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-09616

Type - Initial Exploration Plan

Lease(s) - OCS-G25780 Block - 93 Keathley Canyon Area

Operator - BP Exploration & Production Inc.

Drill & TA Wells A & B

DP SEMISUBMERSIBLE

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.

James Webb

Plan Coordinator

Description -

Rig Type -

Subject:

From:

March 12, 2012
________________________________________________________________________

 

 

 

 

2 29-Feb-2012 Issued for BOEM Submittal Mandy Phthian James Grant

1 23-Feb-2012 Issued for BOEM Submittal Mandy Phythian James Grant

0 15-Dec-2011 Issued for BOEM Submittal Mandy Phythian James Grant 

Rev Date Document Status Custodian/Owner Authority 

Document Organization 

ID Sector ID Discipline ID Document Class 

Sequence 

Number 

Document 

Revision 

Control 

Number 2700 T2 RG PN 0001 0 

Gulf of Mexico Exploration and 

Production 

Initial Exploration Plan 

Keathley Canyon Block 93 

OCS-G 25780 

(Gila) 

PROPRIETARY INFORMATION COPY 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 2 of 38 

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AMENDMENT RECORD 

Amendment 

Date 

Revision 

Number 

Amender 

Initials Amendment 

29-Feb-2012 5 MP 

Revised Tentative Schedule on Plan 

Information Form (Appendix A) to reflect 

updated start date, as requested by James 

Webb, BOEM, via email dated 02/29/2012. 

23-Feb-2012 4 MP 

Removed proprietary maps from Public Copy 

of site clearance letters (Appendix C of 

Public Information copy) 

8-Feb-2012 3 MP 

On 02/07/2012 received email request from 

James Webb, BOEM, for seafloor amplitude 

maps showing Well Locations A and B with 

2000-ft radius surrounding each well 

Responded via email on 02/08/2012 

providing requested seafloor amplitude maps 

(Appendix C) 

26-Jan-2012 2 MP 

On 01/19/2012 received email request from 

James Webb, BOEM, for additional structure 

maps for WCD analysis (Appendix E) 

Responded via email on 01/26/2012 

providing requested structure maps and 

location of additional information regarding 

oil spill surface containment timing 

(Appendix G, Pages 11-18) 

13-Jan-2012 1 MP 

On 01/11/2012 received email request from 

James Webb, BOEM, for additional 

information regarding Blowout Scenario; 

Biological, Physical, and Socioeconomic 

Information; Oil Spill surface containment 

timing; and Wastes Transported and/or 

Disposed Onshore 

Responded via email on 01/13/2012 

providing location of requested items in EP, 

including Blowout Scenario (Section 2.7); 

Biological, Physical, and Socioeconomic 

Information (Section 5 and Appendix C); Oil 

Spill surface containment timing (Section 

2.7); and Wastes Transported and/or 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 3 of 38 

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Disposed Onshore (Section 6.2, Page 18) 

15-Dec-2011 0 MP Submitted to BOEM 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 4 of 38 

Warning:. Check DW Docs revision to ensure you are using the correct revision. 

TABLE OF CONTENTS 

1 Plan Contents .............................................................................................. 7

1.1 Description of Activities...........................................................................7

1.2 Location ...................................................................................................7

1.3 Safety and Pollution Prevention Features ................................................7

1.4 Storage Tanks and Production Vessels....................................................7

1.4.1 Storage Tanks West Sirius...............................................................7

1.4.2 Storage Tanks Support Vessels .......................................................8

1.5 Additional Measures ................................................................................8

2 General Information.................................................................................... 9

2.1 Applications and Permits .........................................................................9

2.2 Drilling Fluids ...........................................................................................9

2.3 New or Unusual Technologies .................................................................9

2.4 Bonding Information ................................................................................9

2.5 Oil Spill Financial Responsibility (OSFR)...................................................9

2.6 Deepwater Well Control Statement.......................................................10

2.7 Blowout Scenario...................................................................................10

2.7.1 Blowout Scenario...........................................................................10

2.7.2 The Potential for the Well to Bridge Over......................................10

2.7.3 The Likelihood for Surface Intervention to Stop the Blowout ........10

2.7.4 The Availability and Timing of a Rig to Drill a Relief Well ...............10

2.7.5 Measures that would Enhance the Ability to Prevent a Blowout...11

2.7.6 Measures that would Reduce the Likelihood of a Blowout ...........12

2.7.7 Measures that would Enhance the Ability to Conduct Early 

Intervention....................................................................................12

2.7.8 Other Measures.............................................................................12

3 Geological and Geophysical Information................................................ 12

3.1 Geological Description ...........................................................................12

3.2 Structure Contour Maps ........................................................................13

3.3 Interpreted 2-D and/or 3D Seismic Lines...............................................13

3.4 Geological Structure Cross-Section Maps..............................................13

3.5 Shallow Hazards Report.........................................................................13

3.6 Shallow Hazards Assessment (Site Clearance Letter) ...........................13

3.7 High Resolution Seismic Lines ..............................................................13

3.8 Stratigraphic Column..............................................................................13

3.9 Time vs. Depth Table.............................................................................13

4 Hydrogen Sulfide (H2S) Information........................................................ 14

4.1 Concentration ........................................................................................14
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 5 of 38 

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4.2 Classification..........................................................................................14

4.3 H2S Contingency Plan ............................................................................14

4.4 Modeling Report ....................................................................................14

5 Biological and Physical Information ........................................................ 14

5.1 Benthic Communities Report.................................................................14

5.2 Topographic Features Map ....................................................................14

5.3 Topographic Features Statement (shunting) ..........................................15

5.4 Live Bottoms (Pinnacle Trend) Map.......................................................15

5.5 Live bottoms (Low Relief) Map..............................................................15

5.6 Potentially Sensitive Biological Features................................................15

5.7 Remotely Operated Vehicle (ROV) Monitoring Survey Plan...................16

5.8 Threatened or Endangered Species, Critical Habitat and Marine Mammal 

Information ............................................................................................16

5.9 Archaeological Report............................................................................17

6 Waste and Discharge Information........................................................... 18

6.1 Waste Generated, Treated, Downhole Disposed or Discharged into the 

GoM.......................................................................................................18

6.2 Wastes Transported and/or Disposed Onshore .....................................19

7 Air Emissions Information........................................................................ 20

7.1 Screening Questions..............................................................................20

7.2 Emissions Worksheet............................................................................20

7.3 Emission Reductions Measures ............................................................20

7.4 Verification of Non-Default Emission Factors.........................................20

8 Oil Spill Information.................................................................................. 21

8.1 Oil Spill Response Planning ...................................................................21

8.1.1 Regional Oil Spill Response Plan (OSRP) Information....................21

8.1.2 Spill Response Sites ......................................................................21

8.1.3 OSRO Information .........................................................................22

8.1.4 Worst-case Scenario Determination ..............................................22

8.2 Oil Spill Response Discussion................................................................23

9 Environmental Monitoring and Mitigation Measures ........................... 23

9.1 Monitoring Systems...............................................................................23

9.2 Incidental Takes .....................................................................................23

9.3 Flower Garden Banks National Marine Sanctuary..................................23

10 Lease Stipulation Information ................................................................. 23

11 Related Facilities and Operations Information....................................... 24

11.1 Produced Liquid Hydrocarbons Transportation Vessels.........................24

12 Support Vessels and Aircraft Information .............................................. 24

12.1 General ..................................................................................................24
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 6 of 38 

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12.2 Diesel Oil Supply Vessels ......................................................................24

12.3 Vicinity Map ...........................................................................................24

13 Onshore Support Facilities Information.................................................. 25

13.1 General ..................................................................................................25

13.2 Support Base Construction or Expansion...............................................25

14 Coastal Zone Management Act (CZMA) Information ............................ 25

15 Environmental Impact Analysis (EIA)...................................................... 25

16 Administrative Information...................................................................... 26

16.1 Exempted Information Description ........................................................26

16.2 Bibliography ...........................................................................................26

Appendix A: Plan Information Forms – Form BOEM-0137 ......................... 27

Appendix B: Vicinity Plat and Location Plat................................................ 31

Appendix C: Geological Description, Structure Contour Maps, Interpreted 

Seismic Lines, Geological Structure Cross-Section Maps, 

Shallow Hazards Assessment (Site Clearance Letters), 

Stratigraphic Column, Seafloor Amplitude Maps ................. 32

Appendix D: Air Quality Report .................................................................... 33

Appendix E: WCD Assumptions for KC93 and WR282 (Exploration Well 

Scenario in Revised OSRP)...................................................... 34

Appendix F: Environmental Impact Analysis (EIA)..................................... 35

Appendix G: Oil Spill Response Discussion................................................. 36

Appendix H: Coastal Zone Management Act (CZMA) Consistency 

Certification .............................................................................. 37

Appendix I: Fee Recovery ............................................................................ 38
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 7 of 38 

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1 Plan Contents 

1.1 Description of Activities 

Under this Exploration Plan, BP Exploration & Production Inc. (BP) proposes to drill and temporarily 

abandon two (2) exploratory wells in Keathley Canyon Block 93, Gulf of Mexico (GoM), OCS-G 25780. 

The wells will be temporarily abandoned and a TA cap will be installed on the wellheads. 

Plan Information Forms (Form BOEM-0137) are included in Appendix A. 

1.2 Location 

A map at a scale of 1-in = 2,000-feet on an 8.5-in X 11-in sheet of paper that depicts the surface locations 

and water depths of the proposed wells is included in Appendix B. 

1.3 Safety and Pollution Prevention Features 

Safety and pollution prevention features utilized during drilling operations will include the use of 

appropriately designed casing and cement programs; appropriate blowout preventers, diverters, and 

other associated well equipment, appropriate mud monitoring equipment and sufficient mud volumes for 

well control; and properly trained personnel as described in 30 CFR § 250, Subparts C, D, E, F and O, 30 

CFR § 550, Subpart C, and as further clarified by Notices to Lessees (NTLs). Appropriate fire drills and 

abandon ship drills will be conducted, and navigational aids, lifesaving equipment, and all other shipboard 

safety equipment will be installed and maintained as mandated by the U.S. Coast Guard regulations 

contained in 33 CFR § 144. 

1.4 Storage Tanks and Production Vessels 

1.4.1 Storage Tanks West Sirius

Type of 

Storage Tank Type of Facility 

Tank 

Capacity 

(bbls) 

No. of 

Tanks 

Total 

Capacity 

(bbls) 

Fluid 

Gravity 

(API) 

Fuel Oil Semisubmersible 5,260 4 21,040 31.14 

Lube oil Semisubmersible 41.5 2 83 34.971 

Lube oil Semisubmersible 28 8 224 34.971 

Lube oil Semisubmersible 126 1 126 34.971 

Active Mud 

Pits Semisubmersible 1,063 avg. 6 6,378 

Reserve Mud 

Pits Semisubmersible 1547 avg. 8 12,376 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 8 of 38 

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Type of 

Storage Tank Type of Facility 

Tank 

Capacity 

(bbls) 

No. of 

Tanks 

Total 

Capacity 

(bbls) 

Fluid 

Gravity 

(API) 

Mud Processing 

Pits Semisubmersible 52 avg. 6 312 

Slugging Pit Semisubmersible 210 2 420 

Base oil Semisubmersible 4,718 2 9,436 20.651 

Brine Tank Semisubmersible 2,462 avg. 2 4,924 

Crude Oil Semisubmersible N/A N/A 

1.4.2 Storage Tanks Support Vessels

Type of 

Storage 

Tank 

Type of 

Facility 

Tank 

Capacity 

(bbls) 

No. of Tanks 

Total 

Capacity 

(bbls) 

Fluid Gravity 

(API) 

Fuel Oil 

Supply Boat 

(Typical 

280-feet) 450 16 

7,200 

dependent on 

other cargo 

carried 31.14 

Mud tanks 

Supply Boat 

(Typical 

280-feet) 1,750 8 

14,000 

dependent on 

fluid weight 

1.5 Additional Measures 

In addition to the safety, pollution prevention and early spill detection measures proposed in 30 CFR § 

250 and 550, BP will rely on its Operating Management System (OMS) to help deliver safe and reliable 

operations. OMS is a system of interdependent activities that drive how BP will actually perform work 

and comply with internal and external standards and regulations. BP has also implemented an 

Environmental Management System (EMS) which provides a systematic way to identify risks, potential 

impacts, and compliance requirements that need to be managed. BP has also presented to the BOEMRE 

a report entitled Deepwater Horizon Containment and Response: Harnessing Capabilities and 

Lessons Learned. This document assesses the capabilities that are now available to respond to oil spills 

in the GoM. 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 9 of 38 

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2 General Information 

2.1 Applications and Permits 

Application / Permit Issuing Agency Status 

Application for Permit to Drill BSEE To be submitted 

Emergency Evacuation Plan USCG To be submitted 

2.2 Drilling Fluids 

A table providing information on the types (including chemical constituents) and amounts of the drilling 

fluids that are planned to be used to drill the proposed wells is included below: 

Table 1: Drilling Fluids per Well (187-Days) 

Type of Drilling Fluid Estimated Volume of Drilling Fluid to be 

Used Per Well 

Water based (seawater, freshwater, barite) 144,000 bbls 

Oil based (diesel, mineral oil) NA 

Synthetic based (internal olefin, ester) 12,578 bbls 

2.3 New or Unusual Technologies 

Exploration activities in Keathley Canyon Block 93 are not expected to utilize any new or unusual 

technology within the meaning of 30 CFR § 550.200. 

2.4 Bonding Information 

The bonding requirements for the activities proposed in this Exploration Plan are satisfied by an areawide bond, furnished and maintained according to 30 CFR § 556, Subpart I, NTL No. 2000-G16 

“Guidelines for General Lease Surety Bonds”; and additional security under 30 CFR § 556.53(d) and NTL 

No. 2008-N07, “Supplemental Bond Procedures”. 

2.5 Oil Spill Financial Responsibility (OSFR) 

BP (Operator No. 02481) has demonstrated oil spill financial responsibility for the facilities proposed in 

this Exploration Plan according to 30 CFR § 553, and NTL No. 2008-N05, “Guidelines for Oil Spill Financial 

Responsibility (OSFR) for Covered Facilities”. 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 10 of 38 

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2.6 Deepwater Well Control Statement 

BP (Operator No. 02481) has the financial capability to drill a relief well and conduct other emergency 

well control operations. 

2.7 Blowout Scenario 

2.7.1 Blowout Scenario

The blowout scenario assumes that the pipe has been tripped out of the hole when a problem with the 

wellhead connector develops, resulting in the removal of the BOP stack. Due to the loss of riser margin, 

the well flows unrestricted. Day 1 worst case discharge (WCD) is 70,000 bopd, with the calculation 

support package for this rate attached as Appendix E. The maximum duration of the blowout is 

estimated at 163 days (see relief well timing below). The rate profile associated with the well blowout 

over this 163 day period (also included in Appendix E) results in a potential worst case spill volume 

estimated at 8.6 mmbo. 

2.7.2 The Potential for the Well to Bridge Over

While bridging is possible due to generally low formation strengths in the Gulf of Mexico, no bridging 

was assumed in the 'worst case scenario'. The open hole intervals experienced on each well have 

multiple formations open simultaneously. The modeling of the failure point of the weakest interval 

includes many variables, and using no bridging yields a maximum flow potential. 

2.7.3 The Likelihood for Surface Intervention to Stop the Blowout

The likelihood for above-mudline intervention to stop a blowout is dependent on the failure mechanism. 

Depending on the circumstances, BP may address a failure of the BOP stack by repairing the control 

system via ROVs, replacing the BOPs, or adding a BOP on top of the current BOP stack. Failure of the 

wellhead or casing would be more difficult and require clear access to the well below the failure point in 

order to run drill pipe and/or tools in the well. 

2.7.4 The Availability and Timing of a Rig to Drill a Relief Well

The table below lists the Mobile Offshore Drilling Units (MODU) that are capable of drilling a relief well. 

The estimated time to spud is 3 to 10 days, pending requirements to safely secure the current operations 

of the MODU, required material logistics, mobilization to location, and regulatory approvals. The 

possibility of drilling a relief well from a neighboring platform or land is not applicable to operations 

proposed in this Exploration Plan; there is no existing infrastructure in the vicinity of Keathley Canyon 

Block 93. 

BP and the operators listed below are signatories to a GoM Mutual Assistance Agreement, which 

provides for cooperation among operators with respect to the availability of drilling rigs in the event of an 

emergency. Availability of the rigs below may be subject to terms and conditions of the Mutual 

Assistance Agreement as well as regulatory agency direction. 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 11 of 38 

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Rig Name Current 

Location 

Current 

Operator 

Contract 

Expire 

Date 

Rated 

WD 

(feet) 

Rated 

TD 

(feet) 

Rated 

BOPs 

(psi) 

Moor 

Type 

Relevant Drill 

Package 

Limitations 

Transocean 

Discoverer 

Americas 

GOM Statoil 2014 12K 40K 15K DP 

None 

identified at 

this time 

Maersk 

Developer GOM Statoil / Woodside 2013 10K 40K 15K DP 

2.0-MM lbs 

rated Top 

Drive 

The estimated time to drill a relief well is: 10 days to mobilize and spud, 118 days from spud to casing 

shoe above WCD zone, plus 35 days for ranging, intersection, and kill operation--for a total of 163 days. 

2.7.5 Measures that would Enhance the Ability to Prevent a Blowout

Measures employed to prevent a blowout include compliance with applicable regulations (30 CFR 250 

and 550), current NTLs, and in particular, the Interim Final Rule focused on BOP certification and 

reliability. Additional measures: 

1. Volume measurements relative to the well will be monitored at all times during all operations; 

2. Flow checks before leaving bottom, after pulling into shoe, and before BHA enters stack. 

3. BP representative shall observe well conditions prior to each trip and after well kills or testing; 

4. BP representative shall be the only person authorized to initiate opening the well as part or 

conclusion of well control measures; 

5. On rig JSA/contingency plan before running any non-shearable tools or pipe through the BOP stack; 

and 

6. BP has adopted additional voluntary performance standards as outlined in a letter to Director 

Bromwich, dated July 15, 2011: 

1. BPXP will use, and will require its contractors involved in drilling operations to use, subsea 

blowout preventers (BOPs) equipped with no fewer than two blind shear rams and a casing 

shear ram on all drilling rigs under contract to BPXP for deepwater service operating in dynamic 

position mode. With respect to moored drilling rigs under contract to BPXP for deepwater 

drilling service using subsea BOPs, the subsea BOP will be equipped with two shear rams, 

which will include at least one blind shear ram and either an additional blind shear ram or a casing 

shear ram. 

2. Each time a subsea BOP from a moored or dynamically positioned drilling rig is brought to the 

surface and testing and maintenance on the BOP are conducted, BPXP will require that a third 

party verify that the testing and maintenance of the BOP were performed in accordance with 

manufacturer recommendations and API RP 53. 

3. BPXP will require that lab testing of cement slurries for primary cementing of casing and 

exposed hydrocarbon bearing zones relating to drilling operations of deepwater wells be 

conducted or witnessed by a BPXP engineer competent to evaluate such lab testing, or a 

competent third party independent of the cement provider. BPXP will provide lab results to the 

applicable BOEMRE field office within a reasonable period of time. 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 12 of 38 

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2.7.6 Measures that would Reduce the Likelihood of a Blowout

Measures to reduce the likelihood of a blowout include compliance with applicable regulations (30 CFR §

250 and 550) and current NTLs. Additional measures: 

1. Minimize any influx events to the wellbore, by using the best pore pressure / frac gradient 

predictions available, using downhole tools when appropriate, such as PWDs to monitor the 

wellbore and update pore pressure / frac gradient predictions; 

2. Management of change process will be followed for all procedure changes; and 

3. A Well Control Response Guide will be in place. 

2.7.7 Measures that would Enhance the Ability to Conduct Early Intervention

Measures to enhance the ability to conduct early intervention in addition to the regulation and NTL 

requirements include: 

1. Possible relief well locations have been identified and screened for general acceptability. In the 

event of a blow out or other event necessitating a relief well, data will be collected post-event to 

ensure that previously-identified relief well locations are still valid, or to assist in determining 

alternate relief well locations if required; 

2. Wellhead equipment and sufficient casing available for a relief well; 

3. A rig(s) is identified and available for a relief well; 

4. A Well Control Response Guide is in place; and 

5. Incident Management System (IMS) is in place. 

 The BP IMS is comprised of government-approved plans which cover various scenarios; 

Incident Management Teams which are trained annually in the Incident Command System, 

which is a part of the National Incident Management System; access to response capability 

through various contractors and technical specialists; and predesignated facilities, where the 

teams can provide adequate oversight to the response. 

2.7.8 Other Measures

All the proposed activities and facilities in this Exploration Plan will be covered by the OSRP filed by BP 

America Inc. (Operator No. 21591) in accordance with 30 CFR § 254 and approved on July 21, 2009. A 

revised Regional OSRP was filed with the BSEE on October 20, 2011 and is awaiting approval. 

3 Geological and Geophysical Information 

3.1 Geological Description 

A discussion of the geological objectives, including a brief description of the hydrocarbon trapping 

elements, is included in Appendix C in the “Proprietary Information” copies of this Exploration Plan. 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 13 of 38 

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3.2 Structure Contour Maps 

Current structure contour maps are included in Appendix C in the “Proprietary Information” copies of this 

Exploration Plan. 

3.3 Interpreted 2-D and/or 3D Seismic Lines 

Migrated and annotated 3-D seismic lines with depth scale within 152 meters (500 feet) of the proposed 

surface locations are enclosed with the site clearance letters included in Appendix C in the “Proprietary 

Information” copies of this Exploration Plan. 

3.4 Geological Structure Cross-Section Maps 

Interpreted geological structure cross-section maps are included in Appendix C in the “Proprietary 

Information” copies of this Exploration Plan. 

3.5 Shallow Hazards Report 

A regional shallow hazards report “Shallow Geohazards Assessment Gila Prospect, Blocks 48-51, 92-95, 

and 136-139 Keathley Canyon Area, Gulf of Mexico” was prepared by Fugro Geoconsulting, Inc. in May 

2010 for BP America, Inc. Two hard copies and two digital copies of this report have been submitted 

with this Exploration Plan. 

3.6 Shallow Hazards Assessment (Site Clearance Letter) 

A shallow hazards assessment (site clearance letter) that evaluates the seafloor and subsurface geologic 

and manmade features and conditions, prepared in accordance with NTL 2008-G05, for the proposed 

surface locations KC93 A and B is included in Appendix C of this Exploration Plan. 

3.7 High Resolution Seismic Lines 

Seismic sections through the proposed well location are included in the Shallow Hazards Assessment 

(site clearance letter) and are taken from a 2010 re-processed exploration 3D seismic data volume which 

meets the data quality and frequency requirements of the current Shallow Hazards NTL 2008-G05. 

3.8 Stratigraphic Column 

A generalized biostratigraphic / lithostratigraphic column are included in Appendix C in the “Proprietary 

Information” copies of this Exploration Plan. 

3.9 Time vs. Depth Table 

Existing well control data for the target areas proposed in this Exploration Plan are from the following 

wells: KC 102 #1 (35,055 feet MD), KC 244 #1 (31,462 feet MD), KC 291 #1 (32,250 feet MD) and KC 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 14 of 38 

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292 #1 (32,499 feet MD). These data address the time vs. depth requirements of 30 CFR 250.214(i) and 

NTL No. 2008-G04. 

4 Hydrogen Sulfide (H2S) Information 

4.1 Concentration 

Based on previous wells drilled in this area, the concentration would be 0 PPM H2S. It is not expected 

that H2S will be encountered during the operations proposed in this Exploration Plan. 

4.2 Classification 

Based on previous drilling, no H2S is known to occur in the project area. The following correlative wells 

in the same Keathley Canyon Area were drilled to similar geologic horizons without encountering H2S: KC 

102 #1 (35,055 feet MD), KC 244 #1 (31,462 feet MD) and KC 292 #1 (32,499 feet MD). Other wells 

drilled to similar geologic horizons in the area without encountering H2S are: Unocal GB 941 #1 (21,207 

feet MD), Unocal KC 681 #1 (27,575 feet MD), Conoco KC 511 #1 (30,082 feet MD), BP AC 739 #1 

(23,847 feet MD), and Shell AC 557 #1 ST02 (19,618 feet MD). BP requests that BOEM confirm the 

“H2S absent” classification. 

4.3 H2S Contingency Plan 

Based on previous drilling, no H2S is known to occur in the project area. Based previous BOEM “H2S 

absent” classification, it is not anticipated that a contingency plan will be required. 

4.4 Modeling Report 

Based on previous drilling, no H2S is known to occur in the project area. Therefore, no modeling report is 

required. 

5 Biological and Physical Information 

5.1 Benthic Communities Report 

Features or areas that could support high-density benthic communities are not located within 2,000 feet 

of each proposed muds and cuttings discharge location. The proposed wells will be drilled utilizing a 

dynamically positioned semi-submersible rig; therefore, physical disturbance of the seafloor will not occur 

due to anchor emplacements. 

5.2 Topographic Features Map 

The intent of NTL No. 2009-G39 is to protect biologically sensitive features and areas, in this case 

Topographic Features or Banks with moderate to high relief, in water depths less than 300 meters (984 

feet). The proposed well locations in Keathley Canyon Block 93 are in water depths greater than 4,000 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 15 of 38 

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feet. The Site Clearance Analysis conducted by BP and based on data from reprocessed 3D seismic data 

has identified no similar features within a 2,000-foot radius of the proposed well locations. All proposed 

bottom-disturbing activities will therefore occur outside 305 meters (1,000 feet) of the "No Activity Zone" 

of an identified topographic feature. 

5.3 Topographic Features Statement (shunting) 

The intent of NTL No. 2009-G39 is to protect biologically sensitive features and areas, in this case 

Topographic Features or Banks with moderate to high relief, in water depths less than 300 meters (984 

feet). The proposed well locations in Keathley Canyon Block 93 are in water depths greater than 4,000 

feet. The Site Clearance Analysis conducted by BP, based on reprocessed 3D seismic data, did not 

identify any similar features within a 2,000-foot radius of the proposed well locations. All proposed 

bottom-disturbing activities will therefore occur outside of the 3-mile Zone of an identified topographic 

feature. 

5.4 Live Bottoms (Pinnacle Trend) Map 

The intent of NTL No. 2009-G39 is to protect biologically sensitive features and areas, in this case the 

crests and flanks of pinnacles or hard-bottom features, in water depths less then 300 meters (984 feet). 

The proposed well locations in Keathley Canyon Block 93 are in water depths greater than 4,000 feet. 

The Site Clearance Analysis conducted by BP, based on reprocessed 3D seismic data, did not identify 

any similar features within a 2,000-foot radius of the proposed well locations. All proposed bottomdisturbing activities will therefore occur outside 61 meters (200 feet) of any hard bottoms/pinnacles that 

have vertical relief of 8 feet or more. 

5.5 Live bottoms (Low Relief) Map 

The intent of NTL No. 2009-G39 is to protect biologically sensitive features and areas, in this case, 

naturally occurring hard or rocky formations with rough, broken or smooth topography, in water depths 

less then 300 meters (984 feet). The proposed well locations in Keathley Canyon Block 93 are in water 

depths greater than 4,000 feet. The Site Clearance Analysis conducted by BP, based on reprocessed 3D 

seismic data, did not identify any similar features within a 2,000-foot radius of the proposed well 

locations. All proposed bottom-disturbing activities will therefore occur outside 30 meters (100 feet) of 

any live bottom area. 

5.6 Potentially Sensitive Biological Features 

The intent of NTL No. 2009-G39 is to protect biologically sensitive features and areas in water depths 

less than 300 meters (984 feet). The proposed well locations in Keathley Canyon Block 93 are in water 

depths greater than 4,000 feet. The Site Clearance Analysis conducted by BP, based on reprocessed 3D 

seismic data, did not identify any similar features within a 2,000-foot radius of the proposed well 

locations. All proposed bottom-disturbing activities will therefore occur outside 30 meters (100 feet) of 

any potentially sensitive biological features. 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

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5.7 Remotely Operated Vehicle (ROV) Monitoring Survey Plan 

Pursuant to NTL No. 2008-G06 “Remotely Operated Vehicle Surveys in Deepwater,” operators may be 

required to conduct remotely operated vehicle (ROV) surveys during pre-spud and post-drilling operations 

for the purpose of biological and physical observations. 

BP is familiar with the ROV survey and reporting provisions of the above referenced NTL and will, if 

required, conduct surveys immediately prior to commencement of and following completion of drilling 

operations at Well Locations A and B. 

BP would use a Seadrill West Sirius rig-based ROV equipped with video imaging capabilities. The survey 

pattern will consist of six transects, centered on the well location, with tracks extending approximately 

100 meters away from the well at bearings of 30 degrees, 90 degrees, 150 degrees, 210 degrees, 270 

degrees, and 330 degrees. The seafloor will be videotaped continuously along the track. 

If the ROV survey is required, BP will make biological and physical observations as described in NTL 

2008-G06 and Form BOEM-0141 prior to commencing drilling operations, and also following the 

completion of drilling operations, but prior to moving the rig off location. The observations will be 

documented using Form BOEM-0141, or a facsimile, and submitted to the BOEM, within 60 days after 

the second survey is completed. 

5.8 Threatened or Endangered Species, Critical Habitat and Marine 

Mammal Information 

Twenty-nine (29) species of marine mammals occur in the GoM. There are twenty-eight (28) species of 

cetaceans (seven (7) mysticete and twenty-one (21) odontocete species), and one (1) sirenian species, 

the manatee. 

Five (5) baleen whale species, one (1) toothed whale species, and one (1) sirenian species occur in the 

GoM, and are listed as endangered under the Endangered Species Act (ESA) (USDOI, OCS EIS/EA MMS 

2007-018): 

 The Northern Right Whale (Eubalaena glacialis); 

 The Blue Whale (Balaenoptera musculus); 

 The Fin Whale (Balaenoptera physalus); 

 The Sei Whale (Balaenoptera borealis); 

 The Humpback Whale (Megaptera novaeangliae); 

 The Sperm Whale (Physeter macrocephalus); and 

 The West Indian Manatee (Trichechus manatus). 

Of the seven (7) or eight (8) extant species of sea turtle, five (5) are known to inhabit the waters of the 

Gulf of Mexico: 

 The Leatherback Sea Turtle (Dermochelys coriacea); 

 The Green Sea Turtle (Chelonia mydas); 

 The Hawksbill Sea Turtle (Eretmochelys imbricata); 

 The Kemp's Ridley Sea Turtle (Lepidochelys kempii); and 

 The Loggerhead Sea Turtle (Caretta caretta). 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

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The Gulf Sturgeon (Ancipenser oxyrincus desotoi) and Smalltooth Sawfish (Pristus pectinata) are the 

listed threatened and endangered fish species in the Gulf of Mexico. 

Keathley Canyon Block 93 is not designated as critical habitat for any of these species. 

Additional information can be found in BP’s Environmental Impact Analysis attached as Appendix F. 

5.9 Archaeological Report 

Keathley Canyon Block 93 is not located within the area of high archaeological potential, as described in 

NTL No. 2005-G07 and supplemental NTLs. Therefore, an Archaeological Report is not required for 

activities proposed in this Exploration Plan. 

However, Keathley Canyon blocks are subject to the recent mitigation guidelines released by the BOEM 

in March 2011, entitled “Pre-Seabed Disturbance Survey Mitigation”, which require archaeological 

assessments prior to undertaking any bottom-disturbing activities, such as spudding a well. An 

archaeological survey “Gila Archaeological and Hazard Report, Blocks 93, 94 and Vicinity, Keathley 

Canyon Area, Gulf of Mexico” was prepared by Fugro Geoconsulting, Inc. in August 2011 for BP 

America, Inc. Two hard copies and two digital copies of this report have been submitted with this 

exploration plan. 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

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6 Waste and Discharge Information 

6.1 Waste Generated, Treated, Downhole Disposed or Discharged 

into the GoM 

Projected generated waste Projected ocean discharges 

Type of Waste Composition Projected Amount Discharge rate Discharge Method Answer yes or no

Will drilling occur ? If yes, you should list muds and cuttings

EXAMPLE: Cuttings wetted with synthetic based fluid 

Cuttings generated while using 

synthetic based drilling fluid. X bbl/well X bbl/hr/well discharge overboard No

Water-based drilling fluid

Spent drilling fluid drilling 

riserless hole plus pad mud to fill 

the hole 144000 32.1 Ocean seafloor discharge No

Cuttings wetted with water-based fluid Water base interval 6526 1.5 Ocean seafloor discharge No

Excess Cement Slurry Water base interval 276 0.1 Ocean seafloor discharge No

Cuttings wetted with synthetic-based fluid 

Drill cuttings, cement cuttings, 

and Synthetic base mud retained 

on cuttings 7,468 1.7 Ocean discharge No

Wash water from cementing equipment Equipment cleaning 2000 0.4 Ocean discharge No

Small Volume Drilling Fluid Discharges

Pit cleanout solids, accumulated 

solids in sand traps, 

displacement interfaces 75 0.02 Ocean discharge No

Cement transfer losses Bulk transfer from boat to rig 198 0.04 Ocean discharge No

Barite transfer losses Synthetic base interval 36.4 0.01 Ocean discharge No

Will humans be there? If yes, expect conventional waste

EXAMPLE: Sanitary waste water

Sanitary waste from living 

quarters X bbl/well X bbl/hr/well

chlorinate and discharge 

overboard No

Domestic waste Food waste 245 0.05 Ocean discharge No

Sanitary waste

Sanitary waste from living 

quarters 8976 2.00 Ocean discharge No

Gray water Gray water from living quarters 65450 14.58 Ocean discharge No

Is there a deck? If yes, there will be Deck Drainage

Deck Drainage Deck washdown & Rain water 36426 8.12 Ocean discharge No

Will you conduct well treatment, completion, or workover? 

