoreline with the distance of the proposed ac tivities from the sh oreline and the primary routes of the support vessels and aircraft t hat will be used when traveling between the onshore support facilities and the drilling rig is included as Attachment 12-B.please specify whetherthe amountreportedis atotalorper wellProjected generatedwasteSolid and LiquidWastes transportationType of Waste Composition Transport MethodName/Location ofFacility Amount Disposal MethodWill drilling occur ? If yes, fill in the muds and cuttings.EXAMPLE: Synthetic-based drilling fluid ormudinternal olefin, esterBelow deck storage tanks onoffshore support vesselsNewpark, Fourchon,LouisianaX bbl/well RecycledNo spent drilling fluids or cuttings will bedisposed of onshore. NA NA NA NA NAWill you produce hydrocarbons? If yes fill in for produced sand.Produced sandNA NA NA NA NAEXAMPLE: trash anddebris (recylables) Plastic, paper, aluminum barged in a storage binARC, New Iberia, LAXlb/well RecycledTrash and debrisWhile drilling Paper & PlasticGarbage bags on Supply or CrewBoatEPS Dock, Fourchon,LA121 bags at 40 cf perbag/per wellLandfillRags & FiltersOily rags/absorbent pads,used oil filters 19 DOT Drums on Supply boatPSC Houston, Texas22 drums/per wellIncinerationWhile Drilling Paint solventsWaste DisposalATTACHMENT 12-AWASTES YOU WILL TRANSPORT AND /OR DISPOSE OF ONSHOREWill you have additional wastes that are not permitted for discharge? If yes,fill in the appropriate rows.Chemical product wastesWhileDrilling-Paint,solvents,light bulbs 19 DOT Drums on Supply boatPSC Houston, Texas300 lbs./per well Hazardous WasteUsed Oil Used engine oil550 gal portable totes on SupplyboatSimons PetroleumOklahoma City, OK 10 totes/per well RecycledCooking OilUsed cooking oil5 gal jugs on supply boat PSC Houston, Texas9 - 5 gals. Jug/per well RecycledFreonUsed freon5 gal cylinders on supply boat PSC Houston, Texas1 - 5 gals. Cylinder/perwellRecycledBatteriesBatteries5 gallon drum on supply boat PSC Houston, Texas 10 gal/wellRecycledNOTE: If you will not have a type of waste, enter NA in the row.Walter Oil & Gas Corporation Section 13 – Pg. 21 of 25 Initial Exploration Plan August, 2013 High Island Block A-588 (OCS-G 34032) 

### SECTION 13

ONSHORE SUPPORT FACILITIES INFORMATION

13.1 GENERAL

Name of Shore base Locat ion Existing/New/Modified
Martin Midstream Freeport, Texas Existing

13.2 SUPPORT BASE CONSTRUCTION OR EXPANSION

There will be no new construction of an onshore suppor t base, nor will we expand the existing shore base as a result of the operations proposed in this EP.

13.3 SUPPORT BASE CONSTRUCTION OR EXPANSION TIMETABLE A support base construction or expansion ti metable is not required for this plan.

13.4 WASTE DISPOSAL The Table, “Wastes You Will Transport and/ or Dispose of Onshore," is included as

Attachment 12-A.Walter Oil & Gas Corporation Section 14 – Pg. 22 of 25 Initial Exploration Plan August, 2013 High island Block A-588, OCS-G 34032 

### SECTION 14

COASTAL ZONE MANAGEMENT ACT (CZMA) INFORMATION

As authorized by the Federal Coastal Zo ne Management Act (CZM A), the State of Texas developed a Coastal Management Program (CMP) to allow for the review of proposed Federal license and permit activities affecting any coastal use or resource, in

or outside of the Texas Coastal Zone.

The OCS related oil and gas exploratory and development activities having potential impact on the Texas Coastal Zone are based on the location of the proposed facilities, access to those sites, best practical techniq ues for drilling location s, drilling equipment guidelines for the prevention of adverse environmental effe cts, effective environmental protection, emergency pl ans and contingency plans.

Below are topics found in other sections of the plan and have been cross referenced for ease in locating:

Topic Cross Reference Comments Construction, Operation and
Maintenance of Oil and Gas Exploration and Production
Facilities 1 Plan Contents

2 General

Discharges of Wastewater and Disposal of Waste from Oil and Gas Exploration and
Production Activities 6 Wastes and Discharges

7 Air Emissions 8 Oil Spill 12 Support Vessels and Aircraft 13 Onshore Support Facilities Construction and Operation of Solid Waste Treatment, Storage, and Disposal
Facilities 6 Wastes and Discharges 12 Support Vessels and Aircraft 13 Onshore Support Facilities

Prevention, Response, and Remediation of Oil Spills 8 Oil Spill 5 Biological, Physical,

Socioeconomic 15 Environmental Impact Analysis Discharge of Municipal and
Industrial Waste Water to
Coastal Waters 6 Wastes and Discharges

Development in Critical
Areas 5 Biological, Physical and

SocioeconomicWalter Oil & Gas Corporation Section 14 – Pg. 23 of 25 Initial Exploration Plan August, 2013 High island Block A-588, OCS-G 34032 10 Lease Stipulations 11 Environmental Mitigation 13 Onshore Support Facilities 15 Environmental Impact Analysis

Construction of Waterfront
Facilities and Other Structures on Submerge
lands 2 General

7 Air Emissions 13 Onshore Support Facilities 15 Environmental Impact Analysis Dredging and Dredged Material Disposal and
Placement 13 Onshore Support Facilities

Construction in the Beach / Dune System 13 Onshore Support Facilities

Alteration of Coastal
Historic Areas 5 Biological, Physical, and

Socioeconomic 15 Environmental Impact Analysis Transportation 13 Onshore Support Facilities

Emission of Air Pollutants 7 Air Emissions 8 Oil Spill 15 Environmental Impact Analysis Appropriations of Water There will be no
fresh water appropriations as a
result of our operations

A certificate of Coastal Zone Management C onsistency for the state of Texas is

included as Attachment 14-A.Walter Oil & Gas Corporation Section 15 – Pg. 24 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 