Well treatment fluids NA

Well completion fluids NA

Workover fluids NA

Miscellaneous discharges. If yes, only fill in those associated with your activity. 

Desalinization unit discharge Seawater 4909685 1093.96 Ocean discharge No

Blowout prevent fluid

Ethylene glycol methanol - BOP 

testing and hydrates 153 0.03 Ocean discharge No

Ballast water Uncontaminated seawater 42075 9.38 Ocean discharge No

Bilge water 3487 0.7 Ocean discharge No

Excess cement at seafloor See above Drilling Section.

Fire water Uncontaminated seawater 2618 0.58 Ocean discharge No

Cooling water Uncontaminated seawater 14025000 3125.00 Ocean discharge No

Will you produce hydrocarbons? If yes fill in for produced water.

Produced water NA NA

Treatment Chemicals Corrosion, inhibitors, biocides 1.3 0.0002897 Ocean discharge No

Will you be covered by an individual or general NPDES permit ? yes

NPDES GENERAL PERMIT GMG290110 

NOTE: If you will not have a type of waste, enter NA in the row. 

Projected 

Downhole 

Disposal
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

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6.2 Wastes Transported and/or Disposed Onshore 

Projected 

generated waste

Solid and Liquid Wastes 

transportation 

Type of Waste Composition Transport Method

Name/Location of 

Facility Amount Disposal Method

Will drilling occur ? If yes, fill in the muds and cuttings.

EXAMPLE: Synthetic-based drilling fluid or 

mud internal olefin, ester

Below deck storage tanks on offshore 

support vessels

Newport Environmental 

Services Inc., Ingleside, 

TX X bbl/well Recycled

Oil-based drilling fluid or mud NA

Synthetic-based drilling fluid Internal olefin base fluid Liquid mud storage on workboat MI Swaco Fouchon La 10000 bbls/well For reuse

Contaminated Synthetic based drilling fluid

Contaminated Synthetic 

based drilling fluid Barged in (25 barrel cutting boxes)

Newpark Environmental 

Services, Fourchon LA 2000 bbls/well Deepwell injection on land

Cuttings wetted with Water-based fluid NA NA NA NA NA

Cuttings wetted with Synthetic-based fluid NA NA NA NA NA

Cuttings wetted with oil-based fluids NA NA NA NA NA

Will you produce hydrocarbons? If yes fill in for produced sand.

Produced sand NA NA NA NA NA

EXAMPLE: trash and debris (recylables) Plastic, paper, aluminum barged in a storage bin ARC, New Iberia, LA X lb/well Recycled

Domestic waste Municipal trash Barged in (supersacks)

River Birch Landfill, 

Avondale, LA 760 yd3/well Disposal

Drilling mud contaminated absorbents

Absorbent pads 

contaminated with drilling 

muds Barged in (Omega 2 yard boxes)

Omega Waste 

Management, 

Patterson, LA 2.4 tons/well Recycled

Excess barite 

Excess barite from vessel 

tank cleaning Transported by vehicle (supersacks)

Francis Drilling Mud or 

River Birch landfill 26 tons/well Reuse/Disposal

Excess cement

Excess cement from vessel 

tank cleaning Transported by vehicle (supersacks)

Grand Isle Port 

Commission or River 

Birch landfill 8.3 tons/well Reuse/Disposal

Washwater

Washwater from boat tank 

cleaning Transported in (15 barrel cuttings boxes)

Newpark Environmental 

Services, Fourchon LA 15815 bbls/well Deepwell injection on land

Well Related Hazardous Waste

Rig lab titrations containing 

isopropanol alcohol, silver 

nitrate etc. Barged in (5 gallon DOT containers)

Chemical Waste 

Management, Sulphur, 

LA 110 gallons/well Disposal

Scrap Metal

scrap piping, grating and 

other metals Barged in (scrap baskets) Southern Scrap. LA 15.8 tons/well Recycled

Recyclables

Plastic bottles, cardboard, 

paper, tin, aluminum Barged in (supersacks)

Recycle the Gulf ARC, 

Iberia, LA 30 tons/well Recycled

Rig Maintenance Wastes (painting, blasting)

Paint thinner, paint chips, 

blast media, aerosol cans Barged in (drums or totes)

L&L Oil and Gas 

Services, Fourchon, LA 55 gallons/well Disposal

Rig Maintenance Wastes (non hazardous) Oily rags, pads, oil filters etc. Barged in (drums or totes)

L&L Oil and Gas 

Services, Fourchon, LA 90 bbls/well Recycle or Disposal

Rig Waste oil Lube oil, hydraulic oil, glycol Barged in (totes)

L&L Oil and Gas 

Services, Fourchon, LA 102 bbls/well Recycled

Universal Waste Batteries Barged in (DOT drums)

L&L Oil and Gas 

Services, Fourchon, LA 40 lbs/well Recycled

Universal Waste Fluorescent light bulbs Barged in (DOT drums)

L&L Oil and Gas 

Services, Fourchon, LA 563 bulbs/well Recycled

NOTE: If you will not have a type of waste, enter NA in the row. 

Waste Disposal

Will you have additional wastes that are not permitted for discharge? If yes, 

fill in the appropriate rows. 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

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7 Air Emissions Information 

7.1 Screening Questions 

Screening Questions for EP’s Yes No 

Is any calculated Complex Total (CT) Emission amount (tons) associated with 

your proposed exploration activities more than 90% of the amounts 

calculated using the following formulas: CT = 3400D2/3 for CO, and CT = 

33.3D for the other air pollutants (where 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 87.5o W longitude? X 

Do you expect to encounter H2S at concentrations greater than 20 parts per 

million (ppm)? X 

Do you propose to flare or vent natural gas for more than 48 continuous 

hours, from any proposed well? X 

Do you propose to burn produced hydrocarbon liquids? X 

7.2 Emissions Worksheet 

Air emissions associated with activities proposed in this Exploration Plan have been calculated, and the 

appropriate emissions information is included in Appendix D. Complex total emissions are the same as 

plan emissions. 

7.3 Emission Reductions Measures 

Emission source Reduction Control 

Method 

Amount of 

Reduction (NOx) Monitoring System 

Offshore Supply, Fast 

Supply (Crew) and 

Multi-service Vessel 

Engines 

Actual Fuel 

Consumption 640 TPY (2012) Logistics Vessel Database 

 

Actual fuel consumption for the period April 1, 2009 to March 31, 2010 is included in Appendix D. 

7.4 Verification of Non-Default Emission Factors 

The default emission factors provided in Form BOEM-0138 were used, without exception. 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

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8 Oil Spill Information 

8.1 Oil Spill Response Planning 

8.1.1 Regional Oil Spill Response Plan (OSRP) Information

All the proposed activities and facilities in this Exploration Plan will be covered by the OSRP filed by BP 

America Inc. (Operator No. 21591) in accordance with 30 CFR § 254 and approved on July 21, 2009. A 

revised Regional OSRP was filed with the BSEE on October 20, 2011 and is awaiting approval. 

In a letter submitted to Mr. Michael J. Saucier dated October 19, 2011, BP provided a certification 

statement of the kind described in 30 CFR § 254.2 covering its operations in the Gulf of Mexico. 

BP has adopted additional voluntary performance standards as outlined in a letter to Director Bromwich, 

dated July 15, 2011: 

4. BPXP’s Oil Spill Response Plan (OSRP) will include information about enhanced measures for 

responding to a spill in open water, near shore response and shoreline spill response based on 

lessons learned from the Deepwater Horizon oil spill. In complying with the requirements of 30 CFR 

§ 254 and related Notices to Lessees, BPXP’s OSRP will include: 

 Provisions to maintain access to a supply of dispersant and fireproof boom for use in the event of 

an uncontrolled long-term blowout for the length of time required to drill a relief well. 

 Contingencies for maintaining an ongoing response for the length of time required to drill a relief 

well. 

 A description of the measures and equipment necessary to maximize the effectiveness and 

efficiency of the response equipment used to recover the discharge on the water’s surface. The 

discussion must include methods to increase encounter rates, the use of vessel tracking, and the 

use of remote sensing technologies. 

 Information on remote sensing technology and equipment to be used to track oil slicks, including 

oil spill detection systems and remote thickness detection systems (such as X-band/infrared 

systems). 

 Information pertaining to the use of vessel tracking systems and communication systems 

between response vessels and spotter personnel. 

 A shoreline protection strategy that is consistent with applicable area contingency plans (ACP). 

 For operations using a subsea BOP or a surface BOP on a floating facility, a discussion regarding 

strategies and plans related to source abatement and control for blowouts from drilling. 

8.1.2 Spill Response Sites

Primary Response Equipment Location Preplanned Staging Location(s) 

Houma, LA.; Lake Charles, LA.; Galveston, TX Fourchon, LA. 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

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8.1.3 OSRO Information

BP is a member of the Marine Spill Response Corporation (MSRC), Clean Gulf Associates (CGA) and the 

National Response Corporation and would utilize said Oil Spill Response Organization’s (OSRO) 

personnel and equipment in the event of an oil spill at Keathley Canyon Block 93. CGA is an oil spill 

cooperative which owns a large inventory of oil spill clean-up equipment which is supported by Marine 

Spill Response Corporation (MSRC). MSRC is responsible for storing, inspecting, maintaining, and 

dispatching CGA’s equipment. MSRC will also provide personnel to supervise and operate the 

equipment. 

8.1.4 Worst-case Scenario Determination

Category Regional OSRP 

(Exploration) 

(Approved July 

2009) 

Revised Regional 

OSRP (Exploration) 

(Submitted October 

20, 2011) 

EP 

Type of Activity Exploration Drilling Exploration Drilling Exploration Drilling 

Facility Location MC 462 WR 282 KC 93 #1 (LOC. A) 

Facility Designation MODU MODU MODU 

Distance to Nearest 

Shoreline 33 262 172.4 

Volume Uncontrolled 

Blowout (Day 1) 250,000-bbls 270,000-bbls 70,000-bbls 

Storage tanks (total) 0 0 0 

Flowlines (on facility) 0 0 0 

Lease term pipelines 0 0 0 

Total Volume (Day1) 250,000-bbls 270,000-bbls 70,000-bbls 

Type of Oil(s) Crude Oil Crude Oil Crude Oil 

API Gravity 26° (estimated) 30° 33.0° 

BP has determined that the worst case scenario from the activities proposed in this Exploration Plan 

does not supersede the worst cast scenario in BP’s Regional July 2009 OSRP or the Revised OSRP filed 

on October 20, 2011. Therefore, pursuant to NTL No. 2008-G04, BP makes the following statement: 

Since BP has the capability to respond to the worst-case spill scenario included in its regional Oil Spill 

Response Plan approved on July 21, 2009, and resubmitted, in revised form in October 2010, and further 

revised and submitted on October 20, 2011, and since the worst-case scenario determined for their 

Exploration Plan does not replace the worst-case scenario in their regional OSRP, BP certifies that it has 

the capability to respond, to the maximum extent practicable, to a worst-case discharge, or a substantial 

threat of such a discharge, resulting from the activities proposed in our Exploration Plan. 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

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Wellbore data, geologic data, reservoir data, and fluid data used in modeling and making the WCD 

determination for Well A, as well as for the Exploration Well WCD Scenario, which was submitted in the 

Revised Regional OSRP on October 20, 2011, are provided in Appendix E. 

8.2 Oil Spill Response Discussion 

A detailed discussion of a response to an oil spill at Keathley Canyon Block 93 is included in Appendix G. 

This Appendix addresses topics such as resource identification, release modeling, response 

technologies, and source containment / control. 

9 Environmental Monitoring and Mitigation Measures 

9.1 Monitoring Systems 

Operational personnel have been instructed to check for pollution frequently during their tour of duty and, 

in the event pollution is spotted, to identify and shut-off the source and make immediate notifications as 

per instructions provided in Section 2 and 3 of BP’s approved OSRP, Volume II. 

In accordance with the provisions of Title 30 CFR § 250.417(e) and NTL 2009-G02 “Deepwater Ocean 

Current Monitoring on Floating Facilities” dated January 27, 2009, the MODU will be equipped with an 

Acoustic Doppler Current Profile (ADCP) current monitoring system onboard to allow continuous 

monitoring and gathering of ocean current data on a real-time basis in the upper 1000 meters. 

9.2 Incidental Takes 

To mitigate incidental takes, all activities will be conducted in adherence to NTL 2007-G03 “Marine Trash 

and Debris Awareness Training and Elimination” and NTL 2007-G04 “Vessel Strike Avoidance and 

Injured/Dead Protected Species Reporting”. As required by NTL 2007-G03, BP submits an annual 

certification letter for its Marine Debris Awareness Training Process. The marine debris awareness 

training is required annually by the BSEE and is identified on BP’s Gulf of Mexico (GoM) Environmental 

Training Matrix and BP’s GoM Health, Safety, and Environmental (HSE) Training Needs Assessment, 

both of which are located on BP’s GoM HSE external website and accessible to all BP employees. 

Monitoring activities are conducted by all personnel on rigs and platforms to prevent accidental loss of 

materials overboard, and to report sightings of injured/dead protected species. Reporting of dead/injured 

protected species is addressed in BP’s Incident Notification and Investigation Procedure - Attachment 1. 

9.3 Flower Garden Banks National Marine Sanctuary 

All proposed activities will occur outside of the Protective Zones of the Flower Garden Banks and Stetson 

Bank. 

10 Lease Stipulation Information 

Lease Stipulation for Protected Species (Sea Turtles, Marine Mammals, Gulf Sturgeon, Brown Pelican, 

Whooping Cranes, and Other Federally Protected Species).
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

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All activities will be conducted in adherence to NTL 2007-G03 “Marine Trash and Debris Awareness 

Training and Elimination” and NTL 2007-G04 “Vessel Strike Avoidance and Injured/Dead Protected 

Species Reporting”. Mitigation to prevent takes varies based on the activity underway and it can include 

worker training on waste management and trash and debris containment procedures to avoid accidental 

loss overboard and its potential impact on protected species, and training on reporting of dead/injured 

protected species addressed in BP’s Incident Notification and Investigation Procedure—Attachment 1. 

11 Related Facilities and Operations Information 

11.1 Produced Liquid Hydrocarbons Transportation Vessels 

There are no well tests proposed in this Exploration Plan. 

12 Support Vessels and Aircraft Information 

12.1 General 

Type Maximum Fuel Tank 

Storage Capacity 

Maximum No. in 

Area at Any Time 

Trip Frequency or 

Duration 

Helicopter 760-gals 1 7 / week 

Crew Boats 1,000-bbls 1 2 / week 

Supply Boats 1,000-bbls 1 4 / week 

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 

240-feet to 280-feet 

50,000-gallons (boat fuel) 

150-K to 250-K gallons of 

transferable fuel (rig fuel) 

Weekly / as 

needed 

From the shorebase 

in Fourchon, LA, to 

KC 93 

12.3 Vicinity Map 

A vicinity map depicting the location of the proposed activities is included in Appendix B. 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 25 of 38 

Warning:. Check DW Docs revision to ensure you are using the correct revision. 

13 Onshore Support Facilities Information 

13.1 General 

The following table provides information of the onshore facility that will be used to provide supply and 

service support for the activities proposed in this Exploration Plan. 

Name Location Existing/New/Modified 

C-port Fourchon, LA Existing 

The C-Port facility provides a vehicle parking lot, office space, radio communication equipment, outside 

and warehouse storage space, crane, forklifts, water and fueling facilities, and boat dock space. The base 

is owned by Chouest and is leased by BP. The base is in operation 24-hours each day. 

A small amount of vessel and helicopter traffic may originate from bases other those described above in 

order to address changes in weather, market, and operational conditions. It is expected that this vessel 

traffic will originate from bases and locations that are in the near vicinity of the base previously described. 

13.2 Support Base Construction or Expansion 

BP will utilize existing support bases for these Exploration activities in Keathley Canyon Block 93 and 

therefore will not require the construction or expansion of additional support bases. 

14 Coastal Zone Management Act (CZMA) Information 

A Coastal Zone Management Act consistency certification, according to 15 CFR § 930.76(b) and (c) for 

the State of Louisiana and the State of Texas, is included as Appendix H. 

15 Environmental Impact Analysis (EIA) 

Attached as Appendix F is an environmental impact analysis (EIA) prepared for the proposed project by CK Associates, LLC, 17170 Perkins Road, Baton Rouge, Louisiana 70810. 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 26 of 38 

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16 Administrative Information 

16.1 Exempted Information Description 

In accordance with 43 CFR § 2, Appendix E, sections (4) and (9), the following information has been 

determined by the BOEM GOMR exempt from public disclosure: 

 Geologic Objectives (BHL, TVD and MD); 

 Proprietary New or Unusual Technology; 

 Geological and Geophysical Information (including Worst Case Discharge (WCD) Assumptions) 

 except for non-proprietary version of Shallow Hazard Assessment 

 Hydrogen Sulfide Correlative Well Information. 

This information is excluded from the “Public Information” copies of the submitted Exploration Plan. 

16.2 Bibliography 

Any previously submitted EP, DPP, DOCD, study report, survey report, or any other material referenced 

in this Exploration Plan is listed below: 

Deepwater Horizon Containment and Response: Harnessing Capabilities and Lessons Learned 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 27 of 38 

Warning:. Check DW Docs revision to ensure you are using the correct revision. 

Appendix A: Plan Information Forms – Form BOEM-0137 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 28 of 38 

Warning:. Check DW Docs revision to ensure you are using the correct revision. 

U.S. Department of the Interior OMB Control Number: 1010-0151 

Bureau of Ocean Energy Management OMB Approval Expires: 12/31/2011

OCS PLAN INFORMATION FORM 

General Information 

Type of OCS Plan X Exploration Plan (EP) Development Operations Coordination Document (DOCD) 

Company Name: BP Exploration & Production, Inc. BOEM Operation Number: 02481 

Address: 200 Westlake Park Blvd Contact Person: Mandy Phythian 

 Houston, TX 77079 Phone Number: 281-504-4352 

 E-Mail Address: mandy.phythian@bp.com 

Lease(s):OCS-G 25780 Area: KC Block(s): 93 Project Name (If Applicable): Gila 

Objective(s): X Oil Gas Sulphur Salt Onshore Base: Fourchon, LA Distance to Closest Land (Miles): 172.4 

Description of Proposed Activities (Mark all that apply) 

X Exploration drilling Development drilling 

 Well completion Installation of production platform 

 Well test flaring (for more than 48 hours) Installation of production facilities 

 Installation of caisson or platform as well protection structure Installation of satellite structure 

 Installation of subsea wellheads and/or manifolds Commence production 

 Installation of lease term pipelines Other (Specify and describe) 

Have you submitted or do you plan to submit a Conservation Information Document to accompany this plan? Yes X No 

Do you propose to use new or unusual technology to conduct your activities? Yes X No 

Do you propose any facility that will serve as a host facility for deepwater subsea development? Yes X No 

Do you propose any activities that may disturb a BOEM-designated high-probability archaeological area? Yes X No 

Have all of the surface locations of your proposed activities been previously reviewed and approved by BOEM? Yes X No 

Tentative Schedule of Proposed Activities 

Proposed Activity Start Date End Date No. of Days 

Drill and temporarily abandon well location “A” 07/18/2012 01/20/2013 187 

Drill and temporarily abandon well location “B” 01/21/2013 07/26/2013 187 

Description of Drilling Rig Description of Production Platform 

 Jackup Drillship Caisson Tension Leg Platform 

 Gorilla Jackup Platform rig Well protector Compliant tower 

 Semi-submersible Submersible Fixed Platform Guyed tower 

X DP Semi-submersible Other (Attach description) Subsea manifold Floating production system 

Drilling Rig Name (if known): Sea Drill West Sirius Spar Other (Attach Description) 

Description of Lease Term Pipelines 

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

NA 

FORM BOEM-0137 (October 2011 - Supersedes all previous editions of form BOEM-0137 which may not be used.) Page 1 of 3
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 29 of 38 

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OCS 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): Well Location “A”

Subsea Completion 

Anchor Radius (if applicable) in feet: NA Yes X No 

Surface Location Bottom-Hole Location (For Wells) 

Lease No. OCS-G 25780 OCS-G 25780 

Area Name KC KC 

Block No. 93 93 

Blockline 

Departures 

N/S Departure: 6627’ F _S_ L N/S Departure: 6627’ F _S_ L 

(in feet) E/W Departure: 122’ F _E_ L E/W Departure: 122’ F _E_ L 

Lambert X-Y X: 1,425,478.00 X: 1,425,478.00 

coordinates Y: 9,748,227.00 Y: 9,748,227.00 

Latitude 

26° 51’ 46.813” N 

Latitude 

26° 51’ 46.813” N 

Latitude / 

Longitude 

Longitude 

93° 39’ 34.194” W 

Longitude 

93° 39’ 34.194” W 

TVD (Feet): 30,116 MD (Feet): 30,116 Water Depth (Feet): 4853’ 

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

necessary) 

Anchor Name 

or No. 

Area Block X Coordinate Y Coordinate Length of 

Anchor Chain on 

Seafloor 

 

 

 

Paperwork Reduction Act of 1995 Statement: The Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35) requires us to inform you that BOEM 

collects this information as part of an applicant’s Exploration Plan or Development Operations Coordination Document submitted for BOEM approval. 

We use the information to facilitate our review and data entry for OCS plans. We will protect proprietary data according to the Freedom of Information 

Act and 30 CFR 550.197. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it 

displays a currently valid Office of Management and Budget Control Number. The use of this form is voluntary. The public reporting burden for this form 

is included in the burden for preparing Exploration Plans and Development Operations Coordination Documents. We estimate that burden to average 

600 hours per response, or 640 with an accompanying EP (1,000 hours in AKOCSR), or 690 (1,700 in AKOCSR) with an accompanying DPP or DOCD, 

including the time for reviewing instructions, gathering and maintaining data, and completing and reviewing the form. Direct comments regarding the 

burden estimate or any other aspect of this form to the Information Collection Clearance Officer, Bureau of Ocean Energy Management, 381 Elden 

Street, Herndon, VA 20170. 

FORM BOEM-0137 (October 2011 - Supersedes all previous editions of form BOEM-0137 which may not be used.) Page 2 of 3
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 30 of 38 

Warning:. Check DW Docs revision to ensure you are using the correct revision. 

OCS 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): Well Location “B”

Subsea Completion

Anchor Radius (if applicable) in feet: NA Yes X No 

Surface Location Bottom-Hole Location (For Wells) 

Lease No. OCS-G 25780 OCS-G 25780 

Area Name KC KC 

Block No. 93 93 

Blockline 

Departures 

N/S Departure 7115’ F _N_ L N/S Departure 7115’ F _N_ L 

(in feet) E/W Departure 7067’ F _W_ L E/W Departure 7067’ F _W_ L 

Lambert X-Y X: 1,416,827.00 X: 1,416,827.00 

coordinates Y: 9,750,325.00 Y: 9,750,325.00 

Latitude 

26° 52’ 07.143” N 

Latitude 

26° 52’ 07.143” N 

Latitude / 

Longitude 

Longitude 

93° 41’ 09.873” W 

Longitude 

93° 41’ 09.873” W 

TVD (Feet): 30,290 MD (Feet): 30,290 Water Depth (Feet): 4768’ 

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

Anchor Name 

or No. 

Area Block X Coordinate Y Coordinate Length of 

Anchor Chain on 

Seafloor 

 

 

 

Paperwork Reduction Act of 1995 Statement: The Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35) requires us to inform you that BOEM 

collects this information as part of an applicant’s Exploration Plan or Development Operations Coordination Document submitted for BOEM approval. 

We use the information to facilitate our review and data entry for OCS plans. We will protect proprietary data according to the Freedom of Information 

Act and 30 CFR 550.197. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it 

displays a currently valid Office of Management and Budget Control Number. The use of this form is voluntary. The public reporting burden for this form 

is included in the burden for preparing Exploration Plans and Development Operations Coordination Documents. We estimate that burden to average 

600 hours per response, or 640 with an accompanying EP (1,000 hours in AKOCSR), or 690 (1,700 in AKOCSR) with an accompanying DPP or DOCD, 

including the time for reviewing instructions, gathering and maintaining data, and completing and reviewing the form. Direct comments regarding the 

burden estimate or any other aspect of this form to the Information Collection Clearance Officer, Bureau of Ocean Energy Management, 381 Elden 

Street, Herndon, VA 20170. 

FORM BOEM-0137 (October 2011 - Supersedes all previous editions of form BOEM-0137 which may not be used.) Page 3 of 3
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 31 of 38 

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Appendix B: Vicinity Plat and Location Plat 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 32 of 38 

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Appendix C: Geological Description, Structure Contour 

Maps, Interpreted Seismic Lines, Geological 

Structure Cross-Section Maps, Shallow Hazards 

Assessment (Site Clearance Letters), 

Stratigraphic Column, Seafloor Amplitude Maps 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 33 of 38 

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Appendix D: Air Quality Report 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 34 of 38 

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Appendix E: WCD Assumptions for KC93 and WR282 

(Exploration Well Scenario in Revised OSRP) 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 35 of 38 

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Appendix F: Environmental Impact Analysis (EIA) 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 36 of 38 

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Appendix G: Oil Spill Response Discussion 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 37 of 38 

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Appendix H: Coastal Zone Management Act (CZMA) 

Consistency Certification 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 38 of 38 

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Appendix I : Fee Recovery 
OG-KC101.dgn 5/18/2010 4:18:39 PM

________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 15-Dec-2011 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: Public Information Page: Page 31 of 37 

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Appendix C: Shallow Hazards Assessment (Site Clearance 

Letter) 

Other contents are Proprietary (Geological 

Description, Structure Contour Maps, 

Interpreted Seismic Lines, Geological Structure 

Cross-Section Maps, Stratigraphic Column, 

Seafloor Amplitude Maps)










________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 15-Dec-2011 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: Public Information Page: Page 32 of 37 

Warning:. Check DW Docs revision to ensure you are using the correct revision. 

Appendix D: Air Quality Report 
EXPLORATION PLAN (EP)

AIR QUALITY SCREENING CHECKLIST

OMB A

COMPANY BP Exploration & Production Inc

AREA Keathley CanyonBLOCK 93LEASE OCS-G26780PLATFORM MODU - West SiriusWELL KC93-A and KC93-B

COMPANY CONTACT Jim Pfeiffer (Air Quality); Mandy Phythian (Plans)TELEPHONE NO. 281-366-1542 (Jim); 281-504-4352 (Mandy)REMARKS

Drill and temporarily abandon two exploratory wells. Complex total emissions are the same as plan emissions.

MMS FORM MMS-138 (December 2008 - Supersedes all previous versions of form MMS-138 which may not be used). Page 1 of 5
EMISSIONS FACTORS

Fuel Usage Conversion Factors Natural Gas Turbines Natural Gas Engines Diesel Recip. Engine RE

SCF/hp-hr 9.524 SCF/hp-hr 7.143 GAL/hp-hr 0.0483 AP42 

Equipment/Emission Factors units PM SOx NOx VOC CO RENG Turbines gms/hp-hr 0.00247 1.3 0.01 0.83 AP42 3.2-NG 2-cycle lean gms/hp-hr 0.00185 10.9 0.43 1.5 AP42 NG 4-cycle lean gms/hp-hr 0.00185 11.8 0.72 1.6 AP42 NG 4-cycle rich gms/hp-hr 0.00185 10 0.14 8.6 AP42 Diesel Recip. < 600 hp. gms/hp-hr 1 1.468 14 1.12 3.03 AP42 Diesel Recip. > 600 hp. gms/hp-hr 0.32 1.468 11 0.33 2.4 AP42 Diesel Boiler lbs/bbl 0.084 2.42 0.84 0.008 0.21 AP42 1.3NG Heaters/Boilers/Burners lbs/mmscf 7.6 0.593 100 5.5 84 P42 1.4-1, 1NG Flares lbs/mmscf 0.593 71.4 60.3 388.5 AP42 1Liquid Flaring lbs/bbl 0.42 6.83 2 0.01 0.21 AP42 1.3-Tank Vapors lbs/bbl 0.03 E&P FFugitives lbs/hr/comp. 0.0005 API SGlycol Dehydrator Vent lbs/mmscf 6.6 La. DGas Venting lbs/scf 0.0034

Sulphur Content Source Value Units

Fuel Gas 3.33 ppm

Diesel Fuel 0.4 % weight

Produced Gas( Flares) 3.33 ppm

Produced Oil (Liquid Flaring) 1 % weight

MMS FORM MMS-138 (December 2008 - Supersedes all previous versions of form MMS-138 which may not be used). Page 2 of 5
EMISSIONS CALCULATIONS 1ST YEAR

COMPANY AREA BLOCK LEASE PLATFORM WELL CONTACT PHONE REMARKS

BP Exploration & Production Inc Keathley Canyon 93 OCS-G26780 ODU - West Siri KC93-A and KC93-B Jim Pfeiffer (Air Quality); Mandy281-366-1542 (J

OPERATIONS EQUIPMENT RATING MAX. FUEL ACT. FUEL RUN TIME MAXIMUM POUNDS PER HOUR 

Diesel Engines HP GAL/HR GAL/D

Nat. Gas Engines HP SCF/HR SCF/D

Burners MMBTU/HR SCF/HR SCF/D HR/D DAYS PM SOx NOx VOC CO PM 

DRILLINGMains- 8 x Cat 3616 PRIME MOVER>600hp diesel 50560 2442.05 58609.15 24 305 35.64 163.48 1225.02 36.75 267.28 130.43 

E-gen- 1 x Cat 3512B AUXILIARY EQUIP>600hp diesel 1750 84.53 2028.60 2 305 1.23 5.66 42.40 1.27 9.25 0.38 Small and Large Aux Engines AUXILIARY EQUIP<600hp diesel 2500 120.75 2898.00 24 76 5.51 8.08 77.09 6.17 16.69 5.04 Fast Supply Vessel/Crew Boat VESSELS>600hp diesel(crew) 7200 347.76 6272.00 6 102 15.86 23.28 222.03 17.76 48.05 3.63 Offshore Supply Vessel #1 VESSELS>600hp diesel(support) 7200 347.76 3370.00 24 153 15.86 23.28 222.03 17.76 48.05 11.72 Offshore Supply Vessel #2 VESSELS>600hp diesel(support) 7200 347.76 3370.00 24 153 5.07 23.28 174.45 5.23 38.06 3.75 Offshore Supply Vessel #3 VESSELS>600hp diesel(support) 7200 347.76 3370.00 24 153 5.07 23.28 174.45 5.23 38.06 3.75 

2012 YEAR TOTAL 84.24 270.35 2137.47 90.18 465.44 158.70 

EXEMPTION CALCULATION DISTANCE FROM LAND IN MILES 5727.60 

172.0

MMS FORM MMS-138 (December 2008 - Supersedes all previous versions of form MMS-138 which may not be used). Page 3 of 5
EMISSIONS CALCULATIONS 2ND YEAR

COMPANY AREA BLOCK LEASE PLATFORM WELL CONTACT PHONE REMARKS

BP Exploration & Production Inc Keathley Canyon 93 OCS-G26780 ODU - West Siri KC93-A and KC93-B Jim Pfeiffer (Air Quality); Mandy281-366-1542 (J

OPERATIONS EQUIPMENT RATING MAX. FUEL ACT. FUEL RUN TIME MAXIMUM POUNDS PER HOUR 

Diesel Engines HP GAL/HR GAL/D

Nat. Gas Engines HP SCF/HR SCF/D

Burners MMBTU/HR SCF/HR SCF/D HR/D DAYS PM SOx NOx VOC CO PM 

DRILLINGMains- 8 x Cat 3616 PRIME MOVER>600hp diesel 50560 2442.05 58609.15 24 69 35.64 163.48 1225.02 36.75 267.28 29.51 E-gen- 1 x Cat 3512B AUXILIARY EQUIP>600hp diesel 1750 84.53 2028.60 2 69 1.23 5.66 42.40 1.27 9.25 0.09 Small and Large Aux Engines AUXILIARY EQUIP<600hp diesel 2500 120.75 2898.00 24 17 5.51 8.08 77.09 6.17 16.69 1.14 Fast Supply Vessel/Crew Boat VESSELS>600hp diesel(crew) 7200 347.76 6272.00 6 23 15.86 23.28 222.03 17.76 48.05 0.82 Offshore Supply Vessel #1 VESSELS>600hp diesel(support) 7200 347.76 3370.00 24 35 15.86 23.28 222.03 17.76 48.05 2.65 Offshore Supply Vessel #2 VESSELS>600hp diesel(support) 7200 347.76 3370.00 24 35 5.07 23.28 174.45 5.23 38.06 0.85 Offshore Supply Vessel #3 VESSELS>600hp diesel(support) 7200 347.76 3370.00 24 35 5.07 23.28 174.45 5.23 38.06 0.85 

2013 YEAR TOTAL 84.24 270.35 2137.47 90.18 465.44 35.90 

EXEMPTION CALCULATION DISTANCE FROM LAND IN MILES 5727.60 

172.0

MMS FORM MMS-138 (December 2008 - Supersedes all previous versions of form MMS-138 which may not be used). Page 4 of 5
SUMMARY

COMPANY AREA BLOCK LEASE PLATFORM WELLBP Exploration &Keathley Canyon 93 OCS-G26780 MODU - West Sirius KC93-A and KC93

Emitted Substance

Year

 PM SOx NOx VOC CO

2012 158.70 664.42 5039.80 165.47 1099.092013 35.90 150.31 1140.15 37.43 248.652014 0.00 0.00 0.00 0.00 0.002015 0.00 0.00 0.00 0.00 0.002016 0.00 0.00 0.00 0.00 0.002017 0.00 0.00 0.00 0.00 0.002018 0.00 0.00 0.00 0.00 0.002019 0.00 0.00 0.00 0.00 0.002020 0.00 0.00 0.00 0.00 0.002021 0.00 0.00 0.00 0.00 0.00

Allowable 5727.60 5727.60 5727.60 5727.60 105155.31

MMS FORM MMS-138 (December 2008 - Supersedes all previous versions of form MMS-138 which may not be used). Page 5 of 5
Actual Fuel Consumption 

Vessels: 

Offshore Supply Vessels (OSVs/SVs) 

Fast Supply Vessels/Crew Boat (FSV) 
Vessel Offshore Activity Time (minutes)

Sum of CHARGE_TIME Boat Type

END_PLACE ANCHOR CREW ROV SUPPLY Grand Total

APACHE 90 90

Atlantis 39,875 39,875

ATLANTIS PQ 4,005 515 115,140 119,660

Balder 810 960 1,770

Bell Pass 75 810 885

BOA DEEP C 390 14,370 14,760

BOA SUB C 1,770 29,120 30,890

BOB PALMER 25,695 96,195 121,890

CHLOE 1,020 1,020

Crossmar 7 375 375

DD1 870 5,385 6,255

DD2 2,155 48,150 653,020 703,325

DD3 27,915 253,305 281,220

ENTERPRISE 32,305 3,970 473,670 509,945

GC 2,225 2,225

GC645 2,190 2,190

GC742 2,070 2,070

GC743 2,850 3,785 6,915 13,550

GC782 270 11,370 11,640

GC787 8,060 1,440 9,500

GI 1,050 1,935 2,985

GI40 REM CLOUGH 1,020 1,020

GI95 1,020 60 1,080

GI95A 2,190 11,010 13,200

HIA119 2,190 2,190

HOLSTEIN 56,355 220,827 277,182

HOLSTEIN DRLG 11,745 11,745

HORIZON 64,552 359,713 424,265

HORN MOUNTAIN 5,115 78,750 83,865

KODIAK 5,306 1,440 6,746

MAD DOG 26,085 17,338 193,650 237,073

MAD DOG DRLG 8,190 8,190

MARIANAS 67,475 31,365 384,260 483,100

MARLIN 3,330 123,671 127,001

MC 65,975 800 66,775

MC127 2,730 1,090 3,820

MC129 3,810 3,810

MC252 58,575 2,767 61,342

MC474 1,950 7,612 9,562

MC520 35,735 4,470 3,330 43,535

MC727 4,260 720 4,980

MC773 12,205 12,205

MC776 2,445 8,800 11,245

MC777 862 862

MC778 930 46,158 16,245 63,333

MC84 2,730 2,730
MC85 2,701 2,701

MP225 4,125 165 4,290

MP260 29,820 4,815 34,635

MP289 4,410 4,590 9,000

NAKIKA 2,415 15,585 112,850 130,850

OCEAN INTER 1 25,925 1,260 27,185

OCEAN INTER 3 735 735

OLYMP CHALNGR 2,760 31,065 33,825

POMPANO 1,035 6,660 150 100,744 108,589

SKANDI ACHIEVER 2,070 690 2,760

SKANDI NEPTUNE 1,155 41,787 42,942

SMI205 8,565 9,135 17,700

SMI205B 5,280 5,280

SP-89E 14,370 6,075 20,445

SS332 3,240 3,390 6,630

ST21 165 165

ST-21 2,021 2,021

ST22 870 1,380 2,250

ST27 1,485 1,485

ST28 1,035 1,035

ST92 1,065 1,065

TH DRLG (CC) 5,700 1,560 7,260

TH SUBSEA 13,830 13,830

THUNDER HORSE 65,123 4,380 709,053 778,556

VK915 5,295 32,510 37,805

VK989 2,050 1,950 15,848 900 20,748

Grand Total 192,247 502,540 314,094 4,141,882 5,150,763
Vessel Diesel Fuel Consumption

Sum of Fuel ConsuBoat Type

Month ANCHOR CREW ROV SUPPLY Grand Total

January 9,175 133,224 44,910 793,546 980,855

February 123,312 47,020 746,560 916,892

March 134,139 38,991 813,793 986,923

April 74,482 218,051 43,738 886,635 1,222,906

May 168,813 228,358 42,857 790,081 1,230,109

June 123,620 275,689 37,518 832,605 1,269,432

July 118,427 281,438 57,738 962,902 1,420,505

August 190,071 215,966 61,365 806,041 1,273,443

September 33,430 204,112 28,550 716,376 982,468

October 129,482 141,550 30,850 785,701 1,087,583

November 109,035 146,266 34,453 734,145 1,023,899

December 88,683 86,618 41,105 821,569 1,037,975

Grand Total 1,045,218 2,188,723 509,095 9,689,954 13,432,990

Diesel Fuel Consumption Per Boat Type

Supply Vessel 2.340 gals/min 140.370 gals/hr

Crew Vessel 4.355 gals/min 261.319 gals/hr

ROV Vessel 1.621 gals/min 97.250 gals/hr

All time is activity time the vessels spent offshore whether actively working, 

transitting from one location to another, or standingby waiting to be called in 

by the offshore asset.
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 15-Dec-2011 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: Public Information Page: Page 33 of 37 

Warning:. Check DW Docs revision to ensure you are using the correct revision. 