### SECTION 15

ENVIRONMENTAL IMPACT ANALYSIS

An Environmental Impact Analysis for Hig h island Block A-588 is included as

Attachment 15-A.Attachment 15-A

Initial Exploration Plan High Island Block A-588
OCS-G 34032

(A) IMPACT PROD UCING FACTORS

ENVIRONMENTAL IMPACT ANALYSIS WORKSHEET

Environment

Resources Impact Producing Factors (IPFs) Categories and Examples Refer to recent GOM OCS Lease Sale EIS for a more complete list of IPFs

Emissions (air, noise, light, etc.) Effluents (muds, cutting, other discharges to

the water

column or seafloor) Physical
disturbances to the

seafloor (rig or

anchor emplacements, etc.) Wastes sent
to shore for

treatment or disposal Accidents (e.g., oil spills,
chemical spills, H 2 S releases) Discarded
Trash &
Debris

Site-specific at Offshore
Location

Designated topographic features (1) (1) (1)

Pinnacle Trend area live bottoms (2) (2) (2)

Eastern Gulf live bottoms (3) (3) (3)

Benthic communities (4)

Water quality X X X

Fisheries X X X

Marine Mammals X(8) X X(8) X

Sea Turtles X(8) X X(8) X

Air quality X(9)

Shipwreck sites (known or potential) (7)

Prehistoric archaeological sites X(7)

Vicinity of Offshore Location

Essential fish habitat X X X(6)

Marine and pelagic birds X X X

Public health and safety (5)

Coastal and Onshore

Beaches X(6) X

Wetlands X(6)

Shore birds and coastal nesting

birds X(6) X

Coastal wildlife refuges X

Wilderness areas X

Footnotes for Environmental Impact Analysis Matrix1) Activities that may affect a marine sanctuary or topographic feature. Specifically, if th e well or platform site or any anchors will be on the seafloor within the:

o 4-mile zone of the Flower Garden Banks, or the 3-mile zone of Stetson Bank;

o 1000-m, 1-mile or 3-mile zone of any topographic feature (submarine bank) protected by the Topographic Features Stipulation attached to an OCS lease;

o Essential Fish Habitat (EFH) criteria of 500 ft. from any no-activity zone; or

o Proximity of any submarine bank (500 ft. buffer zone) w ith relief greater than 2 meters that is not protected by the Topographic Features Stipul ation attached to an OCS lease.

2) Activities with any bottom disturbance within an OCS lease block protected through the Live Bottom (Pinnacle Trend) Stipulation attached to an OCS lease. 3) Activities within any Eastern Gulf OCS block where seaflo or habitats are protected by the Live Bottom (LowRelief) Stipulation attached to an OCS lease. 4) Activities on blocks designated by the BOEM as being in water depths 300 meters or greater. 5) Exploration or production activities where H2S concentr ations greater than 500 ppm might be encountered. 6) All activities that could result in an accidental spill of produced liquid hydr ocarbons or diesel fuel that you determine would impact these environmental resources. If the proposed action is lo cated a sufficient distance from a resource that no impact would occur, the EIA can note that in a sentence or two. 7) All activities that involve seafloor disturbances, including anchor emplacements, in any OCS block designated by the BOEM as having high-probability for the occurrence of shipwrecks or prehistoric sites, including such blocks that will be affected that are adjacent to the leas e block in which your planned activity will occur. If the proposed activities are located a sufficient distance from a shipwreck or a prehistoric site that no impact would occur, the EIA can note that in a sentence or two. 8) All activities that you determine might have an adverse effect on endangered or threatened marine mammals or

sea turtles or their critical habitats. 9) Production activities that involve trans portation of produced fluids to shor e using shuttle tankers or barges.

### (B) ANALYSIS

Site-Specific at Hi gh Island Block A-588

Proposed operations consist of the drilling and completion of two locatio ns (Locations A & B).

Operations will be conducted with a J ack-Up rig and a Semi-Submersible rig.

1. Designated Topographic Features

Potential IPFs on topographic featur es include physical disturbances to the seafloor, effluents,

and accidents.

Physical disturbances to the seafloor: High Island Block A-588 is 6 miles from the closest designated Topographic Features Stipulation Block (Applebaum Bank); therefore, no adverse impacts are expected.

Effluents: High Island Block A-588 is 6 miles fr om the closest designated Topographic Features Stipulation Block (Appl ebaum Bank); therefore, no adve rse impacts are expected.

Accidents: It is unlikely that an accidental surf ace or subsurface spill would occur from the proposed activities (refer to statistics in Item 5 , Water Quality). Oil spills cause damage to benthic organisms only if the oil contacts the orga nisms. Oil from a surface spill can be driven into the water column; measurable amounts have been documented down to a 10 m depth. At this depth, the oil is found only at concentrations several orders of ma gnitude lower than the
amount shown to have an effect on corals. Becau se the crests of topogr aphic features in the Northern Gulf of Mexico are found below 10 m, no oil from a surface sp ill could reach their sessile biota. Oil from a subsurface spill is not app licable due to the distance of these blocks from a topographic area. The activities proposed in th is plan will be covered by Walter’s Regional OSRP (refer to information submitted in Appendix H ).

There are no other IPFs (includi ng emissions and wastes sent to shore for disposal) from the proposed activities, which could impact topographic features.

2. Pinnacle Trend Area Live Bottoms

Potential IPFs on pinnacle trend area live bottoms include physical disturba nces to the seafloor, effluents, and accidents.

Physical disturbances to the seafloor: High Island Block A-588 is 368 miles from the closest live bottom (pinnacle trend) area; therefor e, no adverse impacts are expected.Effluents: High Island Block A-588 is 368 miles from the closest live bottom (pinnacle trend) area; therefore, no adverse impacts are expected.

Accidents: It is unlikely that an accidental surf ace or subsurface spill would occur from the proposed activities (refer to statistics in Item 5 , Water Quality). Oil spill s have the potential to foul benthic communities and cause lethal and sublethal effects on live bottom organisms. Oil from a surface spill can be dr iven into the water column; measurable amounts have been documented down to a 10 m depth. At this depth, the oil is found only at concentrations several orders of magnitude lower than the amount shown to have an effect on marine organisms. Oil from a subsurface spill is not a pplicable due to the distance of these blocks from a live bottom (pinnacle trend) area. The activit ies proposed in this plan will be covered by Walter’s Regional OSRP (refer to information submitted in Appendix H ).

There are no other IPFs (includi ng emissions and wastes sent to shore for disposal) from the proposed activities which could impact a live bottom (pinnacle trend) area.

3. Eastern Gulf Live Bottoms

Potential IPFs on Eastern Gulf live bottoms in clude physical disturbances to the seafloor, effluents, and accidents.

Physical disturbances to the seafloor: High Island Block A-588 is not located in an area characterized by the existence of live bottoms, and this lease does not contain a Live-Bottom Stipulation requiring a photo documen tation survey and survey report.

Effluents: High Island Block A-588 is not located in an area characterized by the existence of live bottoms; therefore, no a dverse impacts are expected.

Accidents: It is unlikely that an accidental surf ace or subsurface spill would occur from the proposed activities (refer to statistics in Item 5 , Water Quality). Oil spills cause damage to live bottom organisms only if the oil contacts the organi sms. Oil from a surface spill can be driven into the water column; measurable amounts have been documented down to a 10 m depth. At this depth, the oil is found only at concentrations several orders of ma gnitude lower than the
amount shown to have an effect on marine inve rtebrates. Oil from a subsurface spill is not applicable due to the distance of these blocks from a live bottom area. The activities proposed in this plan will be covered by Walter’s Regional OSRP (refer to information submitted in Appendix H ).

There are no other IPFs (includi ng emissions and wastes sent to shore for disposal) from the proposed activities which could impact an Eastern Gulf live bottom area.4. Benthic Communities
There are no IPFs (including emissions, physical di sturbances to the seaf loor, wastes sent to shore for disposal, or a ccidents) from the proposed activities that could cause impacts to benthic

communities.

Operations proposed in this plan are in wa ter depths of 492 feet. High-density benthic communities are found only in water depths great er than 984 feet (300 meters); therefore, Walter’s proposed operations in High Island Bl ock A-588 would not cause impacts to benthic

communities.

5. Water Quality

IPFs that could result in water quality degrad ation from the proposed operations in High Island
Block A-588 include disturbances to th e seafloor, effluents and accidents.

Physical disturbances to the seafloor: Bottom area disturban ces resulting from the emplacement of drill rigs, the drilling of wells and the installation of platforms and pipelines would increase water-column turbidity and re-sus pension of any accumulated pollutants, such as
trace metals and excess nutrients. This woul d cause short-lived impacts on water quality
conditions in the immediate vicin ity of the emplacement operations.

Effluents: Levels of contaminants in drilling muds and cuttings and produced water discharges, discharge-rate restrictions a nd monitoring and toxicity testin g are regulated by the EPA NPDES permit, thereby eliminating many significant bi ological or ecological effects. Operational discharges are not expected to cause si gnificant adverse impacts to water quality.

Accidents: Oil spills have the potential to alter o ffshore water quality; how ever, it is unlikely

that an accidental surface or s ubsurface spill would occur from th e proposed activities. Between 1980 and 2000, OCS operations produced 4.7 billion barrels of oil and spilled only 0.001 percent of this oil, or 1 bbl for every 81,000 bbl produced. The spill risk related to a diesel spill from drilling operations is even less. Between 1976 and 1985, (years for which da ta were collected), there were 80 reported diesel spil ls greater than one barrel associ ated with drilling activities. Considering that there were 11,944 wells drille d, this is a 0.7 percen t probability of an occurrence. If a spill were to occur, the water quality of marine waters would be temporarily affected by the dissolved components and small oil droplets. Dispersion by currents and microbial degradation would remove the oil from the water column and dilute the constituents to background levels. Historically, changes in offshore water quality from oil spills have only been detected during the life of the spill and up to seve ral months afterwards. Most of the components
of oil are insoluble in water and therefore floa t. The activities proposed in this plan will be covered by Walter’s Regional Oil Spill Response Plan (refer to information submitted in Appendix H ).There are no other IPFs (includi ng emissions, physical disturbances to the seafloor, and wastes sent to shore for disposal) from the proposed activities which could cause impacts to water quality.

6. Fisheries

IPFs that could cause impacts to fisheries as a result of the proposed op erations in High Island Block A-588 include physical disturbances to the seafloor, efflue nts and accidents.

Physical disturbances to the seafloor: The emplacement of a structur e or drilling rig results in minimal loss of bottom trawling area to commercial fishermen. Pipelines cause gear conflicts which result in losses of trawls and shrimp catch, business downtime and vessel damage. Most financial losses from gear c onflicts are covered by the Fishermen’s Contingency Fund (FCF). The emplacement and removal of faci lities are not expect ed to cause significant adverse impacts

to fisheries.

Effluents: Effluents such as drilling fluids and cuttings discharges contain components and properties which are detrimental to fishery resources. Moderate petroleum and metal

contamination of sediments and the water column can occur out to several hundred meters downcurrent from the discharge point. Offshore discharges are expected to disperse and dilute to very near background levels in the water column or on the seafloor within 3,000 m of the discharge point, and are expected to have negligible effect on fisheries.

Accidents: An accidental oil spill has the potent ial to cause some detrimental effects on fisheries; however, it is unlikely that such an event would occur from the proposed activities (refer to Item 5 , Water Quality). The effects of oil on mobile adult finfish or shellfish would likely be sublethal and the extent of damage woul d be reduced to the cap acity of adult fish and shellfish to avoid the spill, to metabolize hydr ocarbons, and to excrete both metabolites and parent compounds. The activities proposed in this plan will be cove red by Walter’s Regional OSRP (refer to information submitted in Appendix H ).

There are no IPFs from emissions, or wastes sent to shore for disposal from the proposed activities which could cause impacts to fisheries.