Appendix E: Proprietary - WCD Assumptions for KC93 and 

WR282 (Exploration Well Scenario in Revised 

OSRP) 
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 15-Dec-2011 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: Public Information Page: Page 34 of 37 

Warning:. Check DW Docs revision to ensure you are using the correct revision. 

Appendix F: Environmental Impact Analysis (EIA) 
BP EXPLORATION & PRODUCTION 

ENVIRONMENTAL IMPACT 

ANALYSIS 

For 

KEATHLEY CANYON BLOCK 93 

JULY 2011 

Prepared by: 

C-K Associates, LLC 

17170 Perkins Road 

Baton Rouge, Louisiana 70810 

(225) 755-1000 

C-K Associates’ Project 5929E
Environmental Impact Analysis, Keathley Canyon Block 93 

BP Exploration & Production, Inc. 

July 2011 

5929E i of ii C-K Associates, LLC 

TABLE OF CONTENTS 

Section Page

1.0 INTRODUCTION .................................................................................................................1 

2.0 IMPACT PRODUCING FACTORS .....................................................................................3 

3.0 AFFECTED RESOURCES AND IMPACT ANALYSIS .....................................................9 

 3.1 Site Specific at Offshore Location .............................................................................9 

 3.1.1 Soft Bottom Communities .............................................................................9 

 3.1.2 Designated Topographic Features..................................................................10 

 3.1.3 Pinnacle Trend Area Live Bottoms ................................................................11 

 3.1.4 Live Bottom/Low Relief ................................................................................11 

 3.1.5 High Density Benthic Communities ..............................................................11 

 3.1.6 Water Quality .................................................................................................13 

 3.1.7 Fisheries .........................................................................................................14 

 3.1.8 Marine Mammals ...........................................................................................18 

 3.1.9 Sea Turtles .....................................................................................................21 

 3.1.10 Air Quality .....................................................................................................23 

 3.1.11 Shipwreck Sites ..............................................................................................24 

 3.1.12 Prehistoric Archaeological Sites ....................................................................26 

 3.2 Vicinity of Offshore Location ....................................................................................27 

 3.2.1 Essential Fish Habitat ....................................................................................27 

 3.2.2 Marine and Pelagic Birds ...............................................................................29 

 3.2.3 Public Health and Safety ................................................................................31 

 3.3 Coastal and Onshore ..................................................................................................32 

 3.3.1 Beaches ..........................................................................................................32 

 3.3.2 Wetlands ........................................................................................................33 

 3.3.3 Shore Birds and Coastal Nesting Birds ..........................................................36 

 3.3.4 Coastal Wildlife Refuges and Wilderness Areas ...........................................38 

 3.3.5 Other Environmental Resources Identified ....................................................39 

 3.3.5.1 Socioeconomics ..............................................................................39 

 3.3.5.2 Groundwater and Onshore Environments .......................................41 

4.0 CUMULATIVE IMPACTS ...................................................................................................42 

5.0 ENVIRONMENTAL HAZARDS .........................................................................................48 

6.0 ALTERNATIVES..................................................................................................................48 

7.0 MITIGATION MEASURES .................................................................................................48 
Environmental Impact Analysis, Keathley Canyon Block 93 

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TABLE OF CONTENTS 

(cont.) 

Section Page

8.0 CONSULTATION .................................................................................................................49 

9.0 PREPARERS .........................................................................................................................49 

10.0 REFERENCES ......................................................................................................................49 

LIST OF TABLES 

Table

1 Summary Table of Probabilities (expressed as a percent chance) that an oil spill starting 

at Launch Area W025 (includes Keathley Canyon Block 93) will contact a county within 

3/10/30 days 

2 Environmental Impact Analysis Worksheet 

LIST OF FIGURES 

Figure

1 Designated Topographic Features 

2 Pinnacle Trend Area 

3 Chemosynthetic Communities 

4 Coastal Wildlife Refuge
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List of Acronyms 

bbl barrel 

BOEMRE Bureau of Ocean Energy Management, Regulation and Enforcement 

BP BP Exploration and Production, Inc. 

C Celsius 

CFR Code of Federal Regulations 

CGA Clean Gulf Associates 

CIAP Coastal Impact Assistance Program 

CO carbon monoxide 

CPA Central Planning Area 

CWIS Cooling Water Intake Structure 

CWPPRA Coastal Wetlands Protection, Planning & Restoration Act 

EA Environmental Assessment 

EEZ Exclusive Economic Zone 

EFH Essential Fish Habitat 

EIA Environmental Impact Analysis 

EIS Environmental Impact Statement 

EP Exploration Plan 

EPA Eastern Planning Area 

ESA Endangered Species Act 

FAA Federal Aviation Administration 

FGBNMS Flower Garden Banks National Marine Sanctuary 

FMP Fishery Management Plan 

FONSI Finding of No Significant Impact 

FPSO floating production, storage and offloading systems 

ft feet 

FWS U.S. Fish and Wildlife Service 

GMFMC Gulf of Mexico Fishery Management Council 

GOM Gulf of Mexico 

HAPC Habitat Area of Particular Concern 

IPF impact-producing factor 

KC Keathley Canyon 

km kilometer 

l liter 

LCRP Louisiana Coastal Resources Program 

m meter 

MARPOL International Convention for the Prevention of Pollution from Ships 

mi mile 

μg micrograms 

mm millimeter 

MMPA Marine Mammal Protection Act 

MMS Minerals Management Service 

MODU Mobile Offshore Drilling Unit 

MPRSA Marine Protection, Research, and Sanctuaries Act 

MSRC Marine Spill Response Corporation 
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MWCC Marine Well Containment Company 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act 

NERR National Estuarine Research Reserve 

NMFS National Marine Fisheries Service 

NOAA National Oceanic and Atmospheric Administration 

NOx nitrogen oxides 

NPDES National Pollutant Discharge Elimination System 

NRC National Response Corporation 

NTL Notice to Lessees 

NWR National Wildlife Refuge 

OCS Outer Continental Shelf 

OCSLA Outer Continental Shelf Lands Act 

OSRA Oil Spill Risk Analysis 

OSRO Oil Spill Response Organization 

OSRP Oil Spill Response Plan 

PAH polycyclic aromatic hydrocarbon 

PEA Programmatic Environmental Assessment 

PM particulate matter 

ppe personal protective equipment 

ppm parts per million 

PSD Prevention of Significant Deterioration 

RCRA Resource Conservation and Recovery Act 

ROV Remotely Operated Vehicle 

SONS Spill of National Significance 

SOx sulfur oxides 

USCG U.S. Coast Guard 

USDOC U.S. Department of Commerce 

USDOI U.S. Department of the Interior 

USEPA U.S. Environmental Protection Agency 

VOC volatile organic compound 

WCD worst case discharge 

WPA Western Planning Area
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1.0 INTRODUCTION 

Project Background 

BP Exploration & Production Inc. (BP) is proposing to drill and temporarily abandon two 

(2) exploratory wells (Well location A and B) in Keathley Canyon (KC) Block 93 (Gila 

Project Area). The proposed exploratory wells will be drilled with Seadrill’s 

dynamically-positioned West Sirius semi-submersible drilling rig. BP anticipates that it 

will take about 187 days to drill and temporarily abandon each well. 

Regulatory Background 

Under the Federal Outer Continental Shelf Lands Act (OCSLA) the Bureau of Ocean 

Energy Management, Regulation and Enforcement (BOEMRE; formerly Minerals 

Management Service [MMS] prior to June 2010) is charged with the responsibility for 

managing and regulating exploration and development on the Outer Continental Shelf 

(OCS). 

The BOEMRE Notice to Lessees and Operators (NTLs) provide clarification, description, 

or interpretation of a regulation; special lease stipulation or regional requirement 

strategies; or administrative information. Several of the NTLs are applicable and contain 

stipulations which direct lease development to avoid or mitigate impacts. 

NTL No. 2005-G07 

Archaeological Resource Surveys and Reports 

Provides regulatory guidance for archaeological discoveries and clarifies when to 

report discoveries, responsibility for conducting discovery investigations and 

assessments, penalties for non-compliance and changes to survey requirements. 

NTL No. 2007-G03 

Marine Trash and Debris Awareness and Elimination

Provides regulatory guidance for the management of marine trash and debris, 

including the handling and disposal of small items and packing material. 

Requires the posting of placards, marine trash and awareness training and 

certification. 

NTL No. 2007-G04 

Vessel Strike Avoidance and Injured/Dead Protected Species Reporting

Provides guidance on how to implement monitoring programs to minimize risk of 

vessel strikes to protected species and to report observations of injured or dead 

species. 

NTL No. 2008-G04 

Information requirements for Exploration Plans and Development Operations 

Coordination Documents 

Provides guidance on information requirements for OCS plans including guidance 

on information requirements for compliance with the Endangered Species Act 

(ESA), Marine Mammal Protection Act (MMPA), and placing high resolution 

survey lines with 3-D survey data. 
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NTL No. 2008–G20 

Revisions to the List of OCS Lease Blocks Requiring Archaeological Resource 

Surveys and Reports 

Makes additions to and modifies the list of OCS blocks that require 

archaeological surveys. 

NTL No. 2009–G39 

Biologically-Sensitive Underwater Features and Areas

Provides guidance to protect biologically-sensitive underwater features. Changes 

the water depth from 400 meters ((m) 1,812 feet (ft)) to 300 m (984 ft), minor 

regulatory references, update NTL references, and minor administrative changes. 

NTL No. 2009–G40 

Deepwater Benthic Communities 

Provides guidance to protect high density deepwater benthic communities from 

damage from OCS oil and gas activities. Covers all high density deepwater 

features in deepwater greater than 300 m (984 ft) with a separation distance of 

610 m (2,000 ft) from drilling muds and cutting locations. 

NTL No. 2010–N06

Information Requirements for Exploration Plans, Development and Production 

Plans, and Development Operations Coordination Documents on the OCS 

Rescinds the limitations set forth in NTL 2008-G04 regarding a blowout scenario 

and provides guidance regarding the content of the information required in the 

blowout scenario and worst case discharge (WCD) scenarios. 

Under the National Environmental Policy Act (NEPA), the BOEMRE has prepared 

multi-lease-sale Environmental Impact Statements (EIS) in the Central Planning Area 

(CPA) and Western Planning Area (WPA) Gulf of Mexico (GOM). Two recent final 

multi-lease-sale EISs prepared were for oil and gas lease sales 2003-2007 (USDOI MMS 

2002) and oil and gas lease sales 2007-2012 (USDOI MMS 2007a). In 2008 BOERME 

prepared a Supplemental EIS for the CPA and WPA (USDOI MMS 2008b). The GOM 

has also been divided into 17 areas or Grids of biological similarity 

(http://www.gomr.boemre.gov/homepg/regulate/environ/ea_grid/ea_grid.asp). A Programmatic Environmental Assessment (PEA) for specific activities within Grid 4 in the 

OCS region was prepared which includes Keathley Canyon Block 93 (USDOI MMS 

2001). The PEA updates some of the material covered in the EIS. The EIS and PEA 

contain a description of the affected resources; potential impacts on the physical, 

biological, socioeconomic, and human resources; and the cumulative effects of a 

proposed action. 

BOEMRE recently published an Environmental Assessment (EA), Finding of No 

Significant Impact (FONSI) for Increased Safety Measures for Energy Development on 

the Outer Continental Shelf for 30 CFR Part 250 (USDOI BOEMRE 2010a), 

Modifications to Suspensions of Deepwater Drilling Operations (USDOI BOEMRE 

2010b), a Site Specific EA in deepwater (USDOI BOEMRE 2011a) and a draft 

Supplemental EIS, Lease Sale 2011, WPA 218 (USDOI BOEMRE 2011b). The Site 

Specific EA and draft supplemental EIS each contain a catastrophic spill event analysis 
Environmental Impact Analysis, Keatley Canyon Block 93 

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(USDOI BOEMRE 2011a, 2011b; Appendix B). The draft supplemental EIS also has a 

BOEMRE-Oil Spill Risk Analysis (OSRA) Catastrophic Spill Run (USDOI BOEMRE 

2011b, Appendix C). 

2.0 IMPACT PRODUCING FACTORS 

The NTL 2008-G04, including 30 CFR 250.212 (o) and 250.227, contains the 

requirements used to prepare a project specific EIA to assess the potential direct and 

indirect environmental impacts to offshore and onshore resources. In preparing the EIA 

several Impact Producing Factors (IPFs) are considered that are uniquely associated with 

offshore activities. The following are examples of IPFs that have the potential to impact 

the environment as specified in NTL 2008-G04: 

(1) air emissions; 

(2) seafloor disturbance from anchoring and structure emplacement; 

(3) discharges of drilling muds, cuttings, and produced water; 

(4) emissions of light and noise; 

(5) water intakes and discharges; 

(6) use of service vessels and helicopters; 

(7) construction or expansion of onshore support facilities; 

(8) onshore waste disposal; 

(9) marine trash and debris; and, 

(10) accidental events including oil spills, chemical spills, blowouts, vessel 

collisions, hydrogen sulfide releases, or large-volume flaring or venting 

events (for such accidents, describe in terms of volume, duration, etc.). 

Several of the IPFs may be considered to be routine for exploration activities such as 

waste and discharges from vessel operations and drilling activities; air emissions from 

equipment and vessels; noise from vessel and helicopter transportation and drilling 

activities; and anchoring. The routine activities have been addressed in the multisale EIS 

for the WPA and CPA, Gulf of Mexico (GOM) (USDOI MMS 2002, 2007a), the 

supplemental EIS for the CPA and WPA sales (USDOI MMS 2008b), the PEA for Grid 4 

(USDOI MMS 2001), and the draft supplemental EIS (USDOI BOEMRE 2011b). 

Several IPFs can occur from an accidental event such as a vessel collision with marine 

mammals and sea turtles; oil spills and blowouts; and, vessel and helicopter collisions 

with coastal and marine birds (USDOI MMS 2002, 2003, 2007a, 2008b, USDOI 

BOEMRE 2010a, 2011a and 2011b). The IPFs are addressed in detail in the impact 

analysis for each of the affected resources in Section 3.0. Table 2 is the EIA worksheet 

modeled after Form MMS-142 (http://www.gomr.boerme.gov/homepg/regulate/ 

regs/ntls/EIAWorksheet.pdf). It contains the relevant IPFs and the potentially affected 

environmental resources for the activities proposed. 

Accidental Release: 

An accidental release (i.e. spill) is an unplanned, unforeseeable event and past 

experiences are relied upon to predict many factors regarding oil-spill risks (USDOI 

BOEMRE 2011a). In a recent EA, BOEMRE published the analysis of a high-volume, 

long duration oil spill (USDOI BOEMRE 2011a, Appendix B). In this EA, a catastrophic 

event is defined as “large-scale damage involving destruction of species, ecosystems, 

infrastructure, or property with long-term effects, and/or major loss of human life 
Environmental Impact Analysis, Keatley Canyon Block 93 

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(Eccleston 2008).” Several factors were used during the analysis of a catastrophic event 

such as time of year, location of a release relative to winds, currents, land, and sensitive 

resources, specifics of the well (i.e., flow rates, hydrocarbon characteristics, and 

infrastructure damage), and response (i.e., speed and effectiveness). A catastrophic event 

for oil and gas activities on the OCS is considered to be a high volume and long duration 

oil spill, regardless of the cause (USDOI BOEMRE 2011a). Furthermore, a WCD for an 

offshore facility is the largest foreseeable discharge in adverse weather conditions 

(Section 311(a) (24) of the Clean Water Act). A Spill of National Significance (SONS) is 

defined as a spill that because of the severity, size, location, actual or potential impact on 

the public health and welfare or the environment, or the necessary response effort is so 

complex that it requires extraordinary coordination of federal, state, local, and 

responsible party resources to contain and cleanup the discharge (40 CFR Part 300, 

Appendix E). 

An assessment of the probability of a future large spill must consider a number of factors, 

including historical data regarding the occurrence of such events and the low estimated 

spill risk of a larger spill event (.002 percent risk of spill > 1,000 barrels (bbl) as reported 

by BOEMRE) (USDOI BOEMRE 2011a). Risk is further reduced by the recent response 

and containment improvements, BOEMRE’s enhanced oversight, and industry’s 

heightened safety awareness (USDOI BOEMRE 2011a). Based on these factors, it is 

reasonable to conclude that the likelihood such an accidental large volume/long duration 

spill event will occur has been reduced (USDOI BOEMRE 2011a). Additionally, the 

regulations (30 CFR 254) require the submittal of an Oil-Spill Response Plan (OSRP) 

that outlines the availability of spill containment and cleanup equipment as well as 

trained personnel able to respond, to the maximum extent practicable, to a worst case 

discharge or a substantial threat of such a discharge. 

New safety measures (USDOI BOERME 2011b) reduce the risk of large volume, long 

duration oil spills and smaller oil spills occurring. The development of new well 

containment technology, well containment protocols and oil spill response technology, 

methodologies, and protocols reduce the severity and duration of catastrophic oil spills 

(USDOI BOEMRE 2010a). 

Oil Spill Risk Analysis: 

The BOEMRE conducted an OSRA that produced oil spill trajectory simulations used to 

estimate the risk from a spill (Ji et al. 2004). According to BOEMRE studies (Ji et al. 

2004) the occurrence of an oil spill (or spills) is a matter of probability and its impact is 

determined by variables such as the amount of oil released, and winds and ocean currents 

that transport spills. While the occurrence of a spill cannot be predicted, an estimate can 

be calculated of the likelihood of an event contacting environmental resources. 

The trajectories simulated represent only hypothetical pathways of oil slicks and does not 

involve any consideration of spill response activities (i.e., clean up), dispersion, or 

weathering processes that could alter the quantity or properties of oil that may eventually 

contact the environmental resource locations (Ji et al. 2004). 

The OSRA model simulated the likely trajectory of a surface slick, from locations 

projected onto a gridded area. The trajectory simulates a spill’s movement on the surface 

of water by using modeled ocean current and wind fields. The OSRA model tabulates the 
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5929E 5 of 67 C-K Associates, LLC 

number of times that each trajectory moves across or touches (contacts) a location 

representative of various environmental features or shoreline segments. The OSRA 

model compiles the number of contacts to each feature that result from the modeled 

trajectory simulations from all of the launch points for a specific launch area. Each 

trajectory was allowed to continue for as long as 30 days and contacts within 3, 10 and 30 

days were compiled. If the hypothetical spill contacted shoreline sooner than 30 days 

after the start of the spill, the spill trajectory was terminated, and the contact was 

recorded (Ji et al. 2004; Smith et al. 1982; LaBelle and Anderson 1985). The location of 

a launch area(s) where a lease or facility is located can be found at 

http://www.boemre.gov/itd/pubs/2004/2004-026.pdf. 

Keathley Canyon Block 93 is in Launch Area 25. The tables with the conditional 

probability results for three time frames (within 3, 10, or 30 days) can be found in the 

OSRA (Ji et al. 2004) and are summarized below for Launch Area 25 (Table 1). 

Table 1 

Summary Table of Probabilities (expressed as a percent chance) that an oil spill 

starting at Launch Area W025 (includes Keathley Canyon Block 93) will contact a 

county/parish within 3/10/30 days 

Note: “-“ = less than 0.5 percent. Blank cells are less than 0.5 percent for all values. 

The model predicts either a less than 0.5 percent or no shoreline contacts within 3 or 10 

days of a spill. After 30 days, regardless of the season, there is a greater than 0.5 percent 

chance that 12 counties or parishes may be contacted, including ten counties in Texas and 

two parishes in Louisiana. Counties or parishes in Texas, Louisiana, Mississippi, 

Alabama, and Florida with all values less than 0.5 percent are not shown. 

County 

Launch Area 

All 

Seasons

Winter Spring Summer Autumn 

W025 W025 W025 W025 W025 

Cameron, TX -/-/1 -/-/2 -/-/2 -/-/1 

Willacy, TX -/-/1 

Kenedy, TX -/-/2 -/-/5 -/-/1 -/-/1 -/-/2 

Kleberg, TX -/-/2 -/-/4 -/-/2 -/-/1 

Nueces, TX -/-/1 -/-/3 -/-/2 -/-/1 

Aransas, TX -/-/2 -/-/3 -/-/4 -/-/1 -/-/1 

Calhoun, TX -/-/2 -/-/2 -/-/6 -/-/1 -/-/1 

Matagorda, TX -/-/6 -/-/2 -/-/15 -/-/4 -/-/1 

Brazoria, TX -/-/2 -/-/6 -/-/2 

Galveston, TX -/-/4 -/-/12 -/-/4 

Jefferson, TX -/-/2 -/-/7 -/-/1 

Cameron, LA -/-/4 -/-/12 -/-/2 

Vermillion, LA -/-/2 -/-/4 -/-/2 

Iberia, LA -/-/1 

Terrebonne, LA -/-/1 

Plaquemines, LA -/-/1 
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BOEMRE recently published trajectory modeling for a large volume, long duration 

offshore oil spill (USDOI BOEMRE 2011b, Appendix C). This modeling for a high 

volume, long duration oil spill supplements the previous OSRA spill projections (Ji et al. 

2004). This analysis looked at projected shoreline impacts for a hypothetical high 

volume, long duration oil spill lasting for up to 90 days with a trajectory predicted for 

120 days (30 days after the spill is controlled). The three month probabilities provided 

preliminary impact data based on seasonal oceanographic and meteorological variability. 

Releases were simulated for three launch points in the CPA and two launch points in the 

WPA. The OSRA model does not address the likelihood of such an event but may assist 

in identifying potential impacts if the event occurs. A wide range of resources (physical, 

biological, and socioeconomic) could be impacted by such an event depending on the 

location of the spill as well as wind and ocean currents. Offshore resources in the 

vicinity of the drilling rig or platform could be impacted. As time passes there is a higher 

probability these impacts may extend to near shore and coastal resources. 

Understandably the model concluded that near shore and coastal resources closer to the 

spill site have the greatest likelihood of impact. The chance for shoreline impacts 

increases as time increases due to interactions between the oil and complex ocean and 

wind currents (USDOI BOEMRE 2011b, Appendix C). 

 
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TABLE 2 

ENVIRONMENTAL IMPACT ANALYSIS WORKSHEET 

The IPF’s that have the potential to cause impacts to the listed environmental resources are 

identified by an “x”. For those cells that are footnoted, a statement is provided that addresses 

its applicability. 

Environmental Resources Impact Producing Factors (IPFs) 

Categories and examples 

Refer to a recent GOM OCS Lease Sale EIS for a more complete list of IPFs 

Emissions 

(air, noise, 

light, etc.) 

Effluents (muds, 

cuttings, other 

discharges to 

the water 

column or 

seafloor) 

Physical 

disturbances to 

the seafloor (rig 

or anchor 

emplacements, 

subsea 

infrastructure, 

etc.) 

Wastes sent 

to shore for 

treatment 

or disposal 

Accidents 

(e.g., oil 

spills, 

chemical 

spills, H2S 

releases, 

vessel 

strikes) 

Marine 

Trash 

and 

Debris 

Cooling 

Water 

Intake 

Site-specific at Offshore 

Location 

Soft bottom communities x (6)x 

Designated topographic 

features 

 (1) (1) (1)x 

Pinnacle Trend area live 

bottoms 

 (2) (2) (2)x 

 Live bottoms/low relief (3) (3) (3)x 

High density benthic 

communities 

 (4) (6)x 

Water quality x (6)x 

Fisheries x x (6)x x 

Protected species (Marine 

mammals, sea turtles, Gulf 

sturgeon) 

(8)x x (8)x x 

Air quality (9)x (6)x 

Shipwreck sites (known or 

potential) 

 (7) (6)x 

Prehistoric archaeological sites (7) (6)x 

Vicinity of Offshore Location 

Essential fish habitat x x (6)x 

Marine and pelagic birds x x (6)x x 

Public health and safety (5)x 

Coastal and Onshore 

Beaches (6)x x 

Wetlands/Sea grass (6)x 

Coastal protected species 

(shore birds, coastal nesting 

birds, and beach mice) 

 (6)x 

Coastal protected areas 

(wildlife refuges wilderness, 

estuaries, seashore) 

 (6)x 

Wilderness areas (6) x 

Socioeconomics (6)x 

Groundwater and onshore 

environments 

 x (6)x 

NOTE: The numbers in parentheses refer to the footnotes on page 2 of this form.

Copied from BOEMRE FORM MMS-142 Page 1 of 2 
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Footnotes for Environmental Impact Analysis Matrix 

1. Activities that may affect a marine sanctuary or topographic feature. Specifically, if the well or platform site or any anchors will 

be on the seafloor within the: 

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

b. 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; 

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

d. Proximity of any submarine bank (500 ft buffer zone) with relief greater than 2 meters that is not protected by the 

Topographic Features Stipulation attached to an OCS lease. 

2. Activities with any bottom disturbance within an OCS lease block protected through the Live Bottom Activities (Pinnacle Trend) 

Stipulation attached to an OCS lease. 

 

3. Activities within any Eastern Gulf OCS block where seafloor habitats are protected by the Live Bottom (Low Relief) Stipulation 

attached to an OCS lease. 

4. Activities on blocks designated by the BOEMRE as being in water depths 400 meters or greater. 

5. Exploration or production activities where H2S concentrations greater than 500 ppm might be encountered. 

6. All activities that could result in an accidental spill of produced liquid hydrocarbons or diesel fuel that you determine would 

impact these environmental resources. If the proposed action is located 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 MMS as 

having high-probability for the occurrence of shipwrecks or prehistoric sites, including such blocks that will be affected that are 

adjacent to the lease block in which your planned activity will occur. If the proposed activities are located a sufficient distance 

from a shipwreck or 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 transportation of produced fluids to shore using shuttle tankers or barges 

Copied from BOEMRE FORM MMS-142 Page 2 of 2 
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3.0 AFFECTED RESOURCES AND IMPACT ANALYSIS 

3.1 Site Specific at Offshore Location 

3.1.1 Soft Bottom Benthic Communities 

Affected Resource – Much of the GOM consists of a soft, muddy bottom in 

which burrowing infauna are the most abundant invertebrates. Single-celled 

bacteria to invertebrates as well as fish inhabit soft-bottom habitat at almost every 

depth range in the GOM (USDOI MMS 2007a). Major groups of animals that 

live in this habitat include: bacteria and other microbenthos; meiofauna (0.063-0.3 

millimeter (mm)); macrofauna (>0.3 mm); and (4) megafauna (larger organisms 

such as crabs, sea pens, sea cucumbers, crinoids, and bottom-dwelling (demersal) 

fish). All of these groups are represented throughout the entire GOM from the 

continental shelf to the deepest abyssal depths (about 3,850 m (12,630 ft)). The 

seabed in the project area is complex and ranges from smooth to slightly 

hummocky in the basins to rugged in the highly faulted areas in the shallow salt 

(Fugro 2010). 

Impact Analysis – IPFs potentially affecting soft bottom benthic communities are 

effluent discharges (drilling mud and cuttings) and accidental releases. The 

proposed drilling and support activities will be done with a dynamically 

positioned rig, so there are no associated anchors, anchor chain or wire ropes. 

Discharges of drilling mud and cuttings only move to limited directions 

depending on prevailing currents. Impacts will also be limited by the drilling one 

well at a time. This would not result in a significant impact on the soft-bottom 

benthic communities because the duration and areal extent of the proposed 

activities would be limited and recolonization of benthic communities is 

facilitated from nearby surrounding areas (USDOI MMS 2007a). 

Oil from a surface spill can be driven into the water column; measurable amounts 

have been documented down to a 10 m (32.8 ft) depth and modeling did indicate 

that oil could reach a depth of 20 m (65.6 ft). At the 20 m (65.6 ft) depth, the oil 

is found only at concentrations several orders of magnitude lower than the amount 

shown to have an effect on marine organisms, corals, and invertebrates (Lange 

1985; McAuliffe et al. 1975 and 1981; Knap et al. 1985). 

An accidental release (blowout) at the seafloor could create a crater and resuspend 

and disperse large quantities of bottom sediments within a 300-m (984-ft) radius 

of the blowout site (USDOI BOEMRE 2011a, 2011b), burying both infaunal (live 

in the sediment) and epifaunal (live on the sediment) organisms and interfering 

with sessile invertebrates that rely on filter-feeding organs. Even in situations 

where substantial burial of typical benthic infaunal communities occurred, 

recolonization from populations from neighboring soft bottom substrate would be 

expected over a relatively short period of time for all size ranges of organisms, in 

a matter of days for bacteria and probably less than one year for most all 

macrofauna species (USDOI MMS 2007a; NRC 2003; NRC 2006). 

Low concentrations of dispersed oil may occur in areas near a blowout site in 

offshore waters following the subsea use of dispersants (USDOI BOEMRE 
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2011a; Joint Analysis Group 2010). The behavior and impacts of subsurface 

concentrations of dispersed oil are not well known, but such oil could have the 

potential to contact soft bottom benthic communities beyond the 300‐ m (984‐ ft) 

radius estimated by BOEMRE (USDOI BOEMRE 2011a; USDOI MMS 2007a 

and 2008b) depending on its extent, trajectory, and persistence. Potential impacts 

on sensitive resources would be an integral part of the decision and approval 

process for the use of dispersants. 