7. Marine Mammals

GulfCet II studies revealed that cetaceans of the continental shelf and shelf-edge were almost exclusively bottlenose dolphin a nd Atlantic spotted dolphin. S quid eaters, including dwarf and pygmy killer whale, Risso’s dolphin, rough-toothed dolphin, a nd Cuvier’s beaked whale, occurred most frequently along the upper slope in areas outside of anticyclones. IPFs that could cause impacts to marine mammals as a result ofthe proposed operations in High Island Block A588 include emissions, effluents, discarde d trash and debris, and accidents.Emissions: Noises from drilling activities, support vessels and helicopters may elicit a startle

reaction from marine mammals. This reaction may lead to disruption of marine mammals’ normal activities. Stress may make them more vul nerable to parasites, disease, environmental contaminants, and/or predation (Majors and Myri ck, 1990). There is little conclusive evidence for long-term displacements and population trends for marine mammals relative to noise.

Effluents: Drilling fluids and cutti ngs discharges contain components which may be detrimental to marine mammals. Most operational discharges are diluted and dispersed upon release. Any potential impact from drilling flui ds would be indirect, either as a result of impacts on prey items or possibly through ingestion in the food chain (API, 1989).

Discarded trash and debris: Both entanglement in, and inge stion of debris have caused the death or serious injury of marine mammals (Laist, 1997; MMC, 1999). The limited amount of marine debris, if any, resulting from the proposed act ivities is not expected to substantially harm marine mammals. Operators are prohibited from deliberately discharging debris as mandated by
MARPOL-Annex V and the Marine Plastic Polluti on Research and Control Act, and regulations imposed by various agencies including the United States Coast Guard (USCG) and the Environmental Protection Agency (EPA).

Walter will operate in accordance with the regu lations and also avoid accidental loss of solid waste items by maintaining waste management plans, manifesting trash sent to shore, and using special precautions such as coveri ng outside trash bins to prevent accidental loss of solid waste. Special caution will be exercised when handlin g and disposing of small items and packaging materials, particularly those made of non-biode gradable, environmentally persistent materials such as plastic or glass.

Informational placards will be posted on all vessels and facilities having sleeping or food preparation capabilities. All offshore personne l, including contract ors and other support services-related personnel (e.g. helicopter pilots, vessel capt ains and boat crews) will be indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint presentation), “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris training video annually. Offshore personnel will also receive an explanation from Walter management or the designated lease operator management that emphasizes their commitment to waste management in accordance
with NTL No. 2012-G01.

Accidents: Collisions between support vessels and cetaceans would be unusual events, however should one occur, death or injury to marine mammals is possible. Contract vessel operators can avoid marine mammals and reduce potential deaths by maintaining a vigilant watch for marine mammals and maintaining a safe distance when they are sighted. Vessel crews should use a reference guide to help identify the twenty-eight species of whales and dolphins, and the single species of manatee that may be encountered in the Gulf of Mexico OCS. Vessel crews must report sightings of any injured or dead protected marine mamma l species immediately,regardless of whether the injury or death is cau sed by their vessel, to the Marine Mammal and Sea Turtle Stranding Hotline at (888) 404-3922, the NMFS Southeast Regional Office at (727) 824-5312, or the Marine Mammal Stranding Networ k at (305) 862-2850. In addition, if the injury or death was caused by a collision with a contract vessel, the BOEM must be notified within 24 hours of the strike by email to protectedspecies@boemre.gov . If the vessel is the responsible party, it is required to remain available to assist the respective salvage and stranding
network as needed.

Oil spills have the potential to cause sublethal oil-related injuries and spill-related deaths to marine mammals. However, it is unlikely that an accidental oil spill would occur from the proposed activities (refer to Item 5 , Water Quality). Oil spill response activities may increase vessel traffic in the area, which could add to changes in cetacean behavior and/or distribution, thereby causing additional stress to the animals. The effect of oil dispersants on cetaceans is not known. The acute toxicity of oil dispersant chem icals included in Walter’s OSRP is considered to be low when compared with the constituents and fractions of crude o ils and diesel products. The activities proposed in this plan will be covered by Walter’s OSRP (refer to information
submitted in accordance with Appendix H ).

There are no other IPFs (including physical di sturbances to the seafloor) from the proposed activities which could impact marine mammals.

8. Sea Turtles

IPFs that could cause impacts to sea turtles as a result of the proposed operations include emissions, effluents, discarded tr ash and debris, and accidents. GulfCet II studies sighted most loggerhead, Kemp’s ridley and le atherback sea turtles over shel f waters. Historically these species have been sighted up to the shelf’s edge. They appear to be more abundant east of the Mississippi River than they are west of the river (Fritts et al., 1983b; Lohoefener et al., 1990). Deep waters may be used by all sp ecies as a transitory habitat.

Emissions: Noise from drilling activi ties, support vessels, and heli copters may elicit a startle reaction from sea turtles, but th is is a temporary disturbance.

Effluents: Drilling fluids and cuttings discharges are not k nown to be lethal to sea turtles. Most operational discharges are dilu ted and dispersed upon release. Any potential impact from drilling fluids would be indirect , either as a result of impacts on prey items or possibly through ingestion in the food chain (API, 1989).

Discarded trash and debris: Both entanglement in, and inges tion of, debris have caused the death or serious injury of sea tu rtles (Balazs, 1985). The limited am ount of marine debris, if any, resulting from the proposed activitie s is not expected to substantially harm sea turtles. Operators are prohibited from deliberately discharging de bris as mandated by MARPOL-Annex V and the
Marine Plastic Pollution Research and Control Ac t, and regulations imposed by various agenciesincluding the United States Coast Guard (USC G) and the Environmental Protection Agency (EPA). Walter will operate in accordance with th e regulations and also a void accidental loss of solid waste items by maintaining waste management plans, manifesting trash sent to shore, and using special precautions such as covering outsid e trash bins to prevent accidental loss of solid waste. Special caution will be exercised when handling and disposing of small items and packaging materials, particularly those made of non-biodegradable, environmentally persistent materials such as plastic or glass.