Subsurface spills could result in the formation and settling of oil-saturated 

material and oil-sediment particles could come into contact with living soft 

bottom biota tissue. The extent of such impacts will vary depending on, among 

other factors, the magnitude and duration of such an incident. Should any of the 

oil come in contact with soft bottom biota, effects, if any, would be primarily 

sublethal (Jackson et al. 1989). No significant impact is expected to soft bottom 

benthic communities. Contact from small spills is minimized due to water depth. 

Implementation of new BOEMRE environmental and safety regulations may 

further reduce the probability of the occurrence of a large volume/long duration 

spill. 

3.1.2 Designated Topographic Feature 

Affected Resource – Topographic features, along with their associated coral reef 

communities, are typically located on the shelf edge, shelf, and mid-shelf of the 

WPA and the CPA of the GOM OCS Region (Figure 1). These hardbottom 

benthic communities support areas of high biomass, high diversity, and high 

numbers of plant and animal species. Topographic features also support, either as 

shelter or food, or both, large numbers of commercially and recreationally 

important fishes; and they provide a relatively pristine area suitable for scientific 

research. There are 37 known topographic features in the GOM that support 

various, diverse reef ecosystems; 21 in the WPA and 16 in the CPA (USDOI 

MMS 2007a, 2008b; USDOI BOEMRE 2011b; USDOI MMS NTL 2009-G39). 

The Marine Protection, Research, and Sanctuaries Act (MPRSA) of 1972 

established the National Marine Sanctuary Program, which is administered by 

National Oceanic and Atmospheric Administration (NOAA). The Flower Garden 

Banks National Marine Sanctuary (FGBNMS), which was designated in 1992, is 

the only sanctuary that exists in the northern GOM. The East and West Flower 

Garden Banks and Stetson Bank comprise the FGBNMS and are located in the 

WPA (USDOI MMS 2002, 2007a, 2008b; USDOI BOEMRE 2011b). 

Impact Analysis – The only IPF potentially affecting topographic features is 

accidental releases. The nearest topographic feature is the West Flower Garden 

Bank is about 106 km (66 mi) to the north (Figure 1). The site-specific offshore 

location of the proposed activities (Keathley Canyon Block 93) is outside the 3-

mile zone of any identified topographic feature. 

As discussed in Section 3.1.1 sub-sea concentration of dispersed oil may contact 

benthic organisms such as those represented by the designated topographic 

features, however due to distance and the depth such impact is not expected. 

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further reduce the probability of the occurrence of a large volume/long duration 

spill. 

3.1.3 Pinnacle Trend Area Live Bottom 

Affected Resource – A region of topographic relief along the northeastern 

portion of the CPA is known as the “pinnacle trend,” at the outer edge of the 

Mississippi-Alabama shelf between the Mississippi River and DeSoto Canyon 

(USDOI MMS 2002, 2007a and 2008b) (Figure 2). The pinnacles appear to be 

carbonate reef structures in an intermediate stage between growth and 

fossilization (Ludwick and Walton 1957). This area contains a variety of features 

from low-relief rocky areas to major pinnacles, as well as ridges, scarps, and relict 

patch reefs. These discrete mounds vary in size and structural complexity. 

Impact Analysis – The only IPF potentially affecting pinnacle trend features is an 

accidental release. The pinnacle trend area is about 568 km (353 mi) northeast 

from the Gila project area, along the shelf edge south of Mississippi and Alabama 

(Figure 2). None of the blocks in Keathley Canyon are covered by the Live 

Bottom (Pinnacle Trend) Stipulation. 

As discussed in Section 3.1.1 sub-sea concentrations of dispersed oil may contact 

benthic organisms such as those represented by the pinnacle trend, however due 

to distance and the depth such impact is not expected. Implementation of new 

BOEMRE environmental and safety regulations may further reduce the 

probability of the occurrence of a large volume/long duration spill. 

3.1.4 Live Bottom/Low Relief 

Affected Resource – Live-bottoms (low relief features) means seagrass 

communities; areas that contain biological assemblages consisting of sessile 

invertebrates living upon and attached to naturally occurring hard or rocky 

formations with rough, broken, or smooth topography; and areas where a hard 

substrate and vertical relief may favor the accumulation of turtles, fishes, or other 

fauna (USDOI MMS NTL 2009-G39). The closest live bottom feature is beyond 

the pinnacle trend area which is greater than 568 km (353 mi). 

Impact Analysis – The only IPF potentially affecting live bottoms would be 

accidental releases. The Gila project area is not covered by the Live Bottom (low 

relief) Stipulation. As discussed in Section 3.1.1 sub-sea concentrations of 

dispersed oil may contact benthic organisms such as those represented by live 

bottoms, however due to distance and the depth such impact is not expected. 

Implementation of new BOEMRE environmental and safety regulations may 

further reduce the probability of the occurrence of a large volume/long duration 

spill. 

3.1.5 High Density Deepwater Benthic Communities 

Affected Resource – High density deepwater communities are features or areas 

that could support high density chemosynthetic communities, deepwater corals, 

and other associated hard bottom communities (USDOI MMS NTL 2009-G39). 

Chemosynthetic communities are defined as persistent, largely sessile 

assemblages of marine organisms dependent upon chemosynthetic bacteria as 
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their primary food source (MacDonald 1992) (Figure 3). A carbon source 

independent of photosynthesis is used by chemosynthetic communities. Although 

the process of chemosynthesis is entirely microbial, chemosynthetic bacteria and 

their primary production can support thriving assemblages of higher organisms 

through symbiosis. The occurrence of chemosynthetic organisms dependent on 

hydrocarbon seepage has been documented in water depths as shallow as 290 m 

(951.4 ft) (Roberts et al. 1990) and as deep as 2,200 m (7,217.76 ft) (MacDonald 

1992). This depth range places chemosynthetic communities in the deepwater 

region of the GOM. 

The communities are dominated by vestimentiferan tubeworms, mytilid mussels, 

vesicomyid clams, and infaunal lucinid or thyasirid clams (USDOI MMS 2002, 

2007a and 2008b) (MacDonald 1990). These faunal groups tend to display 

distinctive characteristics in terms of how they aggregate, the size of 

aggregations, the geological and chemical properties of the habitats in which they 

occur and, to some degree, the heterotrophic fauna that occur with them. Many of 

the species found at cold seep communities in the GOM are new to science and 

remain undescribed. 

Impact Analysis – The IPF potentially affecting high density deepwater 

communities is an accidental release. None of the known high‐density deepwater 

benthic community locations listed in NTL 2009‐G40 are in Keathley Canyon 

Block 93 (Figure 3). The Shallow Geohazards assessment (Fugro 2010) was 

prepared using the guidance in Attachment B of NTL No. 2009-G40, “Deepwater 

Benthic Communities”. The proposed drilling will be done with a dynamically 

positioned rig, so there are no associated anchors, anchor chain or wire ropes.

BP has provided BOEMRE with the required maps, analyses and statement(s) 

prepared using the guidance in Attachment A of NTL No. 2009-G40 “Deepwater 

Benthic Communities”. As shown in the shallow hazards report (Fugro 2010) 

accompanying the exploration plan, and the seafloor amplitude map included in 

Section 3.0 of the exploration plan, no geophysical evidence of hydrocarbon 

seepage sites or areas that could potentially support the presence of 

chemosynthetic communities are recognized within 2,000 ft around the proposed 

location (Fugro 2010). 

The risk of chemosynthetic communities at or close to this location is therefore 

believed to be negligible. No geophysical evidence of hydrocarbon seepage sites 

or areas that could potentially support the presence of chemosynthetic 

communities are recognized (Fugro 2010). The potential for the presence of 

chemosynthetic communities is considered very low. 

As discussed in Section 3.1.1 sub-sea concentrations of dispersed oil associated 

with an accidental release may contact high density deepwater benthic 

communities, however due to distance and the depth such impact is not expected. 

No significant impact is expected to high density deepwater communities. 

Contact from small spills is minimized due to water depth. Implementation of 

new BOEMRE environmental and safety regulations may further reduce the 

probability of the occurrence of a large volume/long duration spill. 
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3.1.6 Water Quality 

Affected Resource – Deepwater areas in the northern GOM are relatively 

homogeneous with respect to temperature, salinity, and oxygen (USDOI MMS 

2007a). Discharges associated with offshore oil and gas exploration and 

production activities located in the Western and Central GOM must be authorized 

for discharge under the current “National Pollutant Discharge Elimination system 

(NPDES) General Permit for Discharges from the Offshore Subcategory of the 

Oil and Gas Extraction Category for the Western Portion of the Outer 

Continental Shelf of the Gulf of Mexico off the Coasts of Louisiana and Texas”, 

GMG290000 (USEPA 2007). This general permit sets prohibitions, limitations 

and monitoring requirements that are established to protect the water quality and 

marine environment. The discharges associated with offshore oil and gas 

exploration and development activities include drilling fluids and cuttings, 

uncontaminated ballast water, uncontaminated seawater, deck drainage, sanitary 

wastes, domestic wastes, and other miscellaneous discharges (excess cement 

slurry, blowout preventer control fluid, uncontaminated freshwater and saltwater, 

etc.). Discharges associated with oil and gas production activities include deck 

drainage, produced water, domestic wastes, sanitary waste water, and 

miscellaneous discharges (uncontaminated seawater, subsea wellhead 

preservation fluids, subsea production control fluids and hydrate control fluids). 

Discharges associated with support vessels must comply with United States Coast 

Guard (USCG) regulations found at 33 CFR 140, 33 CFR 151 and 33 CFR 159. 

The purpose of these regulations is to promote safety of life and property on OCS 

facilities, vessels, and other units engaged in OCS activities and to protect water 

quality and the marine environment. These regulations incorporate and implement 

the OCSLA, Shore Protection Act of 1988, and the Act to Prevent Pollution from 

Ships of 1980 as amended, including Annexes I, II, and V of the International 

Convention for the prevention of Pollution from Ships (MARPOL 73/78). 

Impact Analysis - IPFs that could result in water quality degradation from the 

proposed operations at Keathley Canyon Block 93 include operational effluents 

(discharges) and accidents. Refer to Section 5.0 of the EP for a list of operational 

discharges associated with this operation. 

Operational discharges could impact water quality in the immediate vicinity of the 

point of discharge (less than 100 m regulatory mixing zone boundary). However, 

any constituents found in these discharges are expected to disperse and dilute 

rapidly to very near background levels in the water column when discharged in 

the open GOM (USDOI MMS 2000). Additionally, all effluents discharged are 

expected to be in compliance with the current NPDES General Permit 

GMG290000, thereby eliminating significant biological or ecological effects. 

Further, the U. S. Environmental Protection agency (USEPA) has stated that 

discharges in compliance with the NPDES Permit, GMG290000 will not cause 

unreasonable degradation of the water quality and the marine environment 

(USEPA 2004). Therefore, operational effluent discharges are not expected to 

have a significant impact to water quality. 
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Support vessels may discharge treated sanitary wastes, deck drainage, ballast 

water, bilge water and domestic wastes. These discharges could impact water 

quality in the immediate vicinity of the point of discharge. However, any 

constituents found in these discharges are expected to disperse and dilute rapidly 

to very near background levels in the water column when discharged in the open 

GOM (USDOI MMS 2000). All discharges from support vessels are expected to 

be in compliance with USGC regulations found at 33 CFR 140, 33 CFR 151 and 

33 CFR 159, thereby eliminating significant effects to biological, ecological and 

water quality resources. Additionally, BP contractual agreements with vessel 

owner/operators require support vessel discharges to comply with all applicable 

USCG regulations. Therefore, support vessel discharges are not expected to have 

significant impacts to water quality. 

Following the 2010 Macondo incident, there is a large amount of ongoing 

research and studies being conducted on the impacts to water quality from an oil 

spill and potential deepwater “plumes” or “clouds” of dispersed oil. For example, 

Terry Hazen with the Lawrence Berkeley National Laboratory (Berkley Lab) 

operated by the University of California is studying the impacts and fate of 

deepwater oil plumes. An initial study result suggests that the potential exists for 

rapid intrinsic bioremediation (bacterial degradation) of sub-sea dispersed oil in 

the water column by deep-sea indigenous microbial activity without significant 

oxygen depletion (Hazen et al. 2010). Other studies lead by David Valentine 

(University of California, Santa Barbara) and John Kessler (Texas A&M 

University) are studying the effects of deepwater dissolved hydrocarbon gases 

(e.g. methane, propane and ethane) and effects to microbial response to a 

deepwater oil spill. Initial study results suggest deepwater dissolved hydrocarbon 

gases may promote rapid hydrocarbon respiration by low-diversity bacterial 

blooms, and thus priming indigenous bacterial populations for rapid hydrocarbon 

degradation of sub-sea oil plumes (Kessler et al. 2011; Valentine et al. 2010). 

These and other studies are ongoing and more data will be generated, analyzed, 

and final conclusions made. As more information from these studies is made 

publicly available the impacts to water quality from oil spills and potential 

deepwater plumes will be addressed and analyzed accordingly by the scientific 

community. Results to date suggest that sub-surface concentrations of 

hydrocarbons may be more rapidly degraded by biological means than was 

previously anticipated. 

During a spill or well blowout, the water quality of marine waters could be 

impacted. The extent of such impacts will vary depending on, among other 

factors, the magnitude and duration of such an incident. Implementation of new 

BOEMRE environmental and safety regulations may further reduce the 

probability of the occurrence of a large volume/long duration spill. No significant 

impact is expected to water quality. 

3.1.7 Fisheries 

Affected Resource – Most fishes inhabiting the GOM, whether benthic or pelagic 

as adults, have pelagic larval stages. For various lengths of time (10-100 days 

depending on the species), the pelagic eggs and larvae become part of the 
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planktonic community. Variability in survival and transport of pelagic larval 

stages is thought to be an important determinant of future year-class strength in 

adult populations of fishes and invertebrates (Underwood and Fairweather 1989; 

Doherty and Fowler 1994). In general, the distribution of fish larvae depends on 

spawning behavior of adults, hydrographic structure at a variety of scales, 

duration of the pelagic period, behavior of larvae, and larval mortality and growth 

(Leis 1991). Richards (1990) estimates that there are 200 families with more than 

1,700 species whose early life stages may occur in the GOM. 

Approximately 46 percent of the southeastern U. S. wetlands and estuaries 

important to fish resources are located within the GOM (Mager and Ruebsamen 

1988). From the shoreline to a depth of about 20 m, the fish fauna is dominated 

by sea catfishes (Ariidae), lizardfishes (Synodontidae), and sciaenids (drums, 

seatrout, kingfish and others) (McEachran and Fechhelm 1998). These fish are 

very dependent on estuaries as nursery grounds (Darnell and Soniat 1979; Darnell 

1988). Out to a depth of 40-50 m, on muddy bottoms, the fish fauna is dominated 

by porgies (Sparidae), batfishes (Ogcocephalidae), sea-robins (Triglidae) sea 

basses (Serranidae), and left-eyed flounders (Bothidae). These species are also 

largely dependent on estuaries as nursery grounds. On shell or hard bottoms in 

the same depth range (20 to 40 or 50 m), a slightly different species group occurs 

dominated by snappers (Lutjanidae) and other spiny-rayed fishes with a 

preference for hard substrate (McEachran and Fechhelm 1998). 

The remaining OCS, ranging to a depth of approximately 200 m (656 ft), 

generally has a muddy or silty soft bottom and dominated by hakes (Phycidae), 

scorpionfishes (Scorpaenidae), and ogcocephalids (batfishes) (McEachran and 

Fechhelm 1998). 

Pelagic fishes occurring from the beach to the open ocean, portioned only by 

temperature, salinity and turbidity (Hoese and Moore 1977) are divided into 

coastal pelagic species, oceanic pelagic species, mesopelagic species, and 

bathypelagic species. Coastal pelagic species traverse shelf waters of the region 

throughout the year. The major coastal pelagic families occurring in the region 

are Carcarhinidae (requiem sharks), Elopidae (ladyfish), Engraulidae (anchovies), 

Clupeidae (herrings), Scombridae (mackerels and tunas), Carangidae (jacks and 

scads), Mugilidae (mullets), Pomatomidae (bluefish), and Rachycentridae (cobia) 

(FishBase 2006). 

Oceanic pelagic species such as tuna occur throughout the GOM, especially at or 

beyond the shelf edge and are reportedly associated with hydrographic features 

such as fronts, eddies, and discontinuities (Power and May 1991). The 

occurrence of bluefin tuna larvae in the GOM is evidence that these species 

spawn in the GOM (Richards et al. 1989). Many of the oceanic fishes associate 

with drifting Sargassum, which provides forage areas and/or nursery refuge. 

Mesopelagic fish assemblages in the GOM include myctophids (lanternfishes), 

with gonostomatids (bristlemouths) and sternoptychids (hachetfishes). These 

fishes make extensive vertical migrations during the night from mesopelagic 

depths (200-1,000 m or 656-3,281 ft) to feed in higher, food-rich layers of the 
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water column (Hopkins and Baird 1985). Mesopelagic fishes are important 

ecologically because they transfer substantial amounts of energy between 

mesopelagic and epipelagic zones over each diel cycle. 

The deeper dwelling bathypelagic fishes inhabit the water column at depths 

greater than 1,000 m (3,281 ft) and seldom migrate into shallower waters. This 

zone receives no sunlight and temperatures range from 4° Celsius (C) to 10°C. 

Common species include deep-sea angler fishes (Ceratioidei), gonostomatids 

(bristlemouths or lightfishes) and scaleless black dragonfishes (Melanostomiidae) 

(McEachran and Fechhelm 1998). 

The Gulf sturgeon (Acipenser oxyrinchus desotoi) is the only listed threatened 

fish species in the GOM that inhabits major rivers and inner shelf waters from the 

Mississippi River to the Suwannee River, Florida (Barkuloo 1988). Gulf 

sturgeons are bottom suction feeders that have ventrally located, highly extrusible 

mouths. Fishes that forage by taste are opportunistic feeders because smell is 

much more discriminating than taste. Another adaptation of sturgeon to major 

rivers and offshore waters is mobility (an adaptation to the large habitat scale). 

The decline of the Gulf sturgeon is believed to be due to overfishing and habitat 

destruction, primarily the damming of coastal rivers and the degradation of water 

quality (Barkuloo 1988). 

The Gulf sturgeon critical habitat occurs in the estuarine and riverine locations 

along the Gulf coast east of the Mississippi River in Louisiana, Mississippi, 

Alabama, and Florida. Critical habitat is defined as special geographic areas that 

are essential for the conservation of a threatened and endangered species, and that 

may require special management and protection. Designated Gulf Sturgeon 

habitat is confined to state waters. 

The endangered smalltooth sawfish (Pristus pectinata) was historically common 

throughout the GOM. The current range of the smalltooth sawfish is peninsular 

Florida and common only to the everglades. The current designated critical 

habitat for the smalltooth sawfish is two areas along the southwest coast of 

Florida (http://www.nmfs.noaa.gov/pr/species/fish/smalltoothsawfish.htm). 

The Center for Biological Diversity (CBD) petitioned the National Marine 

Fisheries Service (NMFS), on May 24, 2010 requesting that the Atlantic bluefin 

tuna (Thunnus thynnus), an Atlantic bluefin tuna distinct population segment 

(DPS) consisting of one or more subpoplations in the U. S. waters, or the entire 

species be listed as endangered or threatened under the ESA. The petition also 

requested that critical habitat be designated for the species. The NMFS appointed 

an Atlantic bluefin tuna status review team (SRT) to assess the species status. 

After an extensive scientific review by the SRT including comments from invited 

Atlantic bluefin tuna experts and five listening sessions with Atlantic bluefin tuna 

fishermen it was announced on May 27, 2011 that Atlantic bluefin tuna currently 

do not warrant species protection under the Endangered Species Act (ESA) 

(Atlantic Bluefin Tuna Status Review Team 2011). The NMFS has committed to 

revisit this decision by early 2013, when more information will be available 
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(http://www.nmfs.noaa.gov/stories/2011/05/bluefin_tuna.html and http://www. 

noaanews.noaa.gov/stories2011/20110527_bluefintuna .html). 

Impact Analysis – IPFs that could affect fisheries include drilling rig and support 

vessel presence (noise and lights), effluent discharges, cooling water intakes, and 

accidents. Fish may be attracted to the drilling rig, as a floating structure in the 

deepwater environment. Epipelagic fishes such as tunas, dolphin, billfishes, and 

jacks, are commonly attracted to fixed and drifting surface structures (e.g., 

Holland et al. 1990; Higashi, 1994; Relini et al. 1994). The feeding of epipelagic 

predators could be enhanced by attracting and concentrating smaller fish species. 

The drilling rig is a single, temporary structure; therefore, impacts on fish 

populations, whether beneficial or adverse, would be considered insignificant. 

Discharges associated with the proposed action to marine waters are muds and 

cuttings resulting from drilling activities (refer to Section 3.1.6, Water Quality for 

additional information). The plume is expected to disperse rapidly, is very near 

background levels at a distance of 1,000 m (3,281 ft), and is usually undetectable 

at distances greater than 3,000 m (9,843 ft) (USDOI MMS 2002 and 2007a). No 

significant impact is expected. 

Cooling Water Intakes Structures (CWIS) on new offshore facilities are regulated 

by Section 316(b) of the Clean Water Act. The West Sirius drilling rig is not 

considered a new facility and therefore NPDES permit (GMG290000) design 

requirements for CWIS are not applicable. Regardless, no significant entrainment 

or impingement impact on key species is expected based on the findings of the 

2009 desktop CWIS Source Water Biological Baseline Characterization Study, as 

required in the NPDES permit, Part I.B.12.a. 

A well blowout scenario could introduce oil to surface or subsurface waters. 

Behavior science associated with adult fish indicate that they would likely avoid 

the area of a spill, but fish eggs and larvae within the spill area of the northern 

GOM could be killed (USDOI MMS 2002 and 2007a). 

Regardless of spill size, adult fish are likely to actively avoid an oil spill, thereby 

limiting the effects and lessening the extent of damage (Baker et al. 1991; Malins 

et al. 1982). Observations at oil spills around the world, including the Exxon 

Valdez spill in Prince William Sound, indicate that free-swimming fish ordinarily 

avoid harm from oil spills (NRC 1985). Some work has demonstrated avoidance 

of extremely small concentrations of hydrocarbons. Farr et al. (1995) reported the 

behavioral avoidance of dissolved concentrations of a polycyclic aromatic 

hydrocarbon (PAH) as low as 14.7 micrograms per liter (μg/l) by a species of 

minnow. 

Adult fish must experience continual exposure to relatively high levels of 

hydrocarbons over several months before secondary toxicological compounds that 

represent biological harm are detected in the liver (Payne et al. 1988). The direct 

effects of spilled oil on fish occur through the ingestion of oil or oiled prey and 

through the uptake of dissolved petroleum products through the gills and 

epithelium by adults and juveniles (NRC 1985). Upon exposure to spilled oil, 

liver enzymes of fish oxidize soluble hydrocarbons into compounds that are easily 
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excreted in the urine (Spies et al. 1982). Ordinary changes in salinity, 

temperature, and food abundance (Evans and Rice 1974; NRC 1985) have little 

effect. Migratory species could be impacted if oil spills covered large areas of 

nearshore open waters. One of the few adult fish-kills on record following an oil 

spill was on the French coast in 1978 when several tons of small rock-clinging 

fish (not commercially harvested) were killed at the site of the Amoco Cadiz 

wreck (USDOI MMS 2002). 

For OCS-related oil spills to have a substantial effect on a commercial fishery 

resource, whether estuary dependent or not, eggs and larvae would have to be 

concentrated in the immediate spill area. This area could be very large 

considering the maximum blowout discharge volume. Oil components also 

would have to be present in highly toxic concentrations when both eggs and 

larvae are in the pelagic stage (Longwell 1977). When eggs and larvae are 

exposed to spilled oil in the water column, the success of a spawning event may 

be reduced (USDOI BOEMRE 2011b). The effect is expected to be lethal for 

eggs and larvae that contact spilled oil (USDOI BOERME 2011b). However, fish 

overproduce eggs on an enormous scale and the overwhelming majority of them 

die at an early stage, generally as food for predators. It is likely that even a heavy 

death toll from a single large oil spill would not have a long lasting effect on the 

adult populations that are exploited by commercial fisheries (USDOI MMS 

2002). This has been confirmed during and after the Torrey Canyon spill off 

Southwest England and the Argo Merchant spill off Nantucket. In both cases, a 90 

percent death of fish eggs and larvae, pilchard and pollack, respectively, was 

observed in the affected area, but this had no impact on the regional commercial 

fishery (Baker et al. 1991). 

 It was noted in the Final Supplemental EIS (USDOI MMS 2008b) that BOEMRE 

has reexamined the analysis for Gulf sturgeon presented in the Multisale EIS 

(USDOI MMS 2007a), and concluded that an area nearly 130 mi (209 km) from 

the nearest coast, and not located within designated critical habitat for Gulf 

sturgeon, that it was unlikely there will be any sturgeon in the area due to water 

depths that far exceed the recorded depths preferred by Gulf sturgeon. 

Additionally, substrate type and potential forage base associated with bottom 

types at these depths are not conducive for sustaining a Gulf sturgeon forage base. 

Therefore, because of the floating nature of oil and the small tidal range of the 

GOM, oil spills alone would typically have very little impact on benthic feeders 

such as the Gulf sturgeon. 

Implementation of new BOEMRE environmental and safety regulations may 

further reduce the probability of the occurrence of a large volume/long duration 

spill. No significant impact is expected to fishery resources. 

3.1.8 Marine Mammals 

Affected Resource – Twenty-eight cetacean (whales and dolphins) and one 

sirenian (manatee) species have confirmed occurrences in the GOM. Cetaceans 

are divided into two major suborders: Mysticeti (i.e., baleen whales) and 

Odontoceti (i.e., toothed whales, dolphins and their allies). Of the seven baleen 
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whale species occurring in the GOM, five are listed as endangered or threatened 

(northern right [Eubalaena glacialis], blue [B. musculus], fin [B. physalus], sei [B. 

borealis], and humpback [Megoptera novaeangliae]). Of the 21 toothed species 

occurring in the GOM, only the sperm whale (Physeter macrocephalus), is listed 

as endangered. The only member of the Order Sirenia found in the GOM is the 

endangered West Indian manatee (Trichechus manatus). All marine mammals are 

protected species under the MMPA. There are no critical habitats designated 

within the offshore GOM for the threatened and endangered species of mammals 

listed above. 

The GOM Cetacean Program (GulfCet) I study showed that several poorly known 

species are moderately common (beaked whales [Meoplodon and Ziphius sp.], 

pygmy and dwarf sperm whales [Kogia sp.], melon-headed whale 

[Peponocephala sp.], and Fraser’s [Lagenodelphis sp.] and Clymene dolphins 

[Stenella sp.]). The GulfCet II Study (surveys conducted 1996-1997), 

administered by the U.S. Geological Survey, Biological Resources Division (BRD 

1999), continued work on patterns of distribution and abundance of GOM 

cetaceans and identified possible associations between high-use habitats and the 

ocean environment (Davis et al. 2000). 

Within the northern GOM, many of the environmental and biotic factors 

influencing the distribution of cetaceans are affected by various hydrological 

circulation patterns. River discharge, wind, and the loop current generally drive 

these patterns. Most of the river discharge into the northern GOM is transported 

west and along the coast. Circulation on the continental shelf is largely winddriven, with localized effects from freshwater (i.e., riverine) discharge (Mullin et 

al. 1994; Davis et al. 2000). 

Studies conducted during the GulfCet I and GulfCet II programs demonstrated a 

correlation of cetacean distribution patterns with certain geomorphic features such 

as seafloor depth or topographic relief. These studies suggested that seafloor 

depth was the most important variable in habitat partitioning among cetacean 

species in the northern GOM (Baumgartner 1995; Davis et al. 1998 and 2000; 

Mullin et al. 1994; Jefferson 1995). 

The West Indian manatee (Trichechus manatus) is the only sirenian known to 

occur in tropical and subtropical coastal waters of the southeastern GOM, 

Caribbean Sea, and the Atlantic coast of northern and northeastern South America 

(Reeves et al. 1992; Jefferson et al. 1993; O’Shea et al. 1995). There are two 

subspecies of the West Indian manatee: the Florida manatee (T. m. latirostris). 

During warmer months, manatees are common along the west coast of Florida 

from the Everglades National Park northward to the Suwannee River in 

northwestern Florida. In winter, the population moves southward to warmer 

waters. The winter range is restricted to smaller areas at the southern tip of 

Florida and to waters near localized warm-water sources. Crystal River, in Citrus 

County, is typically the northern limit of the manatee’s winter range on the Gulf 

coast. Manatees are uncommon along the Florida Panhandle and are infrequently 

found (strandings and sightings) as far west as Louisiana and Texas (Powell and 

Rathbun 1984; Rathbun et al. 1990; Schiro et al. 1998). 
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Impact Analysis – IPFs that could affect marine mammals include drilling rig 

and installation/support vessel presence (noise and lights), effluent discharges, 

accidents and loss of debris. 

Sound from drilling activities, installation/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 

vulnerable to parasites, disease, environmental contaminants, and/or predation 

(Majors and Myrick 1990). There is little conclusive evidence for long-term 

displacements and population trends for marine mammals relative to sound; 

therefore, no significant impact is expected. 

Discharges associated with the proposed action to marine waters are muds and 

cuttings resulting from drilling activities (refer to Section 3.1.6, Water Quality for 

additional information). The plume is expected to disperse rapidly, is very near 

background levels at a distance of 1,000 m (3,281 ft), and is usually undetectable 

at distances greater than 3,000 m (9,843 ft) (USDOI MMS 2002 and 2007a). No 

significant impact is expected. 

Oil spills could affect marine mammals through various pathways: surface 

contact, inhalation, ingestion, and baleen fouling (Geraci 1990). Direct contact 

with oil for marine mammals can lead to irritation and damage of skin and soft 

tissues (such as mucous membranes of the eyes). In cetaceans, fouling of baleen 

plates can occur so as to hinder the flow of water and interfere with feeding, and 

incidental ingestion of oil and/or tar. Studies by Geraci and St. Aubin (1982) have 

shown that the cetacean epidermis functions as an effective barrier to noxious 

substances found in petroleum. 

Crude oil or volatile distillates release toxic vapors that, when inhaled, can lead to 

irritation of respiratory membranes, lung congestion, and pneumonia. Subsequent 

absorption of volatile hydrocarbons into the bloodstream may accumulate into 

such tissues as the brain and liver, causing neurological disorders and liver 

damage (Geraci and St. Aubin 1982; Hansen 1985; Geraci 1990). Toxic vapor 

concentrations just above the water’s surface (where cetaceans draw breath) may 

reach critical levels for the first few hours after a spill, prior to evaporation and 

dispersion of volatile aromatic hydrocarbons and other light components (Geraci 

and St. Aubin 1982). Cetaceans may consume oil contaminated prey (Geraci 

1990) or incidentally ingest oil (USDOI MMS 2007a). Studies have been 

completed with varying results whether marine mammals avoid spilled oil 

(USDOI BOERME 2011b). In some cases, marine mammals have been shown to 

detect and avoid oil slicks (Geraci and St. Aubin 1990), while other reports 

indicate marine mammals did not attempt to avoid spilled oil (Smultea and Würsig 

1995). Other studies are ongoing and more data will be generated, analyzed, and 

final conclusions made. 

There have been no experimental studies and only a handful of observations 

suggesting that oil has harmed any manatees or dugongs (St. Aubin and 

Lounsbury 1990). Direct contact with discharged oil probably does not impact 

adult manatees’ thermoregulatory abilities because they use blubber for insulation 
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(USDOI MMS 2008b). Manatees are nonselective, generalized feeders that might 

consume tarballs along with their normal food; such occurrences have been rarely 

reported (review in St. Aubin and Lounsbury 1990). 

Implementation of new BOEMRE environmental and safety regulations may 

further reduce the probability of the occurrence of a large volume/long duration 

spill. No significant impact is expected. 

Another factor of concern is the lack of ability that cetaceans (more specifically, 

sperm whales) possess for detecting and avoiding the various flowlines, risers, 

umbilicals, and mooring lines (USDOI MMS 2002 and 2007a). Sperm whales are 

known to get entangled in deep-sea cables (Heezen 1957). Sperm whales are one 

of 11 whale species that are hit commonly by ships (Laist et al. 2001). Collisions 

between cetaceans and ships could cause serious injury or death (Laist et al. 

2001). Collisions between OCS vessels and cetaceans in the project area are 

expected to be unusual events. Compliance with NTL 2007-G04 is expected to 

result in no significant impact. Refer to Section 1.0 for additional information. 

Entanglement and ingestion of debris have caused death or serious injury to 

marine mammals (Laist 1997). Compliance with NTL 2007-G03 is expected to 

result in no significant impact. Refer to Section 1.0 for additional information. 

3.1.9 Sea Turtles 

Affected Resource – Five species of sea turtle are found in the waters of the 

GOM: Kemp’s ridley (Lepidochelys kempi), loggerhead (Caretta caretta), green 

(Chelonia mydas), leatherback (Dermochelys coriacea), and hawksbill 

(Eretmochelys imbricate). All are protected under the ESA; and all except the 

loggerhead turtle (threatened) are listed as endangered. Sea turtles spend nearly all 

of their lives in the water. Females must emerge periodically from the ocean to 

nest on beaches. Sea turtles are long-lived, slow-reproducing animals. It is 

generally believed that all sea turtle species spend the first few years of their lives 

in pelagic waters, occurring in driftlines and convergence zones (in sargassum 

rafts) where they find refuge and food in items that accumulate in surface 

circulation features (Carr 1987). No critical habitat has been designated for these 

species in the Gulf of Mexico. 