Informational placards will be posted on all vessels and facilities having sleeping or food preparation capabilities. All offshore personne l, including contract ors and other support services-related personnel (e.g. helicopter pilots, vessel capt ains and boat crews) will be indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint presentation), “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris training video annually. Offshore personnel will also receive an explanation from Walter management or the designated lease operator management that emphasizes their commi tment to waste management in accordance
with NTL No. 2012-G01.

Accidents: Collisions between support vessels and s ea turtles would be unusual events, however should one occur, death or injury to sea turtles is possible. Cont ract vessel operators can avoid sea turtles and reduce potential deaths by main taining a vigilant watch for sea turtles and maintaining a safe distance when they are sighte d. Vessel crews should use a reference guide to help identify the five species of sea turtles that may be encountered in the Gulf of Mexico OCS. Vessel crews must report sightings of any inju red or dead protecte d sea turtle species immediately, regardless of whethe r the injury or death is caused by their vessel, to the Marine Mammal and Sea Turtle Stranding Hotline at (888) 404-3922, the NMFS Southeast Regional Office at (727) 824-5312, or th e Marine Mammal Stranding Ne twork at (305) 862-2850. In addition, if the injury or death was caused by a collision with a contract vessel, the BOEM must
be notified within 24 hours of the strike by email to protectedspecies@boemre.gov . If the vessel is the responsible party, it is required to remain available to assist the respective salvage and stranding network as needed.

All sea turtle species and their life stages are vulnerab le to the harmful e ffects of oil through direct contact or by fouling of their food. Exposure to oil can be fa tal, particularly to juveniles and hatchlings. However, it is un likely that an accidental oil sp ill would occur from the proposed activities (refer to Item 5 , Water Quality). Oil sp ill response activities ma y increase vessel traffic in the area, which could add to the possibility of collisions with sea turtles. The activities proposed in this plan will be covered by Walter’s Regional Oil Spill Response Plan (refer to
information submitted in accordance with Appendix H ).

There are no other IPFs (including physical di sturbances to the seafloor) from the proposed activities which could impact sea turtles.9. Air Quality

The projected air emissions identified in Appendix G are not expected to affect the OCS air quality primarily due to distance to the shore or to any Prevention of Significant Deterioration Class I air quality area such as the Breton W ilderness Area. High Island Block A-588 is beyond the 200 kilometer (124 mile) buffer for the Bret on Wilderness Area and is 90.93 miles from the coastline. Therefore, no special mitigation, monitoring, or reporting requirements apply with respect to air emissions.

Accidents and blowouts can rel ease hydrocarbons or chemicals, which could cause the emission of air pollutants. However, these releases w ould not impact onshore air quality because of the prevailing atmospheric conditions , emission height, emission rate s, and the distance of High
Island Block A-588 from the coastline. There ar e no other IPFs (inclu ding effluents, physical disturbances to the seafloor, wa stes sent to shore for treatment or disposal) from the proposed activities which could impact air quality.

10. Shipwreck Sites (known or potential)

IPFs that could impact known or unknown shipwreck sites as a result of the proposed operations in High Island Block A-588 include disturbances to the seafloor and accidents (oil spill). High
Island Block A-588 is not located in or adjacent to an OCS block designated by BOEM as having a high probability for occurrence of sh ipwrecks. Walter will report to BOEM the discovery of any evidence of a shipwreck and make every reasonable effort to preserve and protect that cultural resource. There are no other I PFs (including emissions, effluents, wastes sent to shore for treatment or dispos al, or accidents) from the proposed activities which could impact shipwreck sites.

Accidents: An accidental oil spill has the potentia l to cause some detrimental effects to shipwreck sites if the re lease were to occur subsea. However, it is unlikely that an accidental oil spill would occur from the proposed activities (refer to Item 5 , Water Quality). The activities proposed in this plan will be covered by Walter’s Regional Oil Spill Response Plan (refer to
information submitted in accordance with Appendix H ).

There are no other IPFs (including emissions, efflue nts, or wastes sent to shore for treatment or disposal) from the proposed act ivities that could cause impacts to shipwreck sites.

11. Prehistoric Archaeological Sites
IPFs that could cause impacts to prehistoric archaeological site s as a result of the proposed operations in High Island Block A- 588 are physical disturbances to the seafloor and accidents (oil spills).

Physical Disturbances to the seafloor: High Island Block A-588 is located inside the Archaeological Prehistoric high probability lines. Walter will report to BOEM the discovery ofany object of prehistoric archaeological signi ficance and make every reasonable effort to preserve and protect that cultural resource.

Accidents: An accidental oil spill has the potentia l to cause some detrimental effects to prehistoric archaeological sites if the release were to occur subsea. However, it is unlikely that an accidental oil spill would occur from the proposed activities (refer to Item 5 , Water Quality). The activities proposed in this plan will be covered by Walter’s Regi onal Oil Spill Response Plan (refer to information submitted in accordance with Appendix H ).

There are no other IPFs (includi ng emissions, effluents, wastes sent to shore for treatment or disposal) from the proposed activi ties that could cause impacts to prehistoric archaeological

sites.

Vicinity of Offshore Location

1. Essential Fish Habitat (EFH)

IPFs that could cause impacts to EFH as a result of the proposed operations in High Island Block A-588 include physical disturbances to the seaf loor, effluents and accidents. EFH includes all
estuarine and marine waters and subs trates in the Gulf of Mexico.

Physical disturbances to the seafloor: The Live Bottom Low Re lief Stipulation, the Live Bottom (Pinnacle Trend) Stipulation, and the Ea stern Gulf Pinnacle Trend Stipulation would prevent most of the potential impacts on live-bottom communities and EFH from bottom disturbing activities (e.g., anchoring, structure emplacement and removal).