Adult turtles in the GOM are apparently less abundant in the deeper waters of the 

GOM than they are in waters less than 27-50 m (80-160 ft) deep (NRC 1990). 

More sea turtles are sighted in the northeastern GOM than in the northwestern 

GOM (Thompson 1999). Sea turtle abundance in the GOM appears to increase 

dramatically east of Mobile Bay (Davis et al. 2000). Factors such as water depth, 

bottom sediments, and prey availability may account for this. In the offshore 

GOM, sea turtle distribution has been linked to zones of convergence. 

GulfCet II studies sighted most loggerhead, Kemp’s ridley and leatherback sea 

turtles over shelf 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 species as a transitory habitat. 
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The green turtle has a global distribution in tropical and subtropical waters. 

Important feeding areas for green turtles in Florida include the Indian River, 

Florida Bay, Homosassa River, Crystal River, and Cedar Key (USDOC NMFS 

1993). Green turtles in the western GOM are primarily restricted to the lower 

Texas coast where seagrass meadows and algae-laden jetties provide 

developmental habitat, especially during warm months (Landry and Costa 1999). 

The leatherback is the most pelagic and most wide-ranging of sea turtles, 

undertaking extensive migrations following depth contours for hundreds, even 

thousands, of kilometers (Morreale et al. 1996; Hughes et al. 2001). It is 

commonly found in relatively shallow continental shelf waters along the U.S. 

Atlantic coast (Hoffman and Fritts 1982; Knowlton and Weigle 1989; Shoop and 

Kenney 1992) and northern GOM (Leary 1957; Fritts et al. 1983a; Lohoefener et 

al. 1988, 1990; Collard 1990; Davis et al. 2000). 

The hawksbill occurs in tropical and subtropical seas of the Atlantic, Pacific, and 

Indian Oceans. The species is widely distributed in the Caribbean Sea and western 

Atlantic Ocean. The species is recorded from all the GOM States and from along 

the eastern seaboard as far north as Massachusetts, with the exception of 

Connecticut; however, sightings north of Florida are rare (USDOC NMFS 1993). 

Texas and Florida are the only states where hawksbills are sighted with any 

regularity (USDOC NMFS 1993). 

The Kemp’s ridley is the most imperiled in the GOM. In the GOM, Kemp’s 

ridleys inhabit nearshore areas, being most abundant in coastal waters from Texas 

to west Florida (Ogren 1989; Marquez 1990 and 1994; Rudloe et al. 1991). 

Kemp’s ridleys display strong seasonal fidelity to tidal passes and adjacent 

beachfront environs of the northern GOM (Landry and Costa 1999). 

The loggerhead sea turtle occurs throughout the inner continental shelf from 

Florida through Cape Cod, Massachusetts (Dodd 1988; Plotkin et. al 1993; Fritts 

and Reynolds 1981; Fritts et al. 1983a; Davis et al. 2000). Aerial surveys indicate 

that loggerheads are largely distributed in water depths less than 100 m (328 ft) 

(Shoop et al. 1981; Fritts et al. 1983a; Davis et al. 2000). 

Impact Analysis – IPFs that could affect sea turtles include drilling rig and 

installation/support vessel presence (noise and lights), effluent discharges, 

accidents, and loss of debris. 

Disturbance (e.g., noise) and/or exposure to sublethal levels of biotoxins and 

anthropogenic contaminants may stress animals, weaken their immune systems, 

and make them more vulnerable to parasites and diseases that normally would not 

be fatal (USDOI MMS 2002, 2007a and 2008b). Sound from drilling activities, 

installation/support vessels, and helicopters may elicit a startle reaction from sea 

turtles, but this is a temporary disturbance. No significant impact is expected to 

sea turtles. 

Discharges associated with the proposed action to marine waters are muds and 

cuttings resulting from drilling activities (refer to Section 3.1.6, Water Quality for 

additional information). The plume is expected to disperse rapidly, is very near 
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background levels at a distance of 1,000 m (3,281 ft), and is usually undetectable 

at distances greater than 3,000 m (9,843 ft) (USDOI MMS 2002 and 2007a). Any 

potential impact would be indirect, either as a result of impacts on prey items or 

possibly through ingestion in the food chain (API 1989). No significant impact is 

expected to sea turtles. 

Sea turtle habitat in the GOM includes inshore, coastal, and oceanic waters, as 

well as numerous beaches in the region, sea turtles could be impacted by 

accidental spills (USDOI MMS 2002 and 2007a). Depending on the timing of the 

spill’s occurrence in coastal waters, its impact and resulting cleanup may interrupt 

sea turtle migration, feeding, mating, and/or nesting activity for extended periods 

(days, weeks, months) (USDOI MMS 2007a). Exposure to hydrocarbons 

persisting in the sea following an oil slick may result in sublethal and lethal 

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

vulnerability to disease) to sea turtles (USDOI MMS 2002, 2007a). Sea turtle 

hatchling exposure to, fouling by, or consumption of tarballs persisting in the sea 

following the dispersal of an oil slick would likely be fatal (USDOI MMS 2002, 

2007a). The net result of any disturbance would depend on the size and 

percentage of the population affected, ecological importance of the disturbed area, 

environmental and biological parameters that influence an animal’s sensitivity to 

disturbance and stress, and the accommodation time in response to prolonged 

disturbance (St. Aubin 2001). Implementation of new BOEMRE environmental 

and safety regulations may further reduce the probability of the occurrence of a 

large volume/long duration spill. No significant impact is expected to sea turtles. 

Collisions between OCS vessels and sea turtles within the project area are 

expected to be unusual events (Laist et al. 2001). Compliance with NTL 2007-

G04 is expected to result in no significant impact. Refer to Section 1.0 for 

additional information. 

Entanglement in, and ingestion of, debris has caused the death or serious injury of 

sea turtles (Balazs 1985). Compliance with NTL 2007-G03 is expected to result 

in no significant impact. Refer to Section 1.0 for additional information. 

3.1.10 Air Quality 

Affected Resource - Winds in the region are driven by the clockwise circulation 

around the Bermuda High (USDOI MMS 2007a). The Gulf of Mexico is located 

to the southwest of this center of circulation, resulting in a prevailing 

southeasterly to southerly flow, which is conducive to transporting emissions 

toward shore. This circulation is affected by tropical cyclones (hurricanes) during 

summer and fall and by extratropical cyclones (cold fronts) during winter. The air 

over the OCS water is not classified, but it is presumed to be better than the 

National ambient Air Quality Standards (NAAQS) for all criteria pollutants 

(USDOI MMS 1997). 

The proposed activities have the potential to emit particulate matter (PM), Sulfur 

Oxides (SOx), Nitrogen Oxides (NOx), Volatile Organic Compounds (VOC), and 

Carbon Monoxide (CO) during operations. Combustion engines (located on 
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drilling rig and installation/support vessels) emit the majority of the emissions 

during a drilling operation. 

Impact Analysis – IPFs for offshore air pollutant emissions will result from the 

drilling rig operations, helicopters and service vessels and an accidental release. 

Emissions occur mainly from combustion or burning of diesel fuel. The 

combustion of fuels occurs primarily on generators, pumps, or motors and from 

lighter fuel motors. Primary air pollutants typically associated with OCS 

activities are suspended PM, SOx, NOx, VOCs, and CO. The proposed activities 

are located approximately 172.4 miles from the nearest shoreline. Due to the 

distance from shore‐based pollution sources, offshore air quality is expected to be 

good. Emissions from the proposed activities have been projected and are below 

the BOEMRE exemption levels (See Section 7.0 of the EP for additional 

information). There would be a limited degree of air quality impacts in the 

immediate vicinity of the proposed activities. Air emissions will be emitted by 

the MODU during drilling and by support vessels. 

The projected air emissions are not expected to affect the air quality of the OCS 

primarily due to distance from the shore or to any Prevention of Significant 

Deterioration (PSD) Class I air quality area such as the Breton Wilderness Area. 

Keathley Canyon Block 93 is about 526 km (327 mi), which is beyond the 200 

km (124 mile) buffer for the Breton Wilderness Area. During the recent Macondo 

event extensive air sampling conducted by the USEPA found no evidence of 

onshore levels of contaminants that are of significant concern for the long term 

health of residents of coastal communities (www.epa.gov/bpspill/air.html and 

www.epa.gov/bpspill/air-mon.html). 

Accidents and blowouts can release hydrocarbons or chemicals, which could 

cause the emission of air pollutants. However, these releases are not expected to 

impact onshore air quality because of the prevailing atmospheric conditions, 

emission height, emission rates, and the distance of Keathley Canyon Block 93 

from the coastline. Implementation of new BOEMRE environmental and safety 

regulations may further reduce the probability of the occurrence of a large 

volume/long duration spill. No significant impact is expected to air quality. 

3.1.11 Shipwreck Sites (known or potential) 

Affected Resource – A historic shipwreck is defined as a submerged or buried 

vessel, at least 50 years old, that has foundered, stranded, or wrecked and is 

presently lying on or embedded in the seafloor including vessels that exist intact 

or as scattered components on or in the seafloor. Several studies (Garrison et al. 

1989; Pearson et al. 2003) have been conducted to model areas in the GOM where 

historic shipwrecks were most likely to exist. A study in 1977 concluded that 

two-thirds of the total number of shipwrecks in the northern GOM lie within 1.5 

km (1 mi) of shore and most of the remainder lie between 1.5 and 10 km (1 and 6 

mi) of the coast (CEI 1977). In 1989 a study found that frequency of shipwrecks 

in the open sea of the Eastern GOM to nearly double that of the Central and 

Western GOM (Garrison et al. 1989). The highest observed frequencies of 

shipwrecks were within areas of intense marine traffic, such as the approaches 
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and entrances to seaports and the mouths of navigable rivers and straits. The most 

recent study in 2003 used about 15 years of high-resolution shallow hazard 

surveys in lease blocks and along pipeline routes. Some of these surveys (almost 

exclusively for pipeline routes) were conducted in deep water. Several of these 

pipeline hazard surveys succeeded in locating historic ships, ranging in age from 

an 18th-century armed sailing ship to a World War II German U-boat. 

In addition to the above studies, historic shipwrecks have, to date, been 

discovered through oil industry sonar surveys in water depths up to 1,981 m 

(6,500 ft). Over a dozen shipwrecks have been located in deep water and nine of 

these ships have been confirmed visually as historic vessels. Many of these 

wrecks were not previously known to exist in these areas from the historic record. 

Taking these discoveries into account, the 2003 study then recommended 

including some deepwater areas, primarily on the approach to the Mississippi 

River, among those lease areas requiring archaeological investigation. Because of 

this, BOEMRE revised its guidelines for conducting archaeological surveys and 

added about 1,200 lease blocks to the list of blocks requiring an archaeological 

survey and assessment (NTL 2005-G07 and NTL 2008-G20). Since 

implementation of these new lease blocks there have been at least 10 possible 

historic shipwrecks reported in this area. Pearson et al. (2003) lists numerous 

shipwrecks that fall within the CPA and WPA. Most of these wrecks are known 

only through the historical record and, to date, have not been located on the ocean 

floor. The BOEMRE Shipwreck Database lists 911 wrecks in the CPA and 494 

wrecks in the WPA (USDOI MMS 2007a; USDOI BOERME 2011b). 

Impact Analysis – IPFs for shipwrecks will result from accidental releases. The 

lease blocks within Keathley Canyon Block 93 are not stipulated as requiring 

archaeological resource surveys and reports (NTL 2005-G07 and 2008-G20). A 

review of the Shallow Hazards Assessment for Gila Prospect, Keathley Canyon 

(Fugro 2010) indicates there is no known or potential shipwreck sites located 

within the survey area. Should BP discover man-made debris that appears to 

indicate the presence of a shipwreck within or adjacent to the Gila Project area, 

BP will immediately halt operations. The proposed activities will be done with 

dynamic positioned vessels which do not have associated anchors, anchor chains 

or wire ropes; therefore, no impacts on such sites are expected as a result of the 

proposed operations. 

An accidental release (blowout) at the seafloor could create a crater and resuspend 

and disperse large quantities of bottom sediments within a 300-m (984-ft) radius 

of the blowout site (USDOI BOEMRE 2011a, 2011b), burying shipwrecks. 

Subsurface spills could result in the formation and settling of oil-saturated 

material, and oil-sediment particles could come into contact with shipwrecks. 

The extent of such impacts will vary depending on, among other factors, the 

magnitude and duration of such an incident. No significant impact is expected to 

shipwrecks. Implementation of new BOEMRE environmental and safety 

regulations may further reduce the probability of the occurrence of a large 

volume/long duration spill. 
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3.1.12 Prehistoric Archaeological Sites 

Affected Resource – Archaeological resources are any material remains of 

human life or activities that are at least 50 years of age and that are of 

archaeological interest (30 CFR 250.105). The Archaeological Resources 

Regulation (30 CFR 250.194) provides specific authority to each BOEMRE 

Regional Director to require archaeological resource surveys, analyses, and 

reports. Surveys are required prior to any exploration or development activities 

on leases within areas determined to have a high potential for archaeological 

resources (NTL 2005-G07 and NTL 2008-G20). 

Available evidence suggests that sea level in the northern GOM was at least 90 m 

(295 ft), and possibly as much as 130 m (427 ft), lower than present sea level 

during the period 20,000-17,000 years before present (Nelson and Bray 1970). 

Sea level in the northern GOM reached its present stand around 3,500 years 

before present (Pearson et al. 1986). 

The arrival of early man into the GOM region is accepted to be around 12,000 

years before present (Aten 1983). Sea-level for the northern GOM would have 

likely been approximately 45-60 m (148-197 ft) below the present day sea level 

(CEI 1977 and 1982). The continental shelf shoreward of the 45 to 60 m (148 to 

197 ft) bathymetric contours has potential for prehistoric sites dating after 12,000 

years before present. Due to uncertainties in both the depth of sea level and the 

entry date of prehistoric man into North America, BOEMRE adopted the 60 m 

(197 ft) water depth as the seaward extent for archaeological site potential in 

GOM. 

Geomorphic features that have a high potential for associated prehistoric sites 

include barrier islands and back-barrier embayments, river channels and 

associated floodplains and terraces, and salt-dome features. Remote-sensing 

surveys have identified these types of geographic features, which have a high 

potential for associated prehistoric sites. Investigations in Louisiana and Florida 

indicate the mound building activity by prehistoric inhabitants may have occurred 

as early as 6,200 years before present (Hagg 1992; Saunders et al. 1992; Russo 

1992); therefore, manmade features may also exist in the shallow inundated 

portions of the OCS. 

The McFaddin Beach site, east of Galveston in the McFaddin National Wildlife 

Refuge, has produced late Pleistocene megafaunal remains and lithics, including a 

large percentage of Paleo-Indian artifacts (Stright et al. 1999). Five types of relict 

landforms were identified in the Sabine-Calcasieu River Valley and evaluated for 

archaeological potential 1986 (CEI 1986). Surveys from other areas of the 

western part of the CPA have produced evidence of floodplains, terracing, and 

point-bar deposits in association with relict late Pleistocene fluvial systems. 

Prehistoric sites associated with these features would have a high potential for 

preservation. Salt diapirs with bathymetric expression have also been recorded 

during lease-block surveys in this area. Solution features at the crest of these 

domes would have a high potential for preservation of associated prehistoric sites. 

The Salt Mine Valley site on Avery Island is a Paleo-Indian site associated with a 
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salt-dome solution feature (CEI 1977). The proximity of most of these relict 

landforms to the seafloor facilitates further investigation and data recovery. 

Impact Analysis - IPFs for archaeological resources will result from accidental 

releases. Keathley Canyon Block 93 is not stipulated as requiring archaeological 

resource surveys and reports (NTL Nos. 2005-G07 and 2008-G20). A review of 

the Shallow Geohazards Assessment (Fugro 2010) was conducted and indicates 

there are no known or potential archaeological sites located within the survey area. 

Therefore, no impacts on such sites are expected as a result of the proposed 

operations. 

An accidental release (blowout) at the seafloor could create a crater and resuspend 

and disperse large quantities of bottom sediments within a 300-m (984-ft) radius 

of the blowout site (USDOI BOEMRE 2011a, 2011b), burying archaeological 

resources. Subsurface spills could result in the formation and settling of oilsaturated material, and oil-sediment particles could come into contact with 

archaeological resources. The extent of such impacts will vary depending on, 

among other factors, the magnitude and duration of such an incident. No 

significant impact is expected to archaeological resources. Implementation of 

new BOEMRE environmental and safety regulations may further reduce the 

probability of the occurrence of a large volume/long duration spill. 

3.2 Vicinity of Offshore Location 

3.2.1 Essential Fish Habitat 

Affected Resource – An Essential Fish Habitat (EFH) is defined as those waters 

and substrate necessary to fish for spawning, breeding, feeding, and growth to 

maturity. Due to the wide variation of habitat requirements for all life history 

stages, EFH for the GOM includes all estuarine and marine waters and substrates 

from the shoreline to the seaward limit of the Exclusive Economic Zone (EEZ). 

The Magnuson-Stevens Fishery Conservation and Management Act of 1976, as 

amended through 1998, places requirements on any Federal agency with respect 

to EFH, and requires the development of management plans for all managed fish 

species. The Gulf of Mexico Fisheries Management Council (GMFMC) currently 

maintains Fishery Management Plans (FMP) for a variety of bay and estuarine 

species that spend a large part of their life cycles in these nearshore environments. 

Occurrence of these managed species, along with major adult prey species and 

relationships with estuary and bay systems in the Eastern GOM, is outlined in the 

Final EIS for CPA and WPA GOM Multisale Lease Areas (USDOI MMS 2002) 

and Final EIS for WPA and CPA GOM Multisale Lease Areas (USDOI MMS 

2007a and 2008b). 

The GMFMC currently describes FMP’s for the following species in the GOM: 

red grouper (Epinephelus morio), gag grouper (Mycteroperca microlepis), scamp 

grouper (Mycteroperca phenax), red snapper (Lutjanus campechanus), gray 

snapper (Lutjanus griseus), yellowtail snapper (Ocyurus chrysurus), lane snapper 

(Lujanus syngagris), gray triggerfish (Balistes capriscus), greater amberjack 

(Seriola dumerili), lesser amberjack (Seriola fasciata), king mackerel 
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(Scomberomorus cavalla), Spanish mackerel (Scomberomorus maculates), cobia 

(Rachycentron canadum), dolphin fish (Coryphaena hippurus), stone crab 

(Menippe spp.), and spiny lobster (Panulirus spp.). Occurrences of these 

managed species are generally within the estuary and bay systems in the GOM. 

None of the stocks managed by the GMFMC are endangered or threatened. 

Migratory species that are likely to be encountered include tuna (Scombridae), 

billfish (Istiophoridae), swordfish (Xiphiidae), and sharks (Squaliformes). These 

groups are under the direct management of NOAA Fisheries and are not included 

as GMFMC managed species. The EFH areas for these highly migratory species 

are described in separate FMP’s, including the FMP for Atlantic tunas, swordfish, 

and sharks (USDOC NMFS 2009) and the Atlantic billfish FMP Amendment 1 

(USDOC NMFS 1999b). Highly migratory species with EFH at or near the Gila 

project area include the following (USDOC NMFS 2009): 

• Bigeye tuna (juvenile, adult) 

• Atlantic bluefin tuna (spawn, eggs, larvae, adults) 

• Atlantic skipjack tuna (spawn, eggs, larvae, adults) 

• Yellowfin tuna (all) 

• Swordfish (all) 

• Blue marlin (juveniles, adults) 

• White marlin (juveniles, adults) 

• Sailfish (juveniles, adults) 

• Longbill spearfish (juveniles, adults) 

• Great hammerhead shark (all) 

• Tiger shark (adult) 

• Whale shark (all) 

• Longfin mako shark (all) 

• Shortfin mako shark (all) 

• Bigeye thresher shark (all) 

• Common thresher shark (all) 

In addition, NMFS (USDOC NMFS 2009) designated a Habitat Area of Particular 

Concern (HAPC) for spawning Atlantic bluefin tuna, and this covers much of the 

deepwater Gulf of Mexico. 

HAPC include the near shore areas of intertidal and estuarine habitats that may 

provide food and rearing for juvenile fish and shell fish; offshore areas with 

substrates of high habitat value or vertical relief, which serve as cover for fish and 

shell fish; and marine and estuary habitat used for migration, spawning, and 

rearing of fish and shellfish. 

As described by NOAA Fisheries documents (USDOC NMFS 2009), the current 

status of the scientific knowledge of these species is such that habitat preferences 

are largely unknown or are difficult to determine. As in the case with shark 

species, it is difficult to define the habitat of sharks of this temperate zone in the 

GOM because most species are highly migratory, using diverse habitats in 

apparently nonspecific or poorly understood ways. Temperature is a primary 

factor affecting the distribution of sharks, and their movement in coastal waters is 
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usually correlated with unpredictable seasonal changes in water temperature. 

Some of the highly migratory species occurring offshore beyond the 200-m 

isobath, and many, such as billfishes, are associated with upwelling areas where 

canyons cause changes in current flow (upwelling) and create areas of higher 

productivity. 

Impact Analysis - IPFs that could cause impacts to EFH as a result of the 

proposed operations in Keathley Canyon Block 93 include rig presence (noise and 

lights), effluents and accidents. EFH includes all estuarine and marine waters and 

substrates in the GOM. 

Epipelagic fishes such as tunas, dolphin, billfishes, and jacks, are commonly 

attracted to fixed and drifting surface structures (e.g., Holland et al., 1990; 

Higashi, 1994; Relini et al. 1994). The feeding of epipelagic predators could be 

enhanced by attracting and concentrating smaller fish species. The drilling 

operations are temporary. Impacts on fish populations, whether beneficial or 

adverse, would be considered insignificant. 

Discharges associated with the proposed action to marine waters are muds and 

cuttings resulting from drilling activities (refer to Section 3.1.6, Water Quality for 

additional information). The plume is expected to disperse rapidly, is very near 

background levels at a distance of 1,000 m (3,281 ft), and is usually undetectable 

at distances greater than 3,000 m (9,843 ft) (USDOI MMS 2002 and 2007a). No 

significant impact is expected. 

A well blowout scenario could introduce oil to surface or subsurface waters. 

Behavior science associated with adult fish indicates that they would likely avoid 

the area of a spill, but fish eggs and larvae within the spill area of the northern 

GOM could be killed (USDOI MMS 2002, 2007a). 

Marine sanctuaries and national estuary reserves are considered to be HAPC that 

meet these general HAPC guidelines. Further relevant discussion on potential 

EFH impacts from spills can be found in Section 3.1.1, 3.1.2, 3.1.3, 3.1.4, 3.1.5, 

and 3.1.7. 

The extent of such impacts will vary depending on, among other factors, the 

magnitude and duration of such an incident. No significant impact is expected to 

EFH resources. Implementation of new BOEMRE environmental and safety 

regulations may further reduce the probability of the occurrence of a large 

volume/long duration spill. 

3.2.2 Marine and Pelagic Birds 

Affected Resource – The offshore waters, coastal beaches, and contiguous 

wetlands of the northern GOM are populated by both resident and migratory 

species of coastal and marine birds that can be separated into five major groups: 

diving birds, shorebirds, marsh birds, wading birds and water fowl. 

Seabirds are a diverse group of birds that spend much of their lives on or over 

saltwater; they live far from land most of the year, except at breeding time when 

they return to nesting areas along coastlines (Terres 1991). Species diversity and 

overall abundance is highest in the spring and summer and lowest in the fall and 
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winter. Four ecological categories of seabirds have been documented in the 

deepwater areas of the GOM: summer migrants (e.g., shearwaters, storm petrels 

and boobies), summer residents that breed in the GOM (e.g., sooty, least, and 

sandwich tern, and frigate birds), winter residents (e.g., gannets, gulls, and 

jaegers), and permanent resident species (e.g., laughing gulls and royal and 

bridled terns) (Hess and Ribic 2000). Collectively, they live far from land most of 

the year, roosting on the water surface, except at breeding time when they return 

to nesting areas along coastlines (Terres 1991). Seabirds typically aggregate in 

social groups called colonies; the degree of colony formation varies between 

species (Parnell et al. 1988). They also tend to associate with various oceanic 

conditions including specific sea-surface temperatures, salinities, areas of high 

planktonic productivity, or current activity. Seabirds obtain their food from the 

sea with a variety of behaviors including piracy, scavenging, dipping, plunging, 

and surface seizing. 

Impact analysis – IPFs that could affect marine and pelagic birds include drilling 

rig presence (noise and lights), effluent discharge, marine debris, support vessel 

and helicopter traffic, and accidents. Birds may use offshore structures and 

platforms for resting, feeding, or as temporary shelter from inclement weather 

(Russell 2005). Effluent discharges are likely to have negligible impacts on the 

birds due to rapid dispersion, the small area of ocean affected, the intermittent 

nature of the discharges, and the mobility of these animals. 

Helicopter and service-vessel traffic could sporadically disturb feeding, resting, or 

nesting behavior of birds or cause abandonment of preferred habitat. These 

impact-producing factors could contribute to indirect population loss through 

reproductive failure resulting from nest abandonment. The Federal Aviation 

Administration (FAA) (Advisory Circular 91-36C) and corporate helicopter 

policy specify minimum altitude over populated areas and biologically sensitive 

areas such as wildlife refuges and national parks. It is expected that 

approximately 10 percent of helicopter trips would occur at altitudes somewhat 

below the minimums listed above as a result of inclement weather. Due to the 

short term duration and sporadic frequency, no significant impact is expected. 

Service vessels would use selected nearshore and coastal (inland) navigation 

waterways, or corridors, and adhere to protocol set forth by the U. S. Coast Guard 

(USCG) for reduced vessel speeds within these inland areas. Routine presence 

and low speeds of service vessels within these waterways would diminish the 

effects of disturbance from service vessels on nearshore and inland populations of 

coastal and marine birds. The effects of service-vessel traffic on birds offshore 

would not be significant. 

Marine birds can become entangled and snared in discarded trash and debris. In 

addition, many species will readily ingest small plastic debris, either intentionally 

or incidentally. Interaction with plastic materials is therefore very serious and can 

lead to permanent injuries and death. Compliance with NTL 2007-G03 is 

expected to result in no significant impact with trash and debris. Refer to Section 

1.0 for additional information. 
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Physical oiling of individuals or local groups of birds, depending on the extent 

and concentration could result in some degree of acute and chronic physiological 

stress (USDOI MMS 2002, 2007a and 2008b). In addition, recent spill 

experience showed that bird mortality is expected to occur during a large 

volume/long duration spill (USDOI BOEMRE 2010b). 

Stress, trauma, and shock enhance the effects of exposure and poisoning (USDOI 

MMS 2002, 2007a and 2008b). Low levels of oil could stress birds by interfering 

with food detection, feeding impulses, predator avoidance, territory definition, 

homing of migratory species, susceptibility to physiological disorders, disease 

resistance, growth rates, reproduction, and respiration (USDOI MMS 2002, 2007a 

and 2008b). 

Implementation of new BOEMRE environmental and safety regulations may 

further reduce the probability of the occurrence of a large volume/long duration 

spill. No significant impact is expected to marine and pelagic birds. 

3.2.3 Public Health and Safety 

The one anticipated IPF for public health and safety is an accidental release. An 

accidental hydrogen sulfide (H2S) release from the proposed activities is not 

expected that could impact public health and safety. This project does not expect 

to encounter the presence of H2S in concentrations greater than 500 parts per 

million (ppm). In accordance with 30 CFR 250.215(b) BP has submitted 

information to justify our request that the area of our proposed activities continue 

to be classified by BOEMRE as H2S absent. Refer to Section 3.0 of the EP. 

The public could be exposed to oil on the water and along the shoreline, including 

skin contact or breathing volatile organic compounds. The amount of exposure 

will depend on the magnitude and duration, the physical/chemical characteristics 

of the material, the oceanic conditions and the effectiveness of the spill response. 

During the recent Macondo event extensive air sampling conducted by the 

USEPA found no evidence of onshore levels of contaminants that are of 

significant concern for the long term health of residents of coastal communities 

(www.epa.gov/bpspill/air.html and www.epa.gov/bpspill/air-mon.html). 

Wildlife cleaning and rehabilitation workers have reported concerns including 

scrapes and cuts, itchy or red skin or rash, and symptoms of headache or feeling 

faint, dizzy, or fatigued. Hand, shoulder, or back pain was also reported by some 

wildlife cleaning workers (Centers for Disease Control and Prevention 2010). 

Spill response workers can be exposed to heat stress and acute exposure to 

hydrocarbons. Typical symptoms include: headaches, dizziness, nausea, 

vomiting, cough, respiratory distress, and chest pain (Solomon and Janssen 2010). 

No significant impact is expected to public health and safety. Implementation of 

new BOEMRE environmental and safety regulations may further reduce the 

probability of the occurrence of a large volume/long duration spill. 

 
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3.3 Coastal and Onshore 

3.3.1 Beaches 

Affected Resource – The description, physical location, and formative processes 

that create the various coastal beaches and barrier island complexes are described 

in Chapter 3.2.1.1 of the Multisale EIS (USDOI MMS 2007a). Coastal barriers of 

the Western GOM are generally divided into two physiographic areas: the 

Chenier Plains and barrier islands. These coastal barriers are relatively low 

landmasses that can be divided into several interrelated environments, including 

the unvegetated foreshore, the dune zone, and the backshore. When coastal storms 

occur, GOM waters may become elevated enough to overwash a coastal barrier, 

leveling the areas of beach and dunes, creating overwash fans or terraces. Within 

a week, overwashed beaches may reestablish their typical structure. Over longer 

periods, terraces will become revegetated by opportunistic species, and the 

formation of dunes will begin again with the availability and nature of windblown sand at each terrace. Landform changes can be seasonal and cyclical. 

Coastal barriers are dynamic habitats and provide a variety of niches that support 

many avian, terrestrial, aquatic, and amphibian species, some of which are 

endangered or threatened (USDOI MMS 2002 and 2007a). 

Accumulations and movements of sediments that make up barrier landforms are 

often described in terms of transgressive and regressive sequences. A 

transgressive sequence moves the shore landward allowing marine deposits to 

form on terrestrial sediments. A regressive sequence is one in which terrestrial 

sediments are deposited over marine deposits as land builds out, into the sea. 

Although transgressive landforms are dominant in the western and northern 

GOM, both transgressive and regressive barriers may occur in the region (USDOI 

MMS 2002 and 2007a). 

Barrier islands have incurred damage from hurricanes. The areas have 

experienced varying degrees of erosion, land and vegetation loss, loss in elevation 

or beach profile and, in some cases, movement toward shore as a result of the 

previous hurricane seasons. The resulting change in elevation and island profiles 

reduces the ability of these features to provide the pre-storm coastal protection to 

the mainland beaches and wetlands. While these barriers can rebuild to some 

extent naturally over time, it is the intent of both Federal and State coastal 

restoration initiatives like the Coastal Wetlands Protection, Planning & 

Restoration Act (CWPPRA), Louisiana Coastal Resources Program (LCRP), and 

Coastal Impact Assistance Program (CIAP) to assist in these barrier island 

restorations (USDOI MMS 2002 and 2007a). 

Impact Analysis - The IPFs associated with this project include vessel traffic, 

marine debris, and accidental releases. The distance to the shore is about 172.4 

mi (277 km) (Figure 4). 

An increase in the number of vessel trips, could result in minor incremental 

impacts to channels and coastal erosion rates. Standard activities associated with 

exploration, development and production have been documented and typically 

have a limited number of vessels required and a relatively short timeframe for 
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each phase resulting in impacts being short term and localized (USDOI MMS 

2002, 2007a and 2008b). No significant impacts are expected. 

Trash on the beach is recognized as a major threat to the enjoyment and use of 

beaches. Only a limited amount of marine debris, if any, should result from the 

proposed activities. Compliance with NTL 2007-G03 is expected to result in no 

significant impact with trash and debris. Refer to Section 1.0 for additional 

information. 

Offshore oil spills of large volume and long duration could pose problems for 

beaches and nearshore barrier islands. Oil and gas infrastructure such as pipelines 

and well heads also pose a higher probability regarding inshore oil spill threat 

(USDOI MMS 2007a and 2008b). The extent of such impacts will vary 

depending on, among other factors, the magnitude and duration of such an 

incident. 

Meteorological and hydrological conditions at the time of the spill coupled with 

the quantity and location of the spill determines the fate of accidental oil spills 

(USDOI MMS 2002, 2007a and 2008b). Spilled oil would need strong southerly 

winds to persist for an extended time prior to or immediately after the spill to 

elevate water levels to move onto beaches or across dunes. Strong winds would 

accelerate oil-slick dispersal, spreading, and weathering, thereby reducing impact 

severity at a landfall site. A study in Texas showed that oil disposal on sand and 

vegetated sand dunes had little harmful effects on the existing vegetation or on the 

recolonization of the oiled sands by plants (Webb et al. 1981 and 1985). Oil or its 

components that remain in the sand after cleanup may be (1) released periodically 

when storms and high tides resuspend or flush beach sediments, (2) decomposed 

by biological activity, or (3) volatilized and dispersed during hot or sunny days 

(USDOI MMS 2002, 2007a and 2008b). 

According to a Site Specific EA for a floating production, storage and offloading 

(FPSO) facility (USDOI MMS 2008a) located in an adjacent area to the east, oil 

spills from the operations could produce either adverse (but not significant) or 

extended (but not irreversible) impacts on coastal barrier beaches, depending 

upon spill size, the nature of the oil coming ashore (e.g., highly vs. lightly 

weathered), and the location and characteristics of the coastal barrier beach. 

Impacts may be long term, depending upon spill location and the relative position 

of sensitive resources. 

No significant impact is expected to coastal beaches. Contact is minimized due to 

distance from small spills. Implementation of new BOEMRE environmental and 

safety regulations may further reduce the probability of the occurrence of a large 

volume/long duration spill. 