Effluents: The Live Bottom Low Relief Stipulati on, the Live Bottom (Pinnacle Trend) Stipulation, and the Eastern Gulf Pinnacle Trend Stipulation would prevent most of the potential impacts on live-bottom communities and EFH from operational waste discharges. Levels of contaminants in drilling muds and cuttings a nd produced-water discha rges, discharge-rate restrictions, and monitoring a nd toxicity testing are regulated by the EPA NPDES permit, thereby eliminating many significa nt biological or ecol ogical effects. Operat ional discharges are not expected to cause significant adverse impacts to EFH.

Accidents: An accidental oil spill has the potential to cause some detrimental effects on EFH. Oil spills that contact coastal bays and estuaries, as well as OCS waters when pelagic eggs and larvae are present, have the greatest potential to a ffect fisheries. However, it is unlikely that an oil spill would occur from the proposed activities (refer to Item 5 , Water Quality). The activities proposed in this plan will be covered by Walte r’s Regional OSRP (refer to information submitted

in Appendix H ).

There are no other IPFs (includi ng emissions, or wastes sent to shore for treatment or disposal) from the proposed activities which coul d impact essential fish habitat.2. Marine and Pelagic Birds

IPFs that could impact marine birds as a result of the proposed activities include air emissions, accidental oil spills, and discarded trash a nd debris from vessel s and the facilities.

Emissions: Emissions of pollutants into the atmo sphere from these activities are far below
concentrations which could harm coastal and marine birds.

Accidents: An oil spill woul d cause localized, low-level petroleum hydrocarbon contamination. However, it is unlikely that an oil spill woul d occur from the proposed activities (refer to Item 5

, Water Quality). Marine and pelagic birds feedi ng at the spill location may experience chronic, nonfatal, physiological stress. It is expected th at few, if any, coastal and marine birds would actually be affected to that extent. The activ ities proposed in this plan will be covered by Walter’s Regional OSRP (refer to information submitted in Appendix H ).

Discarded trash and debris : Marine and pelagic birds could become entangled and snared in discarded trash and debris, or in gest small plastic debris, which can cause permanent injuries and death. Operators are prohibited from deliberat ely discharging debris as mandated by MARPOLAnnex V and the Marine Plastic Pollution Resear ch and Control Act, and regulations imposed by various agencies including the United States Coast Guard (USCG) and the Environmental Protection Agency (EPA). Walter will operate in accordance with the regulations and also avoid accidental loss of solid waste items by maintaini ng waste management plans, manifesting trash sent to shore, and using special precautions such as covering outside trash bins to prevent accidental loss of solid waste. Special caution w ill be exercised when handling and disposing of small items and packaging materials, par ticularly those made of non-biodegradable, environmentally persistent materials such as plastic or glass. Informational placards will be posted on all vessels and facilities having sleeping or food preparation capabilities. All offshore personnel, including contractors and other suppor t services-related pers onnel (e.g. helicopter pilots, vessel captains and boat cr ews) will be indoctrinated on wa ste procedures, and will view the video (or Microsoft PowerPoint presentation), “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris training video annually. Offshore personnel will also receive an explanation from Walter management or the designated lease operator ma nagement that emphasizes their commitment to waste management in accordance with NTL No . 2012-G01. Debris, if any, from these proposed
activities will seldom interact with marine and pelagic birds; therefore, the effects will be negligible.

There are no other IPFs (including effluents, physical disturbances to the seafloor, or wastes sent to shore for treatment or disposal) from the pr oposed activities which could impact marine and pelagic birds.3. Public Health and Safety Due to Accidents.

There are no IPFs (emissions, effluents, physical disturbances to the seafloor, wastes sent to shore for treatment or disposal or accidents, including an accidental H2S releases) from the proposed activities which could cau se impacts to public health a nd safety. In accordance with NTL No.’s 2008-G04, 2009-G27, and 2009-G31, suffi cient information is included in Appendix

D to justify our request that our proposed activities be classified by BSEE as H 2 S absent.

Coastal and Onshore

1. Beaches

IPFs from the proposed activities that could cause impacts to beaches include accidents (oil spills) and discarded trash and debris.

Accidents: Oil spills contacting beaches would have impacts on the use of recreational beaches

and associated resources. Due to the distan ce from shore (90.93 miles) and the response capabilities that would be implemented, no si gnificant adverse impacts are expected. The activities proposed in th is plan will be covered by Walter’s Regional OSRP (refer to information

submitted in Appendix H ).

Discarded trash and debris: Trash on the beach is recogni zed as a major threat to the enjoyment and use of beaches. There will only be a limited amount of marine debris, if any, resulting from the proposed activ ities. Operators are prohibite d from deliberately discharging debris as mandated by MARPOL-Annex V and th e Marine Plastic Pollution Research and Control Act, and regulations imposed by variou s agencies including the United States Coast Guard (USCG) and the Environmental Protec tion Agency (EPA). Walter will operate in accordance with the regulations and also avoi d accidental loss of solid waste items by maintaining waste management plans, manifes ting trash sent to shore, and using special precautions such as covering outside trash bins to prevent accidental loss of solid waste. Special caution will be exercised when handling and dispos ing of small items and packaging materials, particularly those made of non- biodegradable, environmentally pe rsistent materials such as plastic or glass.

Informational placards will be posted on all vessels and facilities having sleeping or food preparation capabilities. All offshore personne l, including contract ors and other support services-related personnel (e.g. helicopter pilots, vessel capt ains and boat crews) will be indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint presentation), “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris training video annually. Offshore personnel will also receive an explanation from Walter management or the designated lease operator management that emphasizes their commi tment to waste management in accordance
with NTL No. 2012-G01.There are no other IPFs (emissions , effluents, physical disturbances to the seaflo or, or wastes sent to shore for treatment or disposal) from th e proposed activities which could impact beaches.

2. Wetlands

IPFs from the proposed activities that could ca use impacts to wetlands include accidents (oil spills) and discarded trash and debris.

Accidents: It is unlikely that an oil spill would occu r from the proposed activities (refer to Item
5 , Water Quality). Due to the distance from shor e (90.93 miles) and the re sponse capabilities that would be implemented, no impacts are expected. The activities proposed in this plan will be covered by Walter’s Regional OSRP (refer to information submitted in Appendix H ).

Discarded trash and debris: There will only be a limited amount of marine debris, if any, resulting from the proposed activ ities. Operators are prohibite d from deliberately discharging debris as mandated by MARPOL-Annex V and th e Marine Plastic Pollution Research and Control Act, and regulations imposed by variou s agencies including the United States Coast Guard (USCG) and the Environmental Protec tion Agency (EPA). Walter will operate in accordance with the regulations and also avoi d accidental loss of solid waste items by maintaining waste management plans, manifes ting trash sent to shore, and using special precautions such as covering outside trash bins to prevent accidental loss of solid waste. Special caution will be exercised when handling and dispos ing of small items and packaging materials, particularly those made of non- biodegradable, environmentally pe rsistent materials such as plastic or glass.

Informational placards will be posted on all vessels and facilities having sleeping or food preparation capabilities. All offshore personne l, including contract ors and other support services-related personnel (e.g. helicopter pilots, vessel capt ains and boat crews) will be indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint presentation), “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debr is training video annually. Offshore personnel will also receive an explanation from Walter management or the designated lease operator management that emphasizes their commi tment to waste management in accordance
with NTL No. 2012-G01.

There are no other IPFs (emissions , effluents, physical disturbances to the seaflo or, or wastes sent to shore for treatment or disposal) fr om the proposed activities which could impact
wetlands.

3. Shore Birds and Coastal Nesting Birds

Accidents: Oil spills could cause impacts to shore bird s and coastal nesting birds. However, it is unlikely that an oil spill would occur from the proposed activities (refer to Item 5 , Water Quality). Given the distance from shore (90.93 mile s) and the response capabilities that would beimplemented, no impacts are expected. The activ ities proposed in this plan will be covered by Walter’s Regional OSRP (refer to information submitted in Appendix H ).

Discarded trash and debris: Coastal and marine birds are highly susceptible to entanglement in floating, submerged, and beached marine debris : specifically plastics. Operators are prohibited from deliberately discharging debris as manda ted by MARPOL-Annex V and the Marine Plastic
Pollution Research and Control Ac t, and regulations imposed by va rious agencies including the United States Coast Guard (USCG) and the Envi ronmental Protection Agency (EPA). Walter will operate in accordance with the regulations a nd also avoid accidental loss of solid waste items by maintaining waste management plans, mani festing trash sent to shore, and using special precautions such as covering outside trash bins to pr event accidental loss of solid waste. Special caution will be exercised when handling and dispos ing of small items and packaging materials, particularly those made of non- biodegradable, environmentally pe rsistent materials such as plastic or glass.

Informational placards will be posted on vessels and every facility that has sleeping or food preparation capabilities. All offshore personne l, including contract ors and other support services-related personnel (e.g. helicopter pilots, vessel capt ains and boat crews) will be indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint presentation), “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris training video annually. Offshore personnel will also receive an explanation from Walter management or the designated lease operator management that emphasizes their commi tment to waste management in accordance
with NTL No. 2012-G01.

There are no other IPFs (emissions , effluents, physical disturbances to the seaflo or, or wastes sent to shore for treatment or disposal) from th e proposed activities that could cause impacts to shore birds and coastal nesting birds.

4. Coastal Wildlife Refuges

Accidents: An accidental oil spill from the proposed activities could cause impacts to coastal wildlife refuges. However, it is unlikely that an oil spill would occur from the proposed activities (refer to Item 5, Water Quality). Due to the distance from shore (90.93 miles) and the response capabilities that would be implemented, no impacts ar e expected. The activities proposed in this plan will be covered by Walter’s Regional OSRP (refer to information submitted in Appendix

H ).

Discarded trash and debris: Operators are prohibited from de liberately discharging debris as mandated by MARPOL-Annex V, the Marine Plas tic Pollution Research and Control Act and regulations imposed by various ag encies including the United St ates Coast Guard (USCG) and the Environmental Protection Agency (EPA). Walter will operate in accordance with the regulations and also avoid accide ntal loss of solid waste items by maintaining waste management plans, manifesting trash sent to shore, and us ing special precautions such as covering outside trash bins to prevent accidental loss of solid waste. Special caution will be exercised whenhandling and disposing of small items and packagi ng materials, particularly those made of nonbiodegradable, environmentally persistent materials such as plastic or glass.

Informational placards will be posted on vessels and every facility that has sleeping or food preparation capabilities. All offshore personne l, including contract ors and other support services-related personnel (e.g. helicopter pilots, vessel capt ains and boat crews) will be indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint presentation), “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris training video annually. Offshore personnel will also receive an explanation from Walter management or the designated lease operator management that emphasizes their commi tment to waste management in accordance
with NTL No. 2012-G01.

There are no other IPFs (emissions , effluents, physical disturbances to the seaflo or, or wastes sent to shore for treatment or disposal) from th e proposed activities that could cause impacts to coastal wildlife refuges.

5. Wilderness Areas

Accidents: An accidental oil spill from the proposed activities could cause impacts to wilderness areas. However, it is unlikely that an oil spill would occur from the proposed activities (refer to
Item 5 , Water Quality). Due to the distance from the nearest designated Wilderness Area (330 miles) and the response capabilities that would be implemented, no significant adverse impacts are expected. The activities proposed in this plan will be covered by Walter’s Regional OSRP (refer to information submitted in Appendix H).

Discarded trash and debris: Operators are prohibited from de liberately discharging debris as mandated by MARPOL-Annex V, the Marine Plas tic Pollution Research and Control Act and regulations imposed by various ag encies including the United St ates Coast Guard (USCG) and the Environmental Protection Agency (EPA). Walter will operate in accordance with the regulations and also avoid accide ntal loss of solid waste items by maintaining waste management plans, manifesting trash sent to shore, and us ing special precautions such as covering outside trash bins to prevent accidental loss of solid waste. Special caution will be exercised when handling and disposing of small items and packagi ng materials, particularly those made of nonbiodegradable, environmentally persistent materials such as plastic or glass.