3.3.2 Wetlands 

Affected Resource – Wetland habitats found specifically along the Gulf coast 

include fresh, brackish, and saline marshes; mud and sand flats; and forested 

wetlands of mangrove swamps, cypress-tupelo swamps, and bottomland 

hardwoods. These can support mixed communities of plant species or pure stands 
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of single species. Coastal wetlands are characterized by high organic 

productivity, high detritus production, and efficient nutrient recycling. Wetlands 

provide habitat for a great number and wide diversity of invertebrates, fish, 

reptiles, birds, and mammals, and are particularly important nursery grounds for 

many economically important fish and shellfish (USDOI MMS 2002, 2007a and 

2008b). 

The Deltaic Plain wetlands are on a series of overlapping riverine deltas that have 

extended onto the continental shelf during the past 6,000 years. Historically, the 

deltaic plain areas that were located near the active Mississippi River channel 

tended to build outward, and marsh areas tended to expand. At the same time, 

areas located near inactive, abandoned channels tended to deteriorate and erode as 

a result of the lack of sediment. Today, the Mississippi River is leveed, which 

greatly reduces the once natural formation of Deltaic Wetlands (USDOI MMS 

2002, 2007a and 2008b). 

The Chenier Plain, found in Texas and Louisiana, is the largest concentration of 

coastal wetlands in the region. The Chenier Plain is located west of the 

Atchafalaya Bay in the western part of coastal Louisiana and is a series of 

separate ridges of shell and sand oriented parallel or oblique to the Gulf coast. 

These ridges are separated by progradational mudflats that are now marshes or 

open water. The mudflats were built during times when the Mississippi River 

Channel was located on the western side of the Deltaic Plain or when minor 

changes in localized hydrologic and sedimentation patterns favored deposition on 

the Chenier Plain (USDOI MMS 2002, 2007a and 2008b). 

Along the Texas coast in the vicinity of southern Padre Island, marshes are 

minimal and unstable, compared with the more northern GOM. Brackish marshes 

occur in less saline, inland areas and are divided into frequently and infrequently 

flooded marshes. Infrequently flooded marshes contain an assemblage of plants 

that are much more tolerant of dry conditions. 

Freshwater marshes in Texas occur inland above tidally delivered saline waters, in 

association with streams, lakes, and catchments. Broken bands of black 

mangroves (Avicennia germinans) also occur in this area (Brown et al. 1977; 

White et al. 1986). Wind-tidal flats of mud and sand are mostly found around 

shallow bay margins and in association with shoals. South of Corpus Christi and 

into Tamaulipas, flats increasingly replace lagoonal and bay marshes. Laguna 

Madre of Texas is divided into northern and southern parts by the wind-tidal flats 

of the Land-Cut Area, just south of Baffin Bay. The Intracoastal Waterway is 

dredged through this area, as are a series of well access channels. Dredging has 

caused topographic and vegetative changes among the flats of Laguna Madre. 

Inland beaches of sand and shells are found along the shores of bays, lagoons, and 

tidal streams. The structure of these beaches is similar to, but much narrower and 

smaller in scale than, barrier beaches. Compared with sand beaches, shell 

features are typically stacked to higher elevations by storm waves and are 

generally more stable (Brown et al. 1977; White et al. 1986). 
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Several factors contribute to wetland loss in coastal Louisiana. Sediment 

deprivation is a result of a 50 percent decreases in the suspended-sediment load of 

the river since the 1950’s, the channelization of the river, and the primary cause, 

the construction of the flood protection levees. Subsidence and sea level rise have 

caused submergence of lower wetland areas. Construction of ring levees allowed 

drainage and development of extensive wetlands. Development activities in low 

areas, outside leveed areas, have caused the filling of wetlands. Construction of 

canals converted wetlands to open water and upland spoil banks. Canals and 

subsidence also contributed to increased tidal influence and salinities in 

freshwater and low salinity wetlands, which in turn has increased erosion and 

sediment export (USDOI MMS 2002, 2007a and 2008b).

Impact Analysis – The IPFs associated with this project include vessel traffic and 

accidental releases. Only a slight increase in vessel traffic is expected to occur, 

but vessel size may increase due to supply needs and open-sea conditions. 

Currently, existing ports, production facilities, and navigation channels would be 

used, eliminating the need for the expansion or construction of facilities into 

wetland areas. Vessel support would likely use armored coastal channels, as well 

as existing offshore channels and sea lanes. No significant impact is expected. 

The primary accidental IPF associated with the potential to impact coastal 

wetlands is oil spills. Barrier islands can provide protection or reduce the severity 

of an oil spill by intercepting the spill before it reaches the wetlands located either 

behind (on mainland shore) or within the interior of the islands. Should a spill 

occur inshore or in nearshore waters, it presents a much greater potential for 

adversely impacting wetlands than an offshore deepwater spill simply due to 

proximity. 

The works of several investigators (Webb et al. 1981 and 1985; Alexander and 

Webb 1983, 1985, and 1987; Lytle 1975; Delaune et al. 1979; Fischel et al. 1989) 

evaluated the effects of potential spills to wetlands. The primary reason for 

vegetation loss and ultimately facilitating land loss associated with an oil spill is 

impact to the vegetation root system. Vegetation diebacks may only happen for 

one growing season depending upon the concentration and the season during 

which contact occurs. The extent of such impacts will vary depending on, among 

other factors, the magnitude and duration of such an incident. The larger the spill 

with longer duration may result in more impact. 

Distant offshore spills have a further diminished probability of impacting inland 

wetland shorelines and seagrasses, largely due to their sheltered locations 

(USDOI MMS 2002, 2007a and 2008b). An inland fuel-oil spill may occur at a 

shore base or as a result of a vessel collision, though the probability is likely also 

very small. Should a spill occur inshore or in nearshore waters, it presents a much 

greater potential for adversely impacting wetlands and seagrasses, due to their 

proximity to the spill. Oil could accumulate in sheens and thick layers in the 

marsh and in protected pools and embayments (USDOI MMS 2002, 2007a and 

2008b). 
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No significant impact is expected to wetlands. Contact is minimized due to 

distance from small spills. Implementation of new BOEMRE environmental and 

safety regulations may further reduce the probability of the occurrence of a large 

volume/long duration spill. 

3.3.3 Shore Birds and Coastal Nesting Birds 

Affected Resource – The offshore waters, coastal beaches, and contiguous 

wetlands of the northeastern GOM are populated by both resident and migratory 

species of coastal and marine birds. This analysis assumes five major groups in 

the area of concern: seabirds, shorebirds, marsh and wading birds, waterfowl, and 

raptors. Many species are mostly pelagic and, therefore, are rarely sighted 

nearshore. Fidelity to nesting sites varies from year to year along the Gulf coast 

(Martin and Lester 1991). Birds may abandon sites along the northern Gulf coast 

because of altered habitat and excessive human disturbance. 

Shorebirds are those members of the order Charadriiformes generally restricted to 

coastline margins (beaches, mudflats, etc.). GOM shorebirds comprise five 

taxonomic families; Jacanidae (jacanas), Haematopodidae (oystercatchers), 

Recurvirostridae (stilts and avocets), Charadriidae (plovers), and Scolopacidae 

(sandpipers, snipes, and allies) (Hayman et al. 1986). An important characteristic 

of almost all shorebird species is their strongly developed migratory behavior, 

with some shorebirds migrating from nesting places in the far north to the 

southern part of South America (Terres 1991). Along the Gulf coast, observers 

have recorded 44 species of shorebirds. Six species nest in the area; the 

remaining species are wintering residents and/or “staging” transients (Pashley 

1991). 

The term wading birds refers to birds that have adapted to living in marshes and 

shallow water. Seventeen species of wading birds in the order Ciconiiformes 

currently nest in the U.S., and all except the wood stork nest in the northern GOM 

coastal region (Martin 1991; Terres 1991). These families have representatives in 

the northern GOM: Ardeidae (herons, bitterns, and egrets), Ciconiidae (storks), 

Threskiornithidae (ibises and spoonbills), Gruidae (crane), and Rallidae (rails, 

moorhens, gallinules, and coots). 

Waterfowl belong to the taxonomic order Anseriformes and include swans, geese, 

and ducks. A total of 27 species are regularly reported along the north-central and 

western Gulf coast (Clapp et al. 1982; National Geographic Society 1983; Madge 

and Burn 1988). Many species usually migrate from wintering grounds along the 

Gulf coast to summer nesting grounds in the northern U.S. waterfowl migration 

pathways have traditionally been divided into four parallel north-south paths, or 

“flyways,” across the North American continent. The Gulf coast serves as the 

southern terminus of the Mississippi (Louisiana, Mississippi, and Alabama) 

flyway. Waterfowl are social and have a diverse array of feeding adaptations 

related to their habitat (Johnsgard 1975). 

There are three main groups of diving birds, respectively: cormorants and 

anhingas, loons, and grebes. Of the two pelican species in North America, only 

the brown pelican is listed as endangered. 
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Several other birds that inhabit or frequent the northern GOM coastal areas are 

recognized by U. S. Fish and Wildlife Service (FWS) as either endangered or 

threatened: interior least tern, Mississippi sandhill crane, piping plover, whooping 

crane, and wood stork. Detailed descriptions of the endangere and threatened 

birds can be found in the Final EIS for Central and Western GOM Multisale 

Lease Areas (USDOI MMS 2002) and Final EIS for Western and Central GOM 

Multisale Lease Areas (USDOI MMS 2007a) and draft supplemental EIS (2008b; 

USDOI BOERME 2011b). 

On July 10, 2001, the final rule was published for critical habitat for the wintering 

population of piping plover in 82 areas from west Florida south to Tampa Bay, 

Alabama, Louisiana, and Texas. Critical habitat identifies specific areas that are 

essential to the conservation of a listed species and that may require special 

management consideration or protection. The primary constituent needs for the 

piping plover are those habitat components that are essential for the primary 

biological needs of foraging, sheltering, and roosting. The least tern is not 

considered federally endangered or threatened within 50 mi of the GOM. Only 

the interior nesting colonies are endangered (USDOI MMS 2002, 2007a and 

2008b). Two other coastal species (Bald Eagle and Brown Pelican) discussed by 

BOERME (USDOI MMS 2007a, 2008b) are no longer listed as endangered or 

threatened; these are included under Shore Birds and Coastal Nesting Birds. 

Impact Analysis - IPFs potentially affecting shore birds and coastal nesting birds 

include helicopter traffic, marine debris, and accidental release. An accidental oil 

spill from the proposed activities could cause impacts to shore birds and coastal 

nesting birds if contact is made. The distance to shore is about 172.4 mi (277 km) 

(Figure 4). 

Helicopter and service-vessel traffic related to the proposed action could 

sporadically disturb feeding, resting, or nesting behavior of birds or cause 

abandonment of preferred habitat. These IPFs could contribute to indirect 

population loss through reproductive failure resulting from nest abandonment. 

The FAA (Advisory Circular 91-36C) and corporate helicopter policy specify 

minimum altitude over populated areas and biologically sensitive areas such as 

wildlife refuges and national parks. Although these incidents are very short term 

in duration and sporadic in frequency, they can disrupt coastal bird behavior and, 

at worst, possibly result in habitat or nest abandonment. No significant impact is 

expected. 

Service vessels should use selected nearshore and coastal (inland) navigation 

waterways, or corridors, and adhere to protocol set forth by the USCG for reduced 

vessel speeds within these inland areas. Routine presence and low speeds of 

service vessels within these waterways would diminish the effects of disturbance 

from service vessels on nearshore and inland populations of coastal and marine 

birds. The effects of service-vessel traffic on birds offshore would result in no 

significant impact. 

Coastal and marine birds can become entangled and snared in discarded trash and 

debris. Additionally, many species will ingest small plastic debris, either 
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intentionally or incidentally. Compliance with NTL 2007-G03 is expected to 

result in no significant impact with trash and debris. Refer to Section 1.0 for 

additional information. 

Oil-spill cleanup methods often require heavy trafficking of beaches and wetland 

areas, application of oil dispersant and bioremediation chemicals, and the 

distribution and collection of oil containment booms and absorbent material. The 

presence of humans, along with boats, aircraft, and other technological creations, 

could also disturb coastal birds after a spill. Investigations have shown that oildispersant mixtures are similar to that of oil alone in its effects to successful 

reproduction in birds (Albers 1979; Albers and Gay 1982). The external exposure 

of adult birds to oil/dispersant emulsions may reduce chick survival more than 

exposure to oil alone; however, successful dispersal of a spill will generally 

reduce the probability of exposure of coastal and marine birds to oil (Butler et al. 

1988). It is possible that changes in the size of an established breeding population 

may also be a result of disturbance in the form of increased human activity for 

cleanup and monitoring efforts or to the intensified research activity after the oil 

spills (Maccarone and Brzorad 1994). 

If physical oiling of individuals or local groups of birds occurs, some degree of 

both acute and chronic physiological stress associated with direct and secondary 

uptake of oil would be expected (USDOI MMS 2002, 2007a and 2008b). In 

addition, recent spill experience showed that bird mortality is expected to occur 

during a large volume/long duration spill (USDOI BOEMRE 2010b). 

Stress, trauma, and shock enhance the effects of exposure and poisoning (USDOI 

MMS 2002, 2007a and 2008b). Low levels of oil could stress birds by interfering 

with food detection, feeding, predator avoidance, territory definition, homing of 

migratory species, susceptibility to physiological disorders, disease resistance, 

growth rates, reproduction, and respiration (USDOI MMS 2002, 2007a and 

2008b). Preventative methods, such as permitted hazing from the path of an 

approaching oil slick or the use of booms to protect sensitive colonies in an 

emergency, have limited applicability (Clark 1984).

No significant impact is expected to shore birds and coastal nesting birds. 

Contact is minimized due to distance from small spills. Implementation of new 

BOEMRE environmental and safety regulations may further reduce the 

probability of the occurrence of a large volume/long duration spill. 

3.3.4 Coastal Wildlife Refuges and Wilderness Areas 

Affected Resource – The National Wildlife Refuge (NWR) System, managed by 

the FWS, is a system of public lands and waters set aside to conserve wildlife and 

fisheries resources. There are about 12 NWRs (Laguna Atacosa, Aransas, Big 

Boggy, San Bernard, Brazoria, Moody, Anahuac, McFadden, Texas Point, Shell 

Keys Delta, Breton and St. Bernard) that are located along the Northern GOM 

along the coast. 

In addition to the NWR system, the National Estuarine Research Reserve (NERR) 

System is a network of protected areas established for longterm research, 
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education, and stewardship. This partnership program between NOAA and 

coastal states has established five reserves (Grand Bay NERR, Weeks Bay NERR, 

Rookery Bay NERR, Apalachicola NERR, and Mission-Aransas NERR) in the 

GOM. 

Impact Analysis – An accidental oil spill from the proposed activities could 

cause impacts to coastal wildlife refuges. However, due to the distance to shore 

(about 172.4 mi) (Figure 4) and the response capabilities that would be 

implemented, no significant adverse impacts are expected. Contact is minimized 

due to distance from small spills. Implementation of new BOEMRE 

environmental and safety regulations may further reduce the probability of the 

occurrence of a large volume/long duration spill. 

3.3.5 Other Environmental Resources Identified 

Other environmental resources identified were socioeconomic and groundwater 

and onshore surrounding environments. 

3.3.5.1 Socioeconomics 

Affected Resource – The GOM provides more than 34 percent of the commercial 

fish landings in the continental United States (USDOC NMFS 2006). 

Commercially important species include the estuary-dependent species such as 

Atlantic menhaden, shrimps, oyster, crabs, and sciaenids (Benson 1982; Hoese 

and Moore 1977). Menhaden, with landings of about 1.02 billion pounds and 

valued at $44.9 million, was the most important GOM species in quantity landed 

during 2004. Shrimp, with landings of nearly 257 million pounds and valued at 

about $367 million, was the most important GOM species in value landed during 

2004. The 2004 GOM oyster fishery accounted for nearly 93 percent of the 

national total with landings of 25 million pounds of meats, valued at about $61 

million. The GOM blue crab fishery accounted for 36 percent of the national total 

with landings of 60 million pounds, valued at about $41 million (USDOC NMFS 

2006). In 2008 commercial fishermen in the Gulf harvested more than 1 billion 

pounds of finfish and shellfish (USDOC NOAA 2010b).

In 2008, over 24 million recreational fishing trips were taken in the GOM, which 

generated about $12 billion in sales, over $6 billion in value added impacts, and 

over 100,000 jobs (USDOC NMFS 2010a). Unlike commercial fishing, 

recreational fishing is concentrated during the summer months. 

Tourism and recreation are integral components of the economy of the GOM. 

Visitors to Texas, Louisiana, Mississippi, Alabama, and Florida spent 

approximately $145 billion in 2008 (USDOI BOEMRE 2011a). This spending 

helped to support approximately 2.4 million jobs in recreation-based industries 

statewide. Approximately, 600,000 of these jobs are in counties that are directly 

along the coast. Recreational jobs account for 14.8 percent of Gulf Coast 

employment, greater than the national average of 12.4 percent (USDOI BOEMRE 

2011a). Gulf Coast recreational employment is reasonably cyclical, with the peak 

months during the past few years occurring between March and June (USDOI 

BOEMRE 2011a). 
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The importance of the oil and gas industry to the coastal communities of the 

GOM is significant, especially in Louisiana, eastern Texas and coastal Alabama 

(USDOI MMS 2007a and 2008b). Oil service related employment is 

concentrated in coastal Louisiana Parishes (St. Mary, Terrebone, Lafourche, 

Iberia, and Plaquemines) and drilling related employment is most concentrated in 

Harris County, Texas and Lafayette Parish Louisiana (USDOI BOEMRE 2011a). 

Changes in OCS oil and gas activities have significant employment implications 

to the communities, especially those directly or indirectly related to oil and gas 

development (USDOI MMS 2007a and 2008b). 

Sufficient land is designated in commercial and industrial parks and adjacent to 

the existing ports to minimize potential disruption to current residential and 

business use patterns (USDOI MMS 2007a and 2008b). The high level of 

offshore oil and gas activity in the GOM is accompanied by development of 

onshore service and support facilities. This onshore infrastructure includes gas 

processing plants, navigation channels, oil refineries, pipelines, storage yards, 

fabrication yards, separation facilities, service bases, and terminals as well as 

landfills and disposal sites for drilling and production wastes (USDOI MMS 

2007a and 2008b). 

Archaeological sites provide recreational opportunities (e.g. tourism and diving) 

both offshore and onshore. Damage by an accidental release on corals and other 

organisms on archaeological resources (i.e. shipwreck sites) could change the 

surrounding site and increase degradation. Additionally, onshore habitat could 

degrade and erode, which would increase exposure to and subsidence of 

prehistoric and historic sites. Archaeological resources affected from the release 

or cleanup activities cannot be reversed, therefore leading to a loss of 

archaeological data. 

Impact Analysis – A large volume/long duration accidental release has the 

potential to impact on recreation and tourism; recreational and commercial fishing 

and employment. Tourism impact would depend on the extent to which any 

structural/ecological damage can be repaired, as well as on the extent to which 

public confidence in the tourism industry can be restored (USDOI BOEMRE 

2011a). For example, a long duration/large volume oil spill would likely affect 

the fish populations in the affected waters to some extent. The most direct impact 

of this would be to lessen recreational fishing activity in a region to the extent that 

the fish population has decreased. An accidental release may or may not result in 

fishery closures, depending on the magnitude and duration of the spill, the 

oceanographic and meteorological conditions at the time, and the effectiveness of 

spill response measures. 

The project will have support from existing shore base facilities in Louisiana. BP 

will use the existing shorebase (C-Port Fourchon Shorebase, Fourchon Heavy Lift 

and Serimax Yard) located in Fourchon, Terrebonne Parish, Louisiana to support 

general vessel operations. No expansion of these physical facilities is expected to 

result from the proposed supplemental activities. The C-Port Fourchon facility is 

located approximately 257 mi (Figure 4) from the general project area, provides a 

vehicle parking lot, office space, radio communication equipment, outside and 
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warehouse storage space, crane, forklifts, water and fueling facilities, and boat 

dock space. The base is in operation 24 hours each day. 

No new or expanded facilities will be constructed, and no new employees are 

expected to move permanently into the area. The project will have a negligible 

impact on socioeconomic conditions such as local employment, existing offshore 

and coastal infrastructure (including major sources of supplies, services, energy, 

and water), and minority and lower income groups. Levels of boat and helicopter 

traffic, as well as demand for goods and services including scarce coastal 

resources, will represent a small fraction of the level of activity occurring at the 

shore base. The response to a release would be staged primarily out of existing 

facilities; however, there could be limited temporary impacts on land use along 

the coast if additional staging areas were needed. These areas would eventually 

return to their original use as the response is demobilized. 

No significant impact is expected to socioeconomic resources. Implementation of 

new BOEMRE environmental and safety regulations may further reduce the 

probability of the occurrence of a large volume/long duration spill.

3.3.5.2 Groundwater and Onshore Environments 

Affected Resource – Offshore drilling operations generate several types of 

wastes such as municipal trash (paper, plastic, wood, food wrappings, etc.), scrap 

metal, used drilling fluids and chemicals. A large majority of the waste generated 

is associated with offshore food service operations, as well as drilling operations 

and maintenance activities of the rig. These waste types are identified in the 

various tables submitted in the EP and are managed in accordance with USEPA’s 

and applicable state waste regulations. Refer to Section 6.0 of the EP for 

additional information regarding wastes types and amounts. Operational waste is 

collected and stored until it is shipped to shore for disposal or recycling at BP 

approved landfills or disposal companies. 

An accidental release of oil could generate large quantities of additional waste 

materials and debris. This could include: tar balls, oiled vegetation and sand, used 

personal protective equipment (PPE), oil and oily water, and oiled sorbent 

materials (e.g. rags, boom and absorbent pads) (USEPA 2010). The amount of 

material generated will depend on the magnitude and duration, the 

physical/chemical characteristics of the material, the oceanic conditions and the 

effectiveness of the spill response. The waste generated would be segregated by 

waste type and sent to an appropriate permitted and BP approved disposal facility 

to receive and manage such wastes. 

Based on information provided in GOM OCS Oil and Gas Scenario Examination: 

Onshore Waste Disposal (Dismukes et al. 2007), current landfills located in 

Texas, Louisiana, Mississippi, and Alabama have an estimated permitted capacity 

of 386,545,904 tons and an average useful life of 32 years. Those with useful life 

of greater than 40 years have a remaining permitted capacity of 170,058,951 tons, 

which represents 44 percent of the total capacity for the GOM region. Activities 

covered in this EP will utilize a limited number of BP approved disposal sites 
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located in Louisiana. Refer to Section 6.0 of the EP for additional information 

regarding approved waste disposal venders and sites. 

Impact Analysis: IPFs that could affect ground water and onshore environments 

are onshore waste disposal. Landfills are state permitted waste management 

facilities and must comply with the Resource Conservation and Recovery Act 

(RCRA) regulations at the federal, state and local levels. The regulations include 

design criteria for the protection of groundwater and the surrounding 

environments such as: Location restrictions, composite liner requirements, 

leachate collection and removal systems, operating practices, groundwater 

monitoring requirements, closure and post-closure care requirements, corrective 

action provisions, and financial assurance. BP conducts routine independent 

audits of commercial waste disposal facilities to review their waste management 

practices, permitting, and compliance history. 

BP will operate in accordance with the regulations 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 covering outside trash bins to 

prevent accidental loss of solid waste in accordance with NTL 2007-G03. Refer to 

Section 1.0 for additional information. 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. 

BP has developed waste management plans for the collection, handling, 

management and disposal of such wastes. These plans are written to ensure 

wastes are handled safely and in accordance with existing applicable federal, state 

and local rules and regulations. 

In addition BP seeks out options to minimize waste that is generated and recycles 

as much as possible. Waste items like plastic drinking bottles, cardboard, paper, 

and tin aluminum are sent for recycling rather than disposal in a landfill. Used oil, 

oily rags/pads, filter, and empty buckets are also sent for recycling rather than 

landfill disposal. 

The Dismukes et al. (2007) study stated that landfill capacities do not appear to be 

a constraint in any fashion to the ongoing or future development of offshore oil 

and gas activities. Environmental regulators in the region indicated that existing 

facilities have ample capacity and see no future constraints. The USEPA recently 

stated that landfills receiving wastes have abundant capacity to handle the 

expected wastes from large response efforts and; therefore, the addition of the 

waste generated from large response efforts would not significantly shorten the 

expected life-span of the landfills (USEPA 2010). 

Therefore, there are no significant impacts expected from onshore waste disposal 

to groundwater and the onshore environments. 

4.0 CUMULATIVE IMPACT ANALYSIS 

The BOEMRE fully addressed the cumulative effects of OCS (i.e., oil and gas 

leasing, exploration, development, and production) and non-OCS related activities 
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for the CPA and WPA as well as the Gulf Coast region as part of the NEPA 

documentation completed for proposed multi-sale lease activities. OCS related 

activities include routine operations (e.g., drill rig presence (noise and lights), 

bottom disturbing activities, vessel traffic, operational discharges, noise generated 

by platforms, drillships, helicopters and vessels, seismic surveys, explosive 

structure removals) and accidental events (e.g., oil spills, oil-spill-response 

activities, vessel collisions loss of debris from service vessels and OCS 

structures). Non-OCS related activities were considered, but not limited to crude 

oil import tankering, State oil and gas activity, recreational and commercial 

fishing, coastal development, natural processes (hypoxia), and recreational, 

commercial and military vessel traffic. These OCS and non-OCS activities are 

considered in this section so far as they could contribute to the cumulative 

environmental and socioeconomic impacts pertinent to the proposed activities. 

Cumulative impacts from OCS and non-OCS related activities are discussed in 

Chapter 4.5 of the multi-sale EIS (USDOI MMS 2002 and 2007a) and Chapter 

4.1 of the supplemental EIS (USDOI MMS 2008b). Additional impacts from 

accidental releases are discussed in Chapter 4 of the multi-sale EIS’s (USDOI 

MMS 2002 and 2007a) and the Supplemental EIS (USDOI MMS 2008b). 

The proposed activities described in the EP are similar to those addressed in 

previous multisale EISs (USDOI MMS 2002, 2007a and 2008b) and a recent site 

specific EA (USDOI BOEMRE 2011a). That EA analyzes impacts upon 

environmental and socioeconomic resources, including cumulative impacts, 

against new information related to the Macondo incident. The cumulative 

impacts discussed in these BOEMRE NEPA documents include both the project 

specific work proposed in these documents and other reasonably foreseeable 

activities expected to take place in the GOM. Incremental impacts from the work 

planned in this EP are expected to be negligible as a result of conforming to the 

laws, regulations, lease stipulations, and NTLs, and the limited geographic scope 

and duration. 

Although regulatory uncertainties continue to affect the approval of new 

exploration and development plans, and the issuance of new permits to drill, 

additional projects are expected to proceed. The closest existing production 

facility is in Garden Banks Block 668, about 30 miles away. The closest 

approved drilling activity is in Garden Banks Block 973, about 10 miles away. 

BP is currently not aware of any other project in the immediate vicinity of the 

proposed EP activity. Discussions below address how the impacts, if any, from 

the proposed EP activities are expected to contribute to the cumulative impacts of 

this and other similar projects. 

The Gulf Coast has survived major natural and manmade disasters (i.e., 

hurricanes and oil spills), through which the people and environmental resources 

of the GOM and the Gulf Coast have repeatedly demonstrated their resiliency. 

While environmental and socioeconomic resources may recover from a natural or 

manmade disaster if given enough time between disasters, disasters happening in 

unison or within short periods of each other would make recovery more difficult 

(USDOI BOEMRE 2011a). 
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The magnitude of OCS and non-OCS activity in the GOM is so immense that 

routine activities associated with a single OCS oil and gas activity (e.g., single 

lease sale, single well) would likely have minor to no incremental contribution to 

the impacts of cumulative activities. However, a large blowout and spill could 

contribute to cumulative impacts on a variety of GOM resources (USDOI 

BOEMRE 2011a).

Benthic Communities (Soft Bottom Benthic Communities, High Density 

Deepwater Benthic Communities, Designated Topographic Feature, Pinnacle 

Trend, and Eastern Gulf Live Bottoms) - The proposed drilling is expected to 

result in no physical impacts due to the use of a dynamically positioned rig. 

Slight increases in turbidity from drilling mud and cuttings are expected to be 

localized and temporary (USDOI BOEMRE 2011a). Subsurface spills, including 

a catastrophic event, could result in sediment or oily material coming into contact 

with the benthic communities. However, the chance of a large blowout is very 

low and would only damage benthic communities where concentrated oil makes 

direct contact (USDOI BOEMRE 2011a). Recolonization from populations of 

neighboring soft bottom substrate would be expected (USDOI MMS 2001, 2002, 

2007a, 2008b). 

Areas that may support high‐density deepwater benthic communities will be 

avoided as required by NTL 2009‐G40. The site clearance narrative did not 

reveal evidence of hydrocarbon seepage within 2,000 ft of the proposed drilling 

location (Fugro 2010). 

Mitigation measures such as those required by laws, regulations, lease stipulations 

and NTLs are expected to result in localized and short term impacts. No 

significant incremental cumulative impacts to these benthic features and 

communities are expected as a result of the proposed activities as well as other 

reasonably foreseeable future activities in the area. 

Water Quality - Slight increases in turbidity from drilling mud and cuttings are 

expected to be localized and temporary. According to a recent site specific EA, 

“spills of oil, diesel fuel, and other materials may occur from vessels transporting 

crude oil and petroleum products; from vessels involved in commercial fishing, 

freight or passenger transport; and from OCS operations (USDOI BOEMRE 

2011a).” During a well blowout the water quality of marine waters could be 

impacted by increase turbidity and the release of oil (USDOI BOEMRE 2011a). 

Short-term, localized changes in water quality would be expected from an oil spill 

≥1,000 bbl and cumulative impacts would be negligible (USDOI BOEMRE 

2011a). The extent of such impacts will vary depending on, among other factors, 

the magnitude and duration of the incident. 

Mitigation measures such as those required by laws, regulations, lease stipulations 

and NTLs are expected to result in short term impacts. No significant incremental 

cumulative impacts to water quality are expected as a result of the proposed 

activities as well as other reasonably foreseeable future activities in the area. 

Fisheries and EFH – The BOEMRE identified cumulative activities such as

State oil and gas activity, coastal development, crude oil imports by tanker, 
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commercial and recreational fishing, hypoxia (i.e., red or brown tides), removal of 

OCS structures, and offshore discharges of drilling muds and produced waters 

that could impact fisheries and EFH (USDOI BOEMRE 2011a). The drilling rig 

is a single, temporary structure; therefore, impacts on fish populations, whether 

beneficial or adverse, would be considered insignificant. Slight increases in 

turbidity from drilling mud and cuttings are expected to be localized and 

temporary. A well blowout scenario could introduce oil to surface or subsurface 

waters. Behavior science associated with adult fish indicate that they would 

likely avoid the area of a spill, but fish eggs and larvae within the spill area of the 

northern GOM could be killed (USDOI MMS 2002 and 2007a). 

Mitigation measures such as those required by laws, regulations, lease stipulations 

and NTLs are expected to minimize impacts. No significant incremental 

cumulative impacts to fisheries and EFH are expected as a result of the proposed 

activities as well as other reasonably foreseeable future activities in the area. 

Marine Mammals and Sea Turtles – Oil and gas leasing, exploration, 

development and production activities including the degradation of water quality 

resulting from operational discharges, vessel traffic, noise generated by platforms, 

drillships, helicopters and vessels, seismic surveys, explosive structure removals, 

oil spills, oil-spill-response activities, loss of debris from service vessels and OCS 

structures, commercial fishing, capture and removal, and pathogens may 

contribute to cumulative impacts that could affect marine mammals and sea 

turtles (USDOI BOEMRE 2011a). Disturbances from OCS-related activities 

could stress and/or weaken individuals of a local group or population and make 

them more vulnerable to infection from natural or anthropogenic sources (USDOI 

BOEMRE 2011a). Few deaths are expected from chance vessel collisions, 

ingestion of plastic material by compliance with NTL 2007-G03 and NTL 2007-

G04. 

Mitigation measures such as those required by laws, regulations, lease stipulations 

and NTLs are expected to minimize impacts. No significant incremental 

cumulative impacts to marine mammals and sea turtles are expected as a result of 

the proposed activities as well as other reasonably foreseeable future activities in 

the area. 

Air Quality - The proposed activities are located approximately 172.4 miles 

offshore. Cumulative impacts on air quality within the offshore area would come 

primarily from non-OCS oil/gas activities in the GOM as well as onshore sources 

such as emissions from industrial plants, power generation, and urban 

transportation (USDOI BOEMRE 2011a). 

The projected air emissions are not expected to affect the air quality of the OCS 

primarily due the distance to the shore or to any Prevention of Significant 

Deterioration Class I air quality area such as the Breton Wilderness Area. 

Keathley Canyon Block 93 is beyond the 200 kilometer (124 mile) buffer for the 

Breton Wilderness Area. Portions of the Gulf Coast have ozone levels that 

exceed the Federal air quality standard (USDOI MMS 2007a, 2008b). 
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Mitigation measures such as those required by laws, regulations, lease stipulations 

and NTLs are expected to minimize impacts. No significant incremental 

cumulative impacts to air quality are expected as a result of the proposed 

activities as well as other reasonably foreseeable future activities in the area. 

Shipwreck Sites (known or potential) and Prehistoric Archaeological Sites - 

Several impact-producing factors may threaten historic archaeological resources. 

An impact could result from a contact between a historic shipwreck and an OCS 

activity (pipeline and platform installations, drilling rig emplacement and 

operation, dredging, and anchoring activities) (USDOI BOEMRE 2011a). 

Keathley Canyon Block 93 are not stipulated as requiring archaeological resource 

surveys and reports (NTL 2005-G07 and 2008-G20). A review of the Shallow 

Geohazards Assessment (Fugro 2010) was conducted and indicates there is no 

known or potential shipwreck sites located within the survey area. The proposed 

drilling will be done with a dynamic positioned rig which does not have 

associated anchors, anchor chains or wire ropes; therefore, no impacts on such 

sites are expected as a result of the proposed operations. 

During oil and gas exploration and development as well as during fishing or other 

maritime activities, the loss or discard of ferromagnetic debris may occur that 

could result in the masking of historic shipwrecks or the introduction of false 

targets that could be mistaken in the remote sensing record as historic resources 

(USDOI BOEMRE 2011a). 

Mitigation measures such as those required by laws, regulations, lease stipulations 

and NTLs are expected to minimize impacts. No significant incremental 

cumulative impacts to shipwrecks and prehistoric archaeological sites are 

expected as a result of the proposed activities as well as other reasonably 

foreseeable future activities in the area. 

Marine, Pelagic, Coastal Nesting and Shore Birds – The majority of effects 

resulting from the proposed project on marine, pelagic, coastal nesting and shore 

birds are expected to be sublethal: behavioral effects, sublethal exposure to or 

intake of OCS-related contaminants or discarded debris, temporary disturbances, 

and displacement of localized groups from impacted habitats (USDOI MMS 

2007a). Chronic sublethal stress, however, is often undetectable in birds. As a 

result of stress, individuals may weaken, facilitating infection and disease 

(USDOI MMS 2007a). 

Birds may use offshore structures and platforms for resting, feeding, or as 

temporary shelter from inclement weather (Russell, 2005). Effluent discharges 

are likely to have negligible impacts on the birds due to rapid dispersion, the 

small area of ocean affected, the intermittent nature of the discharges, and the 

mobility of these animals. Compliance with NTL 2007-G03 is expected to result 

in reduced interaction with discarded trash and debris. 

Oil-spill cleanup methods often require heavy trafficking of beaches and wetland 

areas, application of oil dispersant and bioremediation chemicals, and the 

distribution and collection of oil containment booms and absorbent material. The 
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presence of humans, along with boats, aircraft, and other technological creations, 

could also disturb coastal birds after a spill. 

Mitigation measures such as those required by laws, regulations, lease stipulations 

and NTLs are expected to minimize impacts. No significant incremental 

cumulative impacts to marine, pelagic, coastal nesting and shore birds are 

expected as a result of the proposed activities as well as other reasonably 

foreseeable future activities in the area. 

Public Health and Safety - An accidental H2S release from the proposed 

activities is not expected. Some members of the public could be exposed to oil on 

the water and along the shoreline, including skin contact or breathing volatile 

organic compounds. The amount of exposure will depend on the magnitude and 

duration, the physical/chemical characteristics of the material, the oceanic 

conditions and the effectiveness of the spill response. 

Mitigation measures such as those required by laws, regulations, lease stipulations 

and NTLs are expected to minimize impacts. No significant incremental 

cumulative impacts to public health and safety are expected as a result of the 

proposed activities as well as other reasonably foreseeable future activities in the 

area. 

Beaches, Wetlands, Coastal Wildlife Refuges and Wilderness Areas - The 

distance to the nearest shore is 172.4 miles (Figure 4). An increase in the number 

of vessel trips, could result in minor incremental impacts to channels and coastal 

erosion rates. Currently, existing ports, production facilities, and navigation 

channels would be used, eliminating the need for the expansion or construction of 

facilities into wetland areas. 

Offshore oil spills of large volume and long duration could produce impacts on 

beaches and nearshore barrier islands. Implementation of new BOEMRE 

environmental and safety regulations may further reduce the probability of the 

occurrence of a large volume/long duration spill. 

Mitigation measures such as those required by laws, regulations, lease stipulations 

and NTLs are expected to minimize impacts. No significant incremental 

cumulative impacts to beaches, wetlands, coastal wildlife refuges and wilderness 

areas are expected as a result of the proposed activities as well as other reasonably 

foreseeable future activities in the area. 

Socioeconomics - Tourism impact would depend on the extent to which any 

structural/ecological damage can be repaired, as well as on the extent to which 

public confidence in the tourism industry can be restored (USDOI BOEMRE 

2011a). Recreational resources and tourism in coastal areas would not be affected 

by any routine activities due to the distance from shore. 

The magnitude of OCS and non-OCS activity in the Gulf of Mexico is so 

immense that routine activities associated with a single OCS oil and gas activity 

(e.g., single lease sale, single well) have a minor to no incremental contribution to 

the impacts of cumulative activities. However, a large blowout and spill could 

contribute to cumulative impacts (USDOI BOEMRE 2011a). The project will 
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have support from existing shore base facilities in Louisiana. No new or 

expanded facilities will be constructed, and no new employees are expected to 

move permanently into the area. The project will have a negligible impact on 

socioeconomic conditions such as local employment, existing offshore and coastal 

infrastructure (including major sources of supplies, services, energy, and water), 

and minority and lower income groups. 

Mitigation measures such as those required by laws, regulations, lease stipulations 

and NTLs are expected to minimize impacts. No significant incremental 

cumulative impacts to socioeconomics are expected as a result of the proposed 

activities as well as other reasonably foreseeable future activities in the area. 

5.0 ENVIRONMENTAL HAZARDS 

The proposed activities could be adversely impacted by strong environmental phenomena 

(e. g. hurricanes). BP’s Severe Weather Contingency Plan identifies the thresholds (e. g. 

wind speed, current speed) at which such impacts may occur and describes the 

consequences and measures BP will take to mitigate those impacts. 

6.0 ALTERNATIVES 

No Action Alternative - This alternative would result in no impact from the proposed 

action but could discourage the development of much needed hydrocarbon resources, and 

thereby result in a loss of royalty income for the United States and energy for America. 

This alternative was not selected. 

Approval of the Proposed Action - Measures that BP proposes to implement to limit 

potential environmental effects are discussed in the EP. The BOEMRE’s lease 

stipulations, OCS Operating Regulations, NTLs, and other regulations and laws were 

identified throughout this environmental impact analysis as existing mitigation to 

minimize potential environmental effects associated with the proposed action. 

Considering the mitigative measures, this alternative was selected for evaluation in this 

EIA. 

7.0 MITIGATION MEASURES 

The EP contains numerous mitigation measures required by laws and regulations, lease 

stipulations and NTL’s. Additional mitigation measures include: 

• Low sulfur fuel to be used. 

• NPDES permit compliance will minimize potential environmental impact. 

• Water treatment equipment will be effectively operated and maintained to reduce 

pollutant discharge. 

• A waste minimization plan will be followed for ongoing operations to recycle and 

source reduce waste. 

BP is covered by a Regional OSRP approved by the BOEMRE. BP has contracts in-place 

with three (3) Oil Spill Removal Organizations (OSRO's): The National Response 

Corporation (NRC), the Marine Spill Response Organization (MSRC), and Clean Gulf 

Associates (CGA). NRC, MSRC and CGA will provide both equipment and trained 

personnel in the event an oil spill response is mounted as a result of BP's proposed 
Environmental Impact Analysis, Keatley Canyon Block 93 

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July 2011 

5929E 49 of 67 C-K Associates, LLC 

activities described in the Plan. BP has a contract in place with Marine Well Containment 

Company (MWCC) which provides well containment capabilities. 

8.0 CONSULTATION 

No agencies or persons were consulted regarding potential impacts associated with the 

proposed activities. 

9.0 PREPARERS 

The EIA was prepared by the following: 

James Durbin – Sr. Environmental Scientist 

Brad Marler – Sr. Environmental Scientist 

Keith Nichols – Sr. Environmental Scientist 

Dan Strecker – Sr. Environmental Scientist 

Tre’ Wharton – Sr. Environmental Scientist 

Chad Leblanc – Sr. GIS Specialist 

C-K Associates, LLC 

17170 Perkins Rd. 

Baton Rouge, LA 70810 

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Austin, TX. 
Environmental Impact Analysis, Keatley Canyon Block 93 

BP Exploration & Production, Inc. 

July5, 2011 

5929E C-K Associates, LLC

FIGURES 
Environmental Impact Analysis, Keatley Canyon Block 93 

BP Exploration & Production, Inc. 

July5, 2011 

5929E C-K Associates, LLC

FIGURE 1 

SITE LOCATION MAP 

KEATHLEY CANYON 
66 MILES

WESTERN

PLANNING AREA

CENTRAL

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200

2000

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2000

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GULF OF MEXICO

FIGURE 1

CAL/AM9.2

BM

BM

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Dwg. No.: A5929E-01

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0 25 50 100

Miles

DESIGNATED TOPOGRAPHIC

FEATURES

BP EXPLORATION AND PRODUCTION, INC.

ENVIRONMENTAL IMPACT ANALYSIS

HOUSTON, TEXAS

SOURCES

 

	








Legend

Bank Location

Bathymetric Contour

Planning Areas

Protraction Areas

Blocks

A S S O C I A T E S , L L C

ENVIRONMENTAL & ENGINEERING

Minerals Management Service - Gulf of Mexico Region (MMS - GOMR) GulfOfMexico.mdb CONSULTANTS
Environmental Impact Analysis, Keatley Canyon Block 93 

BP Exploration & Production, Inc. 

July5, 2011 

5929E C-K Associates, LLC

FIGURE 2 

SITE LOCATION MAP 

PINNACLE TREND AREA 
353 MILES

WESTERN

PLANNING

AREA

CENTRAL

PLANNING AREA

EASTERN

PLANNING

AREA

Baldwin

Vernon

Mobile

Clarke

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Newton

Perry

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Calcasieu

Beauregard

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200

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FIGURE 2

CAL/AM9.2

BM

BM

5/20/11

Dwg. No.: A5929E-02

Drawn:

Checked:

Approved:

Date:

0 50 100 200

Miles

PINNACLE TREND AREA

BP EXPLORATION AND PRODUCTION, INC.

ENVIRONMENTAL IMPACT ANALYSIS

HOUSTON, TEXAS

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Legend

Bathymetric Contour

Planning Areas

Protraction Areas








A S S O C I A T E S , L L C

ENVIRONMENTAL & ENGINEERING

Minerals Management Service - Gulf of Mexico Region (MMS - GOMR) GulfOfMexico.mdb CONSULTANTS
Environmental Impact Analysis, Keatley Canyon Block 93 

BP Exploration & Production, Inc. 

July5, 2011 

5929E C-K Associates, LLC

FIGURE 3 

SITE LOCATION MAP 

CHEMOSYNTHETIC COMMUNITIES 
50 MI

CENTRAL

WESTERN PLANNING AREA

PLANNING AREA

Polk Tyler

Vernon

Mobile

Cameron

Liberty

Rapides

Allen

Jasper

Baldwin

Vermilion

Hardin

Amite

Terrebonne

Newton

Perry

Lafourche

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Jefferson

Grant

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St. Landry

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Jones

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St. Tammany

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Trinity

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St. Helena

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East Feliciana

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St. Charles

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Galveston

Cherokee

San Jacinto

St. John the Baptist

West Baton Rouge

Houston

Copiah

Monroe

Winn Choctaw

Brazoria

200

2000

1000

3000

1000

2000

2000

200

3000

GULF OF MEXICO

FIGURE 3

CAL/AM9.2

BM

BM

5/20/11

Dwg. No.: A5929E-03

Drawn:

Checked:

Approved:

Date:

A S S O C I A T E S , L L C

ENVIRONMENTAL & ENGINEERING

CONSULTANTS

0 50 100 200

Miles

CHEMOSYNTHETIC COMMUNITIES

BP EXPLORATION AND PRODUCTION, INC.

ENVIRONMENTAL IMPACT ANALYSIS

HOUSTON, TEXAS

SOURCES





	


Legend

Known Chemosynthetic Community

Bathymetric Contour

Planning Area

Protraction Areas

Blocks






Minerals Management Services - Gulf of Mexico Region (MMS - GOMR) GulfOfMexico.mdb
Environmental Impact Analysis, Keatley Canyon Block 93 

BP Exploration & Production, Inc. 

July5, 2011 

5929E C-K Associates, LLC

FIGURE 4 

SITE LOCATION MAP 

GULF OF MEXICO 
226 MILES (To South Padre Island)

197MILES(ToHollyBeach,LA)

257 MILES (To Port Fourchon)

327 MILES (To Breton National Wildl

172.4 MILES (To Closest Shoreline)

Cameron

Kenedy

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Nueces

Matagorda

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Iberia

St. Mary

Willacy

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Calhoun

Galveston

Aransas

Keathley Canyon

0 25 50 100

Miles SOURCES

 

	








Legend

Planning AreaProtraction AreasBlocksGulf County / Parish

Forest ServiceFish and Wildlife ServiceNational Park Service GU

A S S O C I A T E S , 

ENVIRONMENTAL & ENGINE

CONSULTANTS

COASTAL W

BP EXPLORATIO

ENVIRONME

HO

Minerals Management Services - Gulf of Mexico Region (MMS - GOMR) GulfOfMexico.mdb
________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 12/15/11 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: BP Confidential Page: Page 35 of 37 

Warning:. Check DW Docs revision to ensure you are using the correct revision. 

Appendix G: Oil Spill Response Discussion 
 GILA KC 93 

Revised 10/19/11

Worst Case Discharge scenario for Gila, KC 93 

1) Worst Case Summary 

BP has estimated its worst-case scenario for discharge from a mobile drilling 

rig operation that may occur from Gila. Given the anticipated reservoir 

thickness and historical productivity index, the worst-case discharge is 

estimated to be 70,000 barrels of crude oil per day. Calculations are based 

on formulas defined by BSEE regulations. 

2) Facility Information 

 Type of Operation: Exploration 

 Facility Name: Gila 

 Area and Block: KC 93 

 Latitude: 26° 51’ 46.813” 

 Longitude: -93° 39’ 34.194” 

 Distance to Shore: 172.4 miles 

 Water Depth: 4,853 feet 

 API Gravity: 33° (Estimated) 

 Oil Storage Volume: 0 barrels 

3) Worst Case Discharge Volume 

Criteria Barrels 

Estimated highest capacity well uncontrolled blowout volume 

associated with exploration well 70,000 

TOTAL WORST CASE DISCHARGE 70,000 

4) Land Segment Identification 

In compliance with NTL 2006-G21, BP has determined the land areas that 

could be potentially impacted by a potential KC 93 oil spill using the BSEE 

Oil Spill Risk Analysis Model (OSRAM) trajectory results. The OSRAM 

estimates the probability that oil spills from designated locations would 

contact shoreline and offshore natural resources. (Whether and where a 

particular spill would reach shore is dependent on various factors, such as 

weather, currents, and product characteristics and, as a result, actual oil 

movement in the event of a spill may vary from the OSRAM results.) These 

probabilities are intended to indicate, in terms of percentage, the computed 

likelihood that an oil spill occurring in a particular launch area will contact a 

certain county or parish within 3, 10, and 30 days. 

OCS Launch Block #25 was utilized as Gila’s point of origin. Land segments 

identified by the model are listed below (referenced from “Oil-Spill Risk 

Analysis: Contingency Planning Statistics for Gulf of Mexico OCS Activities” 

– OCS Report MMS 2004-026): 
 GILA KC 93 

Revised 10/19/11

Area and Spill Site Land Segment Contact Percent Impact Chance 

(Days) 

Land Segment No. & 

County/ Parish & State 3 10 30 

Cameron, TX -- -- 1 

Kenedy, TX -- -- 2 

Kleberg, TX -- -- 2 

Nueces, TX -- -- 1 

Aransas, TX -- -- 2 

Calhoun, TX -- -- 2 

Matagorda, TX -- -- 6 

Brazoria, TX -- -- 2 

Galveston, TX -- -- 4 

Jefferson, TX -- -- 2 

Cameron, LA -- -- 4 

Keathley 

Canyon 

93

Vermilion, LA -- -- 2 

5) Resource Identification 

The land segment that has the highest computed probability of being 

impacted by a release from KC 93, within 30 days, is Matagorda County, 

Texas, at 6 percent. Sources which may be used to identify the sensitive 

resources located within Matagorda County are identified in the Regional 

OSRP, Section 11. 

6) Response 

BP GoM has contracted with OSROs as identified in Section IX, Part A-3.

Release Modeling 

A portion of the release will either naturally disperse or evaporate. An ASA 

Spill Impact Model Application Package (SIMAP) analysis (in conjunction 

with its blowout model) was completed for a deepwater spill of medium 

crude (with a Gas-to-Oil Ratio [GOR] of 1:1) release from 5,000 feet below 

the surface. The SIMAP model uses environmental data and transport and 

weathering algorithms to calculate the mass of oil components in various 

environmental compartments (water surface, shoreline, water column, 

atmosphere, sediments, etc.), oil pathway over time (trajectory), surface oil 

distribution, and concentrations of the oil components in the water and 

sediments. Due to the deepwater nature of the release site in this scenario, 

the ASA SIMAP model was selected to predict the behavior of a release 

from KC 93. 

Based on the ASA SIMAP analysis, the amounts of the released oil that 

have dispersed into the water column, evaporated, or naturally decayed will 

leave no more than roughly 50% of the oil present at the surface. Using the 

results of this model, this would leave an estimated 35,000 barrels/day to be 

addressed by the response technologies discussed below. 
 GILA KC 93 

Revised 10/19/11

Response Technologies Discussion 

This section discusses various response technologies (in no prioritized 

order) that might be employed during a response to a release of oil from KC 

93. The particular response technologies applied during a spill event will be 

coordinated based on the most accurate and up-to-date knowledge of the 

situation, which will determine the types of technology to be used, the 

locations at which particular technologies are applied, and the 

implementation of simultaneous operations (SIMOPS). 

The status boards below set forth a representative list of equipment and are 

not meant to be exhaustive. The status boards outline on-water 

containment; on-water recovery; temporary storage; aerial, vessel and 

subsea dispersant application; in-situ burning; and shoreline protection 

equipment identified as most relevant in addressing the volume of oil that 

does not either evaporate or naturally disperse into the water column. These 

status boards estimate times needed for procurement, load out, travel time 

to the site and deployment. 

Surveillance 

Upon notification of a release and mobilization of the response, either a 

fixed-wing aircraft or a field-support helicopter would be dispatched as 

promptly as possible (considering available daylight hours, weather 

conditions, and other safety factors) in order to conduct visual surveillance at 

the source of the spill. If necessary, visual surveillance could be 

supplemented through use of field vessels. The effectiveness of many 

response technologies (such as in-situ burning, dispersant application and 

mechanical recovery) may be increased through collaboration with air-based 

spotters, who can guide these systems to oil concentrations and coordinate 

simultaneous operations (SIMOPS). Air-based spotters may be equipped 

with air to marine/ground communication equipment to facilitate immediate 

communications with marine- and land-based response assets. Vessel 

locations may also be monitored in real-time using vessel-tracking 

technologies (such as Automated Identification Systems (AIS) data, GPSbased tracking, cell phone data, etc.), which can facilitate vessels being 

deployed for optimal recovery. Further information regarding methods of 

identifying and tracking a spill on water are discussed in the Regional 

OSRP, in Section 10.
 GILA KC 93 

Revised 10/19/11

Source Containment/Source Control 

Source containment and source control operations would be implemented 

simultaneously with the above response technologies to either reduce or 

stop the flow of the well into the environment. Source containment is 

designed to temporarily stop or redirect the flow from the well. Source 

control addresses the original source through either well-kill operations or 

the drilling of a relief well to permanently stop the flow of oil from the well. 

The steps applied to achieve flow containment will be dependent on the 

specific characteristics and nature of the spill at hand. This could include 

multidisciplinary initiatives to recover flow to the surface for contained 

processing and disposal, efforts to shut-in flow at the source using pressurerated, tight-seal, fit-for-purpose assemblies, and techniques to kill (cease 

pressure source) the well. See Section 6 of the Regional OSRP for a nonexhaustive list of potentially applicable techniques. 

Slick (Fresh Oil) Containment Systems 

Slick (fresh oil) containment systems may be deployed (provided it is safe to 

do so) in thick, fresh oil to minimize further spreading of oil on the water’s 

surface. These systems would typically consist of two offshore vessels 

(capable of trolling speeds of 0.5 knots) towing between 1,000-1,500 feet of 

offshore boom in a “U” or “V” configuration. The containment systems may 

allow fresh oil to be contained, concentrated, and diverted to both skimming 

systems and in-situ burn task forces, as appropriate, increasing their 

encounter rate and containment efficiency to support enhanced skimming 

and burning operations. 

Mechanical Recovery 

Mechanical recovery equipment, including Oil Spill Response Vessels 

(OSRVs), Oil Spill Response Barges (OSRBs), and Vessel of Opportunity 

Skimming Systems (VOSS), may be mobilized from contracted OSROs. As 

necessary, response equipment could be cascaded from locations along the 

Gulf of Mexico and other regions of the United States, as well as from 

international locations. This equipment could be deployed either at the 

source of the release or in concentrations of recoverable oil. Offshore 

mechanical recovery assets could be organized according to span of control 

concepts within ICS. Vessels should be organized into task forces or groups 

with consideration for effective communication and control. As operations 

increase in scale or complexity, dedicated command/control vessel(s) may 

be considered for each major operating area or mission. These vessels 

could provide response activity coordination of all marine assets under their 

control, as well as provide communication between marine and air assets. 

Additionally, other technologies (like GPS-based vessel tracking systems) 

may be used to facilitate coordination of marine assets. Positioning this 

equipment can be facilitated by collaboration with air-based spotters, who 

can guide these systems to oil concentrations. During night-time operations, 

skimming activities could be facilitated through the use of alternative spill 
 GILA KC 93 

Revised 10/19/11

surveillance technologies (such as infrared [IR] and X-band radio systems) 

to guide skimming vessels to sufficient concentrations of oil. The specific 

technologies used will be chosen based on availability suitability, OSRO 

recommendations, and other situation-specific considerations. 

The Offshore On-Water Recovery Equipment and Offshore On-Water 

Storage status boards below identify response resources that could be 

mobilized to address a release from KC 93. The combined Effective Daily 

Recovery Capacity (EDRC) for dedicated skimming vessel systems is 

110,777 barrels; total storage volume for these dedicated systems is 

132,245 barrels. (EDRC represents a planning standard mandated by 

governing regulations [30 CFR § 254.44(a)] and is required to be specified in 

an OSRP. Actual performance of mechanical recovery systems in 

responding to an oil spill will depend on many situation-specific factors, such 

as: oil encounter rates, access to heavy concentrations of fresh oil, oil 

emulsification, and others. As a result, oil volumes recovered may be 

significantly lower than stated EDRC volumes.) 

Aerial Dispersant Application 

Aerial dispersants may be a response option depending on the 

circumstances of the release. Aerial dispersants are applied under the 

direction and approval of a designated Federal On-Scene Coordinator 

(FOSC), and in a manner consistent with the National Contingency Plan and 

the applicable Regional Response plan(s) and/or Area Contingency Plans 

(ACPs). Spotter aircraft could be activated along with aerial dispersant 

aircraft to coordinate more precise dispersant application on concentrations 

of free-floating oil and prevent dispersant operations from impacting other 

ongoing response technologies during SIMOPS. The table below identifies 

aerial dispersant application aircraft to which BP GoM has contractual 

access, as well as their response capacities. A table listing the dispersant 

stockpile available to BP GoM may be found in Section 18 of the Regional 

OSRP. 

Aircraft Owner/ Contractor Dispersant 

Capacity 

Possible 

Sorties/Day 

Regional Assets 

DC-3 ASI (through CGA) 1,200 gallons 1-2 

BT-67 

(DC-3 Turboprop)

ASI (through CGA) 2,000 gallons 1-2 

C-130 MSRC 3,250 gallons 1-3 

Out-of-Region Assets 

C-130 CCA 5,000 gallons 1-3 

Hercules L382G OSR 5,000 gallons 1-3 

For planning purposes, BP GoM assumes a 1:20 application rate and 

approximately a 50% to 75% effectiveness rate. Based on the estimates 

regarding aircraft dispersant capacities identified in the table above, 16,450 

to 65,800 gallons of dispersant could be applied per day, which translates to 

approximately 3,917 to 23,500 barrels/day. 
 GILA KC 93 

Revised 10/19/11

Vessel-Based Dispersant Application 

Vessel-based dispersant application may be another available response 

option. In previous responses, boat-spray systems were used for both 

dispersing oil and suppressing vapors on the water surface near the spill 

source. Vessel-based dispersants are also applied under the direction and 

approval of a designated Federal On-Scene Coordinator (FOSC), and in a 

manner consistent with the National Contingency Plan and the applicable 

Regional Response Plan(s) and/or Area Contingency Plans (ACPs). If 

appropriate, vessel spray systems can be installed on offshore vessels of 

opportunity to apply dispersants at the source, or at other areas where there 

are significant concentrations of oil. Using inductor nozzles installed on firewater monitors, skid mounted systems, or purpose-built boom-arm spray 

systems, vessels can initially apply dispersant beginning in the first 12 to 24 

hours of the response, and thereafter as needed. 

Subsea Dispersant Application 

Depending on the circumstances, the use of a subsea dispersant application 

system may provide a response option in the event of a subsurface well 

blowout or other ongoing subsurface release. A modular Subsea Dispersant 

Application Unit (SDAU)—including an integrated chemical storage, 

distribution, and deployment system—may be installed at the spill site in 

close proximity to the release. 

The subsea application of dispersants is a new variation on proven 

dispersant technology. Therefore, certain assumptions, including application 

rates and effectiveness, have been made based on recent experience. 

However, additional data collection, laboratory tests, and field tests are likely 

to be undertaken by industry, government, and/or academia, and will help 

evaluate further the optimal application rates and anticipated effectiveness 

rates for subsea application of dispersants. For planning purposes, and 

subject to obtaining regulatory approval, BP assumes a 1:75 application 

rate, at 50% to 75% effectiveness, and a system flow rate of 8 to 11 gallons 

per minute (approximately 11,500 to 16,000 gallons of dispersant per day). 

(During a recent response, the EPA limited sub surface dispersant usage to 

15,000 gallons per day.) Under those assumptions, the system might be 

capable of dispersing approximately 10,268 to 21,429 barrels of oil per day. 

A table listing the dispersant stockpile available to BP GoM may be found in 

Section 18 of the Regional OSRP. 

In-Situ Burning 

Open-water in-situ burning (ISB) also may be used as a response strategy 

depending on the circumstances of the release. ISB services may be 

provided by the primary OSRO contractors. If appropriate conditions exist 

and approvals are granted, one or multiple ISB task forces could be 

deployed offshore. Task forces typically consist of two to four fire teams, 

each with two vessels capable of towing fire boom, guide boom, or tow line 

with either a handheld or aerially-deployed oil ignition systems. At least one 
 GILA KC 93 

Revised 10/19/11

support/safety boat would be present during active burning operations to 

provide logistics, safety, and monitoring support. Depending upon a number 

of factors, including the weather conditions and the nature and distribution of 

oil, up to 4 burns per 12-hour day could be completed per ISB fire team. 

Depending on weather and fire intensity, most fire boom systems can be 

used for approximately 8 to 12 burns before being replaced. Although the 

number of barrels eliminated per burn is dependent on many factors, 

experience suggests that a typical burn might eliminate approximately 600 to 

750 barrels per burn. Based on those assumptions, a single task force of 

two fire teams, assuming appropriate conditions including weather and 

safety—each completing four burns per day—might be capable of removing 

up to approximately 4,800 to 6,000 barrels of oil per day. (See e.g., August 

2010 reports: “Deepwater Horizon MC252 Gulf Incident Oil Budget” and “BP 

Deepwater Horizon Oil Budget: What Happened to the Oil?”) Additional 

information on ISB is presented in Section 19 in the Regional OSRP. 

Shoreline Response

While historical trajectory modeling is important for planning response 

tactics, the potential direction and impact of a spill depends heavily upon 

existing environmental conditions during an actual response. Strategies 

developed during tactical planning would be based upon surveillance and 

real time trajectories that depict areas of potential impact given actual sea 

and weather conditions. Near shore response may include the deployment 

of shoreline boom to protect beach areas, or protection and sorbent boom 

for vegetated areas. The Area Contingency Plan and relevant agencies—

including, as appropriate, “branch offices” similar to those stood in previous 

responses—should be consulted to provide assurance that environmental, 

special economic, and cultural resources are correctly identified and 

prioritized to provide optimal protection. If impact does occur, onshore 

cleanup response may include specialized beach and marsh cleanup. 

The Response Group’s Shoreline Response Guides identify response 

strategies including equipment and personnel needs, possible tactics, and 

detailed job descriptions (ICS 204 Field Assignments) applicable for oil spill 

protection and clean-up operations. The guides are a tool for operational 

planning and logistics to initiate the procurement and deployment of 

resources while branch operations are established. Early tactical planning 

and deployment of advance (forward) teams should be considered to 

establish locations for branch offices as needed. For more information on 

resource identification, see Section 11 of the Regional OSRP. In addition, 

see Section 13 and 14 for information on resource protection methods and 

the mobilization of equipment. 



Staging ETA

Loadout 

Time

ETA to Site

Deployment 

Time

Total ETA**

42" Auto Boom (ft) 1000

* >110' Utility Boat 2

Personnel 8

Safety Monitor 2

42" Auto Boom (ft) 1000

* >110' Utility Boat 2

Personnel 8

Safety Monitor 2

42" Auto Boom (ft) 1000

* >110' Utility Boat 2

Personnel 8

Safety Monitor 2

67" Sea Sentry II Boom (ft) 1320

* >110' Utility Boat 2

Personnel 8

Safety Monitor 2

42" Inflatable Boom (ft) 1000

* >110' Utility Boat 2

Personnel 8

Safety Monitor 2

42" Inflatable Boom (ft) 1000

* >110' Utility Boat 2

Personnel 8

Safety Monitor 2

42" Inflatable Boom (ft) 1000

* >110' Utility Boat 2

Personnel 8

Safety Monitor 2

42" Inflatable Boom (ft) 1000

* >110' Utility Boat 2

Personnel 8

Safety Monitor 2

42" Auto Boom 1000

* >110' Utility Boat 2

Personnel 8

Safety Monitor 2

67" Sea Sentry II Boom (ft) 1320

* >110' Utility Boat 2

Personnel 8

Safety Monitor 2

67" Sea Sentry II Boom (ft) 1320

* >110' Utility Boat 2

Personnel 8

Safety Monitor 2

67" Sea Sentry II Boom (ft) 1320

* >110' Utility Boat 2

Personnel 8

Safety Monitor 2

** These ETAs are rounded up to the next hour.

Offshore Slick 

Containment 

System

CGA

888-242-2007

Belle 

Chasse, LA

Port 

Fourchon, 

LA

263 4.5 1 19 1 26

Offshore Slick 

Containment 

System

CGA

888-242-2007

Belle 

Chasse, LA

Port 

Fourchon, 

LA

263 4.5 1 19 1 26

1 19 1

Skimming 

System

Supplier 

& Phone Warehouse Containment Package

Quantity

Staging Area

Distance to

Site from 

Staging (Miles)

Response Times (Hours)

KC 93 Exploratory WCD

Potential Offshore Slick Containment Status Board

1 19 1 26

Offshore Slick 

Containment 

System

MSRC

800-OIL-SPIL

Belle 

Chasse, LA

Port 

Fourchon, 

LA

263 4.50

1 19 1 26

Offshore Slick 

Containment 

System

NRC

800-899-4672

New Iberia, 

LA

Port 

Fourchon, 

LA

263 4.75

19 1 26

Offshore Slick 

Containment 

System

NRC

800-899-4672

New Iberia, 

LA

Port 

Fourchon, 

LA

263 4.75

28

Offshore Slick 

Containment 

System

NRC

800-899-4672

New Iberia, 

LA

Port 

Fourchon, 

LA

263 4.75

Offshore Slick 

Containment 

System

MSRC

800-OIL-SPIL

Lake 

Charles, LA

Port 

Fourchon, 

LA

263 6.5

27

Offshore Slick 

Containment 

System

MSRC

800-OIL-SPIL

Pascagoula, 

MS

Port 

Fourchon, 

LA

263 6

1 19 1 30

Offshore Slick 

Containment 

System

MSRC

800-OIL-SPIL

Galveston, 

TX

1 19 1 26

Offshore Slick 

Containment 

System

NRC

800-899-4672

New Iberia, 

LA

Port 

Fourchon, 

LA

263 4.75

Port 

Fourchon, 

LA

263 9

27

1 19 1

* Additional equipment to be procured by OSROs for deployment

TOTAL SLICK CONTAINMENT BOOM AVAILABLE (FEET) 13,280

25

Offshore Slick 

Containment 

System

CGA

888-242-2007

Pascagoula, 

MS

Port 

Fourchon, 

LA

263 6 1 19 1

1 19 1 26

Offshore Slick 

Containment 

System

CGA

888-242-2007 Houma, LA

Port 

Fourchon, 

LA

263 4 1 19 1

1


Staging ETA

Loadout Time

ETA to Site

Deployment 

Time

Total ETA

Aero Commander 1

Spotter Personnel 2

Crew - Pilots 1

DC-3 Dispersant Aircraft 1

Dispersant - Gallons 2000

Spotter Aircraft 1

Spotter Personnel 2

Crew - Pilots 2

DC-3 Dispersant Aircraft 1

Dispersant - Gallons 1200

Spotter Aircraft 1

Spotter Personnel 2

Crew - Pilots 2

C130-A Dispersant Aircraft 1

Dispersant - Gallons 3250

Spotter Aircraft 1

Spotter Personnel 2

Crew - Pilots 2

L-382 Hercules Aircraft 1 24.2

ADDS PACK 1 to

Dispersant - Gallons 5000 44.2

Spotter Aircraft 1

Spotter Personnel 2

Crew - Pilots 2

C-130 Aircraft (contractor) 1 27.6

ADDS PACK 1 to

Dispersant - Gallons 5000 51.6

Spotter Aircraft 1

Spotter Personnel 2

Crew - Pilots 2

2-4 15.68 0.5

351 1.06 0.3 1.06

Stennis

INTL, MS

2nd Flight

Stennis

INTL, MS

1st Flight

5,176

Clearwater, 

FL

1st Flight

677 24-48 1 2.05 0.5

1.06 0.5 2.93

Aerial 

Dispersant 

System

Supplier 

& Phone

Distance to

Site from 

Staging (Miles)

Response Times (Hours)

Quantity

Staging Area

Warehouse Aerial Dispersant 

Package

Houma, LA

DC-3 (BT-67) 

Aircraft

Air Speed - 194 

MPH

Airborne 

Support

985-851-6391

Houma, LA Houma, LA 261 2 0.4 0.91 0.2 3.55

Stennis 

INTL., MS

2nd Flight

210

351 1.03 0.3 1.03

0.5

ADDS PACK

Air Speed - 330 

MPH

Clean 

Carribean

985-851-6391

Pt. Everglades, 

FL

351 1.06 0.3

Stennis

INTL, MS

2nd Flight

0.5

0.3

ADDS PACK

Air Speed - 330 

MPH

Oil Spill 

Response

+44 (0) 1224-

72-6859

South 

Hampton, UK

6-24

2.90

2.93

Aero 

Commander

Air Speed - 288 

MPH

1.35 0.3 3.50

9.45

DC-3 Aircraft

Air Speed - 150 

MPH

Airborne 

Support

985-851-6391

Airborne 

Support

985-851-6391

Houma, LA

4.15

Houma, LA

2nd Flight 261 1.35 0.5

0.5 1.35 0.3

C130-A Aircraft

Air Speed - 342 

MPH

MSRC

800-OIL-SPIL Coolidge, AZ

Ellington 

Field, TX

1st Flight

8

KC 93 Exploratory WCD

Potential Offshore Aerial Dispersant Status Board

Houma, LA

1st Flight 261 2 0.5 1.74 0.3 4.55

Houma, LA

2nd Flight 261 1.74 0.5 1.74 0.3 4.30

Houma, LA

1st Flight 261 2

0.61

0.5
Staging ETA

Loadout 

Time

ETA to Site

Deployment 

Time

Total ETA**

Dispersant Spray System 1

Dispersant (Gallons) 500

Personnel 4

* Crew Boat 1

Dispersant Spray System 1

Dispersant (Gallons) 500

Personnel 4

* Offshore Vessel 1

Dispersant Spray System 1

Dispersant (Gallons) 330

46' Vessel 1

Personnel 4

Personnel 4

* Offshore Vessel 1

Dispersant Spray System 1

Dispersant (Gallons) 500

Personnel 4

* Offshore Vessel 1

Dispersant Spray System 1

Dispersant (Gallons) 300

46' Vessel 1

Personnel 4

** These ETAs are rounded up to the next hour.

Fourchon, LA Fourchon, 

LA

1 19 0.5

1

19

1

0.5

19

0.5

* Additional equipment to be procured by OSROs for deployment

Response Times (Hours)

Quantity

Staging Area

Distance to

Site from 

Staging (Miles)

4

27

Fourchon, 

LA 263 4

6.25

Vessel Based 

Dispersant 

Spray System

0.5

Fire Monitor 

Induction 

Dispersant 

Spray System

Fire Monitor 

Induction 

Dispersant 

Spray System

AMPOL

800-482-6765 Cameron, LA Fourchon, LA 263 7 1

263

NRC

800-899-4672

Morgan City, 

LA

Boat Spray 

Dispersant 

System

Supplier 

& Phone

USCG SMART 

Team

Warehouse Boat Spray Dispersant 

Package

263 AMPOL

800-482-6765

USCG Mobile, AL Fourchon, 

LA

25

25

28

19

29

26

KC 93 Exploratory WCD 

Potential Offshore Boat Spray Dispersant Status Board

Skid-mounted 

Boat-Spray 

Dispersant 

System

CGA

888-CGA-2007 Venice, LA Venice, LA 324 4 0.5 23 1

Skid-mounted 

Boat-Spray 

Dispersant 

System

CGA

888-CGA-2007 Houma, LA Houma, LA 279 4 0.5 20 1

Staging ETA

Loadout Time

ETA to Site

Deployment 

Time

Total ETA**

Lori Brush Skimmer 1

56" Boom 50'

46' Vessel 1

Personnel 4

Lori Brush Skimmer 1

56" Boom 50'

46' Vessel 1

Personnel 4

LORI Brush Skimmer 1

Personnel 4

47' Fast Response Boat 1

Lori Brush Skimmer 1

56" Boom 50'

46' Vessel 1

Personnel 4

Lori Brush Skimmer 1

56" Boom 50'

46' Vessel 1

Personnel 4

Skimmer 1

20" Boom 50'

Personnel 4

Push Boat 1

Towable Bladder 1 400

Skimmer 1

20" Boom 50'

Personnel 4

Utility Boat 1

Towable Bladder 1 500

Weir Disc Skimmer 1

18"-21" Boom 200'

Personnel 4

Portable Barge Set * 1

Marco Belt Skimmer 1

18" Boom (contractor) 100'

Personnel 3

38' Skimming Vessel 1

Belt Skimmer 1

18" Boom 100'

Personnel 3

38' Skimming Vessel 1

Shallow Water Barge 1 249

Marco Belt Skimmer 1

18" Boom (contractor) 100'

Personnel 3

36' Skimming Vessel 1

Shallow Water Barge 1 249

Offshore Barge 1

Personnel 4

Offshore Tug 1

VOSS w/ 

AARDVAC

MSRC

800-645-7745

Pascagoula, 

MS 3,840

Port 

Fourchon, 

LA

263 6 1

MSRC

800-645-7745 Ingleside, TX 5,000 50 Ingleside, TX 238 2 1

279 4 1 CTCo-5001 

Offshore Barge

CGA

888-CGA2007

Houma, LA N/A 45,000 Houma, LA

Houston, TX 1,371 238

Port 

Fourchon, 

LA

* Additional equipment to be procured by OSROs for deployment

** These ETAs are rounded up to the next hour.

DERATED RECOVERY RATE (BBLS/DAY) 41,758

SKIMMING VESSEL STORAGE CAPACITY (BARRELS) 47,504

263 6 1 19 1 27

263 9 1

SBS w/GT-185 MSRC

800-645-7745

Pascagoula, 

MS 1,371 400 Port 

Fourchon, 

LA

KC 93 Exploratory WCD

Potential Nearshore On-Water Recovery Status Board

Skimming 

System

Supplier 

& Phone Warehouse Skimming Package

Quantity

Effective Daily 

Recovery Capacity 

(EDRC in Bbls/Day) 

Storage (Barrels)

Staging Area

Distance to

Site from Staging 

(Miles)

Response Times (Hours)

CGA-53 MARCO 

Shallow Water 

Skimmer

CGA

888-CGA2007Houma, LA 3,588

Port 

Fourchon, 

LA

34

CGA-52 MARCO 

Shallow Water 

Skimmer

CGA

888-CGA2007Venice, LA 3,588

Port 

Fourchon, 

LA

34

CGA

888-CGA2007Galveston, TX 5,000 65

M/V Bastian Bay

CGA

888-CGA2007

Lake Charles, 

LA 5,000 65 Lake 

Charles, LA

CGA-54 

Egmopol 

Shallow Water 

Skimmer

CGA

888-CGA2007Houma, LA 3,000

Port 

Fourchon, 

LA

90

NRC Weir Disc 

103

NRC 

800-899-4672

226 2 1

Galveston, 

TX 191 2 1

M/V Grand Bay

CGA

888-CGA2007Venice, LA 5,000 65

M/V RW 

Armstrong

CGA

888-CGA2007Houma, LA 5,000 65 Houma, LA 279 2 1

MSRC "Quick 

Strike"

CGA 58 

Timbalier Bay

17 1 21

19 1 27

13.5 1

16 1 20

18

20 0.5 24

Venice, LA 324 2 1 23 1 27

263 4 1 29 1 35

1

19 1 30

263 4 29 35

263 6 1 29

1

1 37

33.5 1 40

________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 15-Dec-2011 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: Public Information Page: Page 36 of 37 

Warning:. Check DW Docs revision to ensure you are using the correct revision. 

Appendix H: Coastal Zone Management Act (CZMA) 

Consistency Certification 
BP EXPLORATION & PRODUCTION 

COASTAL ZONE MANAGEMENT 

ACT CONSISTENCY 

for 

Keathley Canyon Block 93 

SEPTEMBER 2010 

Prepared by: 

C-K Associates, LLC 

17170 Perkins Road 

Baton Rouge, Louisiana 70810 

(225) 755-1000 

C-K Associates’ Project 5929E
Coastal Zone Management Act Consistency for Keathley Canyon Block 93 

BP Exploration & Production, Inc. 

September 2010 

5929E i C-K Associates, LLC 

TABLE OF CONTENTS 

Section Page

1.0 COASTAL ZONE MANAGEMENT ACT INFORMATION ........................................1 

2.0 CONSISTENCY CERTIFICATION.................................................................................1 

3.0 LOUISIANA COASTAL ZONE MANAGEMENT PROGRAM...................................1 

 A. GUIDELINES APPLICABLE TO ALL USES...........................................................1 

 B. GUIDELINES FOR LINEAR FACILITIES...............................................................4 

 C. GUIDELINES FOR DREGE SPOIL DEPOSITION.................................................4 

 F. GUIDELINES FOR SURFACE ALTERATIONS .....................................................4 

G. GUIDELINES FOR HYDROLOGIC AND SEDIMENT TRANSPORT 

MODIFICATIONS........................................................................................................4 

H. GUIDELINES FOR DISPOSAL OF WASTES..........................................................4 

I. GUIDELINES FOR USES THAT RESULT IN THE ALTERATION OF 

WATERS DRAINING INTO COASTAL WATERS.................................................5 

J. GUIDELINES FOR OIL, GAS AND OTHER MINERAL ACTIVITIES ...............5 

4.0 TEXAS COASTAL ZONE MANAGEMENT PROGRAM ............................................6 

CATEGORY 2 Construction, Operation and Maintenance of Oil and Gas 

Exploration and Production Facilities (Rule §510.17) .........................7 

CATEGORY 3 Discharges of Wastewater and Disposal of Waste from Oil and Gas 

Exploration and Production Activities (Rule §501.18) ........................8 

CATEGORY 4 Construction and Operation of Solid Waste Treatment, Storage, 

and Disposal Facilities (Rule §501.19) ...................................................9 

CATEGORY 5 Prevention, Response, and Remediation of Oil Spills Rule §501.20....10 

CATEGORY 6 Discharge of Municipal and Industrial Waste Water to Coastal 

Waters Rule §501.21................................................................................10 

CATEGORY 7 Non Point Source Pollution (Rule §501.22) ...........................................11 

CATEGORY 8 Development in Critical Areas (Rule §501.23)......................................11 

CATEGORY 9 Construction of Waterfront Facilities and Other Structures on 

Submerged lands (Rule §501.24)............................................................14 

CATEGORY 10 Dredging and Dredged Material Disposal and Placement (Rule 

§501.25).....................................................................................................17 

CATEGORY 11 Construction in the Beach / Dune System (Rule §501.26)..................17 

CATEGORY 12 Development in Coastal Hazard Areas (Rule §501.27) ......................17 

CATEGORY 13 Development within Coastal Barrier Resource (Rule §501.28).........17 

CATEGORY 14 Development in State Parks, Wildlife Management Areas or 

Preserves (Rule §501.29)........................................................................18 

CATEGORY 15 Alteration of Coastal Historic Areas (Rule §501.30)...........................18 

CATEGORY 16 Transportation Projects (Rule §501.31)...............................................18 

CATEGORY 17 Emission of Air Pollutants (Rule §501.32)...........................................18 
Coastal Zone Management Act Consistency for Keathley Canyon Block 93 

BP Exploration & Production, Inc. 

September 2010 

5929E ii C-K Associates, LLC 

TABLE OF CONTENTS 

(cont.) 

Section Page

CATEGORY 18 Appropriations of Water (Rule §501.33) .............................................18 

CATEGORY 19 Levee and Control Projects (Rule §501.34).........................................19 

CATEGORY 22 Policies for Major Actions (Rule §501.15)...........................................19 

LIST OF TABLES 

Table

1 Louisiana Guidelines 

2 Texas Guidelines 

LIST OF APPENDICES 

Appendix

A Coastal Zone Management Consistency Certification 
Coastal Zone Management Act Consistency for Keathley Canyon Block 93 

BP Exploration & Production, Inc. 

September 2010 

5929E 1 C-K Associates, LLC 

1.0 COASTAL ZONE MANAGEMENT ACT (CZMA) INFORMATION 

 (250.226 and 250.260) 

Under the direction of the Coastal Zone Management Act (CZMA), the states of 

Alabama, Florida, Louisiana, Mississippi and Texas developed Coastal Zone 

Management Programs (CZMP) to allow for the supervision of significant land and water 

use activities that take place within or that could significantly impact their respective 

coastal zones. 

2.0 CONSISTENCY CERTIFICATION 

A Coastal Zone Management Act consistency certification according to 15 CFR 

930.76(c) and (d) for Louisiana and Texas is included as Appendix A. 

3.0 LOUISIANA COASTAL ZONE MANAGEMENT PROGRAM 

Issues identified in the Louisiana CZMP include the following: general coastal 

use guidelines, levees, linear facilities (pipelines); dredges soil deposition; 

shoreline modifications, surface alterations, hydrologic and sediment transport 

modifications; waste disposal; uses that result in the alteration of waters draining 

into coastal waters; oil, gas or other mineral activities; and air and water quality. 

BP has considered all of Louisiana’s enforceable policies and certifies the 

consistency for the proposed operations. The following Louisiana Coastal 

Resource Program (LCRP) guidelines (http://dnr.louisiana.gov/CRM/coastmgt/ 

interagencyaff/consistency/pdf/Guidelines.pdf) are applicable to the proposed 

operations to Outer Continental Shelf (OCS) plan filings 

(http://www.gomr.boemre.gov/homepg/regulate/regs/ntls/enforpols.pdf): 

A. GUIDELINES APPLICABLE TO ALL USES 

Guideline 1.2: Applicable air and water quality laws and regulations 

compliance guidelines

Conformance with applicable water and air quality laws, standards and 

regulations, and with those other laws, standards and regulations which have been 

incorporated into the coastal resources program shall be deemed in conformance 

with the program except to the extent that these guidelines would impose 

additional requirements. 

Addressed in Section 5.0 (water quality) and Section 6.0 (air quality) of the 

Initial Exploration Plan for Keathley Canyon Block 93 (plan). 
Coastal Zone Management Act Consistency for Keathley Canyon Block 93 

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Guideline 1.6: General factors that will be utilized by the permitting 

authority 

Information regarding the following general factors shall be utilized by the 

permitting authority in evaluating whether the proposed use is in compliance with 

the guidelines. 

a) type, nature and location of use. 

b) elevation, soil and water conditions and flood and storm hazard characteristics 

of site. 

c) techniques and materials used in construction, operation and maintenance of 

use. 

d) existing drainage patterns and water regimes of surrounding area including 

flow, circulation, quality, quantity and salinity; and impacts on them. 

e) availability of feasible alternative sites or methods for implementing the use. 

f) designation of the area for certain uses as part of a local program. 

g) economic need for use and extent of impacts of use on economy of locality. 

h) extent of resulting public and private benefits. 

i) extent of coastal water dependency of the use. 

j) existence of necessary infrastructure to support the use and public costs 

resulting from use. 

k) extent of impacts on existing and traditional uses of the area and on future 

uses for which the area is suited. 

l) proximity to and extent of impacts on important natural features such as 

beaches, barrier islands, tidal passes, wildlife and aquatic habitats, and forest 

lands. 

m) the extent to which regional, state and national interests are served including 

the national interest in resources and the siting of facilities in the coastal zones 

as identified in the coastal resources program. 

n) proximity to, and extent of impacts on, special areas, particular areas, or other 

areas of particular concern of the state program or local programs. 

o) likelihood of, and extent of impacts of, resulting secondary impacts and 

cumulative impacts. 

p) proximity to and extent of impacts on public lands or works, or historic, 

recreational or cultural resources. 

q) extent of impacts on navigation, fishing, public access, and recreational 

opportunities. 

r) extent of compatibility with natural and cultural setting. 

s) extent of long term benefits or adverse impacts. 

Addressed in sections 4.0 through 14.0 of the plan. 
Coastal Zone Management Act Consistency for Keathley Canyon Block 93 

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Guideline 1.7: Adverse effects from land and water uses in the coastal areas

It is the policy of the coastal resources program to avoid the following adverse 

impacts. To this end, all uses and activities shall be planned, sited, designed, 

constructed, operated and maintained to avoid to the maximum extent practicable 

significant: 

a) reductions in the natural supply of sediment and nutrients to the coastal 

system by alterations of freshwater flow. 

b) adverse economic impacts on the locality of the use and affected 

governmental bodies. 

c) detrimental discharges of inorganic nutrient compounds into coastal waters. 

d) alterations in the natural concentration of oxygen in coastal waters. 

e) destruction or adverse alterations of streams, wetland, tidal passes, inshore 

waters and waterbottoms, beaches, dunes, barrier islands, and other natural 

biologically valuable areas or protective coastal features. 

f) adverse disruption of existing social patterns. 

g) alterations of the natural temperature regime of coastal waters. 

h) detrimental changes in existing salinity regimes. 

i) detrimental changes in littoral and sediment transport processes. 

j) adverse effects of cumulative impacts. 

k) detrimental discharges of suspended solids into coastal waters, including 

turbidity resulting from dredging. 

l) reductions or blockage of water flow or natural circulation patterns within or 

into an estuarine system or a wetland forest. 

m) discharges of pathogens or toxic substances into coastal waters. 

n) adverse alteration or destruction of archaeological, historical or other cultural 

resources. 

o) fostering of detrimental secondary impacts in undisturbed or biologically 

highly productive wetland areas. 

p) adverse alteration or destruction of unique or valuable habitats, critical habitat 

for endangered species, important wildlife or fishery breeding or nursery 

areas, designated wildlife management or sanctuary areas, or forestlands. 

q) adverse alteration or destruction of public parks, shoreline access points, 

public works, designated recreation areas, scenic rivers, or other areas of 

public use and concern. 

r) adverse disruptions of coastal wildlife and fishery migratory patterns. 

s) land loss, erosion and subsidence. 

t) increases in the potential for flood, hurricane or other storm damage, or 

increases in the likelihood that damage will occur from such hazards. 

u) reductions in the long term biological productivity of the coastal ecosystem. 

Addressed in Section 14.0 of the plan. 
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Guideline 1.9: Permitting multiple uses to avoid conflict 

Uses shall to the maximum extent practicable be designed and carried out to 

permit multiple concurrent uses which are appropriate for the location and to 

avoid unnecessary conflicts with other uses of the vicinity. 

Addressed in Sections 1.0 and 2.0 of the plan. 

B. GUIDELINES FOR LINEAR FACILITIES 

Section 3.1 through Section 3.16 are not applicable. This is not a linear 

facility. 

C. GUIDELINES FOR DREGE SPOIL DEPOSITION 

Section 4.1 through Section 4.7 are not applicable, there will be no dredge 

spoil deposition. 

F. GUIUIDELINES FOR SURFACE ALTERATIONS 

Section 6.1 is not applicable. There will be no surface alterations such as 

industrial, commercial, urban, residential, and recreational. 

G. GUIDELINES FOR HYDROLOGIC AND SEDIMENT TRANSPORT 

MODIFICATIONS 

Sections 7.1, 7.3, and 7.9 are not applicable. There will be no hydrologic and 

sediment transport modifications. 

H. GUIDELINES FOR DISPOSAL OF WASTES 

Guideline 8.1: Location and operation of waste storage, treatment, and 

disposal facilities

The location and operation of waste storage, treatment, and disposal facilities 

shall be avoided in wetlands to the maximum extent practicable, and best practical 

techniques shall be used to minimize adverse impacts which may result from such 

use. 

Addressed in Sections 5.0 and 12.0 of the plan. 
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Guideline 8.2: Generation, transportation, treatment, storage, and disposal 

of hazardous waste

The generation, transportation, treatment, storage and disposal of hazardous 

wastes shall be pursuant to the substantive requirements of the Department of 

Natural Resources adopted pursuant to Act 334 of 1978 and approved pursuant to 

the Resource Conservation and Recovery Act of 1976 P.L. 94-580, and the Office 

of Conservation for injection below surface. 

Addressed in Sections 5.0 and 12.0 of the plan. 

Guideline 8.8: Approved disposal sites 

Waste shall be disposed of only at approved disposal sites. 

Addressed in Sections 5.0 and 12.0 of the plan. 

Guideline 8.9: Radioactive waste

Radioactive wastes shall not be temporarily or permanently disposed of in the 

coastal zone. 

Addressed in Sections 5.0 and 12.0 of the plan. 

I. GUIDELINES FOR USES THAT RESULT IN THE ALTERATION OF 

WATERS DRAINING INTO COASTAL WATERS 

Section 9.2 is not applicable. There will be no alteration of waters draining 

into coastal waters.

J. GUIDELINES FOR OIL, GAS AND OTHER MINERAL ACTIVITIES 

Guideline 10.3: Siting of exploration, production and refining activities 

Exploration, production and refining activities shall, to the maximum extent 

practicable, be located away from critical wildlife areas and vegetation areas. 

Mineral operations in wildlife preserves and management areas shall be 

conducted in strict accordance with the requirements of the wildlife management 

body. 

Addressed in Sections 2.0 and 14.0 of the plan. 
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Guideline 10.5: Access to sites 

Access routes to mineral exploration, production and refining sites shall be 

designed and aligned so as to avoid adverse impacts on critical wildlife and 

vegetation areas to the maximum extent practicable. 

Addressed in Sections 2.0 and 12.0 of the plan. 

Guideline 10.6: Best practical techniques for drilling and production sites 

Drilling and production sites shall be prepared, constructed, and operated using 

the best practical techniques to prevent the release of pollutants or toxic 

substances into the environment. 

Addressed in Sections 2.0, 5.0 and 7.0 of the plan. 

Guideline 10.10: Guidelines for drilling and production equipment for 

preventing adverse environmental effects 

Mineral exploration, production and refining facilities shall be designed and 

constructed using best practical techniques to minimize adverse environmental 

impacts. 

Addressed in Section 1.0 of the plan. 

Guideline 10.11: Effective environmental protection and emergency or 

contingency plans

Effective environmental protection and emergency or contingency plans shall be 

developed and complied with for all mineral operations. 

Addressed in Sections 1.0, 7.0, and 14.0 of the plan. 

BP has considered all of Louisianas’ enforceable policies and certifies the 

consistency for the proposed operations. See attached Table 1.

4.0 TEXAS COASTAL ZONE MANAGEMENT PROGRAM 

Issues identified in the Texas CZMP include the following: general coastal use 

guidelines, levees, linear facilities (pipelines); dredges soil deposition; shoreline 

modifications, surface alterations, hydrologic and sediment transport modifications; 

waste disposal; uses that result in the alteration of waters draining into coastal waters; oil, 

gas or other mineral activities; and air and water quality. 

BP has considered all of Texas’ enforceable policies and certifies the consistency for the 

proposed operations. The following Texas Coastal Management Program (TCMP) 
Coastal Zone Management Act Consistency for Keathley Canyon Block 93 

BP Exploration & Production, Inc. 

September 2010 

5929E 7 C-K Associates, LLC 

(http://info.sos.state.tx.us/pls/pub/readtac$ext.ViewTAC?tac_view=5&ti=31&pt=16&ch

=501&sch=B&rl=y) are applicable to the proposed operations to Outer Continental Shelf 

(OCS) plan filings (http://www.gomr.boemre.gov/homepg/regulate/regs/ntls/ 

enforpols.pdf): 

CATEGORY 2 Construction, Operation and Maintenance of Oil and Gas 

Exploration and Production Facilities (Rule §510.17) 

(a) Oil and gas exploration and production on submerged lands shall comply with 

the policies in this section. 

 

(1) In or near critical areas, facilities shall be located and operated and 

geophysical and other operations shall be located and conducted in such 

a manner as to avoid and otherwise minimize adverse effects, including 

those from the disposal of solid waste and disturbance resulting from the 

operation of vessels and wheeled or tracked vehicles, whether on areas 

under lease, easement, or permit or on or across access routes thereto. 

Where practicable, buffer zones for critical areas shall be established and 

directional drilling or other methods to avoid disturbance, such as 

pooling or unitization, shall be employed. Critical areas – a coastal 

wetland, oyster reef, hard substrate reef, submerged aquatic vegetation, 

or a tidal sand or mud flat. 

(2) Lessees, easement holders, and permittees shall construct facilities in a 

manner that avoids impoundment or draining of coastal wetlands, if 

practicable, and shall mitigate any adverse effects on coastal wetlands 

impounded or drained in accordance with the sequencing requirements 

in this section. 

(3) Upon completion or cessation of operations, lessees, easement holders, 

and permittees shall remove facilities and restore any significantly 

degraded areas to pre-project conditions as closely as practicable, unless 

facilities can be used for maintenance or enhancement of Coastal 

Natural resource Areas (CNRAs) or unless restoration activities would 

further degrade CNRAs. 
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CNRA – any area defined in Texas Natural Resources Code, §33.203(1) 

that is located within the coastal zone: 

 Coastal historic areas  Water under tidal influence 

 Submerged land  Coastal wetlands 

 Submerged aquatic veg.  Tidal sand or mud flats 

 Oyster reefs  Hard substrate reefs 

 Coastal barriers  Coastal shore areas 

 Gulf beaches  Critical dune areas 

 Special hazard areas  Critical erosion areas 

 Water of the open Gulf of 

Mexico 

 Coastal preserves 

(b) To the extent applicable to the public beach, the policies in this section are 

supplemental to any further restrictions or requirements relating to the beach 

access and use rights of the public. 

 

(c) The Texas General Land Office (GLO) and School Land Board (SLB) shall 

comply with the policies in this section when approving oil, gas, and other 

mineral lease plans of operation and granting surface leases, easements, and 

permits and adopting rules under the Texas Natural Resources Code, Chapters 

32, 33 and 51 - 53, governing oil and gas exploration and production on 

submerged lands. 

 

Addressed in Section 14.0 of the plan. 

CATEGORY 3 Discharges of Wastewater and Disposal of Waste from Oil and 

Gas Exploration and Production Activities (Rule §501.18) 

(a) Disposal of oil and gas waste in the coastal zone shall comply with the 

policies in this section. 

(1) No new commercial oil and gas waste disposal pit shall be located in any 

CNRA. 

 (2) Oil and gas waste disposal pits shall be designed to prevent releases of 

pollutants that adversely affect coastal waters or critical areas. 

(b) Discharge of oil and gas exploration and production wastewater in the coastal 

zone shall comply with the following policies. 

(1) All discharges shall comply with all provisions of surface water quality 

standards established by the Texas Commission on Environmental Quality 

(TCEQ) under §501.21. 
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(2) To the greatest extent practicable, new wastewater outfalls shall be located 

where the discharge will not adversely affect critical areas. Existing 

wastewater outfalls that adversely affect critical areas shall be either 

discontinued or relocated so as not to adversely affect critical areas within 

two years of the effective date of this section. 

(3) The Railroad Commission of Texas (RRC) shall notify the TCEQ and the 

Texas Parks and Wildlife Department (TPWD) upon receipt of an 

application for a new permit to discharge produced waters to waters under 

tidal influence. In determining compliance with the policies in this section, 

the RRC shall consider the effects of salinity from the discharge. 

(c) The RRC shall comply with the policies in this section when issuing permits 

and adopting rules under the Texas Natural Resources Code, Chapter 91, for 

oil and gas waste, and under Texas Water Code, Chapter 26, and the Texas 

Natural Resources Code, Chapter 91, for oil and gas wastewater discharges. 

Addressed in Section 5.0 of the plan (Part a is not applicable). 

CATEGORY 4 Construction and Operation of Solid Waste Treatment, 

Storage, and Disposal Facilities (Rule §501.19) 

Not applicable. There will be no construction and operation of new and 

existing solid waste facilities and hazardous waste facilities located within the 

coastal zone. 

CATEGORY 5 Prevention, Response, and Remediation of Oil Spills Rule 

§501.20 

(a) The GLO regulations governing prevention of, response to and remediation of 

coastal oil spills shall provide for measures to prevent coastal oil spills and to 

ensure adequate response and removal actions. The GLO regulations for 

certification of vessels and facilities that handle oil shall be designed to ensure 

that vessels and facilities are capable of prompt response and adequate 

removal of unauthorized discharges of oil. The GLO regulations adopted 

pursuant to the Oil Spill Prevention and Response Act (OSPRA), Texas 

Natural Resources Code, Chapter 40, shall be consistent with the State Coastal 

Discharge Contingency Plan adopted pursuant to OSPRA; and the National 

Contingency Plan adopted pursuant to the Federal Water Pollution Control 

Act, 33 United States Code Annotated, Chapter 26. 

(b) Natural Resource Damage Assessment (NRDA). GLO rules under OSPRA 

governing the assessment of damages to natural resources injured as the result 

of an unauthorized discharge of oil into coastal waters shall provide for 

reasonable and rational procedures for assessing damages and shall take into 

account the unique circumstances of the spill incident. The costs of assessing 
Coastal Zone Management Act Consistency for Keathley Canyon Block 93 

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the damages shall not be disproportionate to the value of the injured resources. 

Plans for the restoration, rehabilitation, replacement or acquisition of 

equivalent resources shall provide for participation by the public and shall be 

designed to promote the restoration of the injured resources with all deliberate 

speed. The GLO rules shall be consistent with other state rules and policies 

and with the CMP goals and policies. 

Addressed in Section 7.0 of the plan. 

CATEGORY 6 Discharge of Municipal and Industrial Waste Water to Coastal 

Waters Rule §501.21 

(a) TCEQ rules shall: 

(1) comply with the requirements of the Clean Water Act, 33 United States 

Code Annotated, §§1251 et seq, and implementing regulations at Code of 

Federal Regulations, Title 40, which include establishing surface water 

quality standards in order to protect designated uses of coastal waters, 

including the protection of uses for water supply, recreational purposes, 

and propagation and protection of terrestrial and aquatic life, and 

establishing water-quality-based effluent limits, including toxicity 

monitoring and specific toxicity or chemical limits as necessary to protect 

designated uses of coastal waters; 

(2) provide for the assessment of water quality on a coastal watershed basis as 

required by the Texas Water Code, §26.0135(d); 

(3) to the greatest extent practicable, provide that all permits for the discharge 

of wastewater within a given watershed or region of a single watershed 

contain the same expiration date in order to evaluate the combined effects 

of permitted discharges on water quality within that watershed or region; 

(4) identify and rank waters that are not attaining designated uses and 

establish total maximum daily pollutant loads in accordance with those 

rankings using scientifically valid models calibrated and validated with 

monitored data and with public input from affected stakeholders; and 

(5) require that increases in pollutant loads to coastal waters shall not: 

(A) impair designated uses of coastal waters; or 

(B) result in degradation of coastal waters that exceed fishable/swimmable 

quality except in cases where lowering coastal water quality is 

necessary for important economic or social development. 

(b) Discharge of municipal and industrial wastewater in the coastal zone shall 

comply with the following policies. 
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(1) Discharges shall comply with water-quality-based effluent limits. 

(2) Discharges that increase pollutant loadings to coastal waters shall not 

impair designated uses of coastal waters and shall not significantly 

degrade coastal water quality unless necessary for important economic or 

social development. 

(3) To the greatest extent practicable, new wastewater outfalls shall be located 

where they will not adversely affect critical areas. 

(c) The TCEQ shall comply with the policies in this section when adopting rules 

and authorizing wastewater discharges under Texas Water Code, Chapter 26. 

(d) The TCEQ shall consult with the Texas Department of Health when reviewing 

permit applications for wastewater discharges that may significantly adversely 

affect oyster reefs. 

Addressed in Section 5.0 of the plan. 

CATEGORY 7 Non Point Source Pollution (Rule §501.22) 

Not applicable. No on-site disposal systems and underground storage tanks 

will be located, designed, operated, inspected, and maintained; therefore, 

non-point source water pollution will not be discharged as part of this 

project. 

CATEGORY 8 Development in Critical Areas (Rule §501.23)

(a) Dredging and construction of structures in, or the discharge of dredged or fill 

material into, critical areas shall comply with the policies in this section. In 

implementing this section, cumulative and secondary adverse effects of these 

activities will be considered. 

(1) The policies in this section shall be applied in a manner consistent with the 

goal of achieving no net loss of critical area functions and values. 

(2) Persons proposing development in critical areas shall demonstrate that no 

practicable alternative with fewer adverse effects is available. 

(3) In evaluating practicable alternatives, the following sequence shall be 

applied: 

(A) Adverse effects on critical areas shall be avoided to the greatest extent 

practicable. 
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(B) Unavoidable adverse effects shall be minimized to the greatest extent 

practicable by limiting the degree or magnitude of the activity and its 

implementation. 

(C) Appropriate and practicable compensatory mitigation shall be required 

to the greatest extent practicable for all adverse effects that cannot be 

avoided or minimized. 

(4) Compensatory mitigation includes restoring adversely affected critical 

areas or replacing adversely affected critical areas by creating new critical 

areas. Compensatory mitigation should be undertaken, when practicable, 

in areas adjacent or contiguous to the affected critical areas (on-site). If 

on-site compensatory mitigation is not practicable, compensatory 

mitigation should be undertaken in close physical proximity to the affected 

critical areas if practicable and in the same watershed if possible (off-site). 

Compensatory mitigation should also attempt to replace affected critical 

areas with critical areas with characteristics identical to or closely 

approximating those of the affected critical areas (in-kind). The preferred