Informational placards will be posted on vessels and every facility that has sleeping or food preparation capabilities. All offshore personne l, including contract ors and other support services-related personnel (e.g. helicopter pilots, vessel capt ains and boat crews) will be indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint presentation), “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris training video annually. Offshore personnel will also receive an explanation from Walter management or the designated lease operator management that emphasizes their commi tment to waste management in accordance
with NTL No. 2012-G01.There are no other IPFs (emissions , effluents, physical disturbances to the seaflo or, or wastes sent to shore for treatment or disposal) from th e proposed activities that could cause impacts to
wilderness areas.

6. Other Environmental Resources Identified

There are no other environmental resources identified for this impact assessment.

(C) IMPACTS ON PROPOSED ACTIVITIES

The site–specific environmental conditions have been taken into account for the proposed activities. No impacts are expected on the propos ed activities from site-specific environmental

conditions.

(D) ENVIRONMENTAL HAZARDS
During the hurricane season, June through November , the Gulf of Mexico is impacted by an average of ten tropical storms (39-73 mph winds), of which si x become hurricanes ( > 74 mph winds). Due to its location in the gulf, Hi gh Island Block A-588 may experience hurricane and tropical storm force winds, and related sea curr ents. These factors can adversely impact the integrity of the operations covered by this pla n. A significant storm may present physical hazards to operators and vessels, damage exploration or pr oduction equipment, or result in the release of hazardous materials (including hydrocarbons). Add itionally, the displacement of equipment may disrupt the local benthic habitat a nd pose a threat to local species.

The following preventative measures included in this plan may be implemented to mitigate these impacts:

1. Drilling & completion

a. Secure well

b. Secure rig / platform

c. Evacuate personnel

Drilling activities will be conducted in accordance with NTL No.’s 2008-G09, 2009-G10, and

2010-N10 .

2. Structure Installation Operator will not conduct structure instal lation operations duri ng Tropical Storm or

Hurricane threat.

(E) ALTERNATIVES

No alternatives to the proposed activities were cons idered to reduce environmental impacts.(F) MITIGATION MEASURES

No mitigation measures other than those requ ired by regulation will be employed to avoid, diminish, or eliminate potential im pacts on environmental resources.

(G) CONSULTATION

No agencies or persons were consulted regard ing potential impacts associ ated with the proposed activities. Therefore, a list of such entities has not been provided.

(H) PREPARER(S)

Matt Harlan J. Connor Consulting, Inc. 16225 Park Ten Place, Suite 700 Houston, TX 77084 (281) 578-3388 matt.harlan@jccteam.com

(I) REFERENCES

Authors:

American Petroleum Institute (API). 1989. Eff ects of offshore petroleum operations on cold
water marine mammals: a literature revi ew. Washington, DC: American Petroleum Institute. 385 pp.

Balazs, G.H. 1985. Impact of ocean debris on mari ne turtles: entanglement and ingestion. In: Shomura, R.S. and H.O. Yoshida, eds. Proceedings, Workshop on the Fate and Impact of Marine Debris, 26-29 November 1984, Honolu lu, HI. U.S. Dept. of Commerce. NOAA Tech. Memo. NOAA-TM-NMFS-SWFC-54. Pp 387-429.

Burke, C.J. and J.A. Veil. 1995. Potential benef its from regulatory cons ideration of synthetic drilling muds. Environmental Assessmen t Division, Argonne Na tional Laboratory,

ANL/EAD/TM-43.

Daly, J.M. 1997. Controlling the discharge of synthetic-based drilling fluid contaminated cuttings in waters of the United States. U. S. Environmental Protection Agency, Office of Water. Work Plan, June 24, 1997.

Hansen, D.J. 198l. The relative sens itivity of seabird populations in Al aska to oil pollution. U.S. Dept. of the Interior, Bureau of Land Mana gement, Alaska OCS Region, Anchorage. BLMYK-ES-81-006-1792.

Laist, D.W. 1997. Impacts of marine debris: en tanglement of marine life in marine debris including a comprehensive list of species with entanglement and ingestion records. In: Coe,J.M. and D.B. Rogers, eds. Marine debris: s ources, impacts, and solutions. New York, NY: Springer-Verlag. Pp. 99-139.

Majors, A.P. and A.C. Myrick, Jr. 1990. Effects of noise on animals: implications for dolphins exposed to seal bombs in the eastern tropi cal Pacific purse-sein e fishery–an annotated bibliography. NOAA Admini strative Report LJ-90-06.

Marine Mammal Commission. 1999. A nnual report to Congress – 1998.

Piatt, J.F., C.J. Lensink, W. Butler, M. Ke ndziorek, and D.R. Nysewander. 1990. Immediate impact of the Exxon Valdez oil spill on marine birds. The Auk. 107 (2): 387-397.

Vauk , G., E. Hartwig, B. Reineking, and E. Vauk-Hentzelt. 1989. Losses of seabirds by oil pollution at the German North Sea coast. Topi cs in Marine Biology. Ro s, J.D, ed. Scient. Mar. 53 (2-3): 749-754.

Vermeer, K. and R. Vermeer, 1975 Oil threat to birds on the Canadian west coast. The Canadian
Field-Naturalist. 89:278-298.

Although not cited, the following were utilized in prepar ing this EIA:

• Hazard Surveys

• BOEM EIS’s:

o GOM Deepwater Operations and Activities. Environmental Assessment. MMS 2000-001

o GOM Central and Western Planning Areas Sales 166 and 168 Final Environmental Impact Statement. MMS 96-0058.Walter Oil & Gas Corporation Section 16 – Pg. 25 of 25 Initial Exploration Plan August, 2013 High Island Block A-588, OCS-G 34032 

### SECTION 16

ADMINISTRATIVE INFORMATION

16.1 EXEMPTED INFORMATION DESCRIPTION The proposed bottom-hole locations of the planned wells have been removed from the Public Information copy of the EP as well as any discussions of the target objectives, geologic or geophysical data, and any interpreted geology.

16.2 BIBLIOGRAPHY

1. Marine Surveys, L. L. C. Archaeolog ical and Hazard Survey Block A-588 High
Island Area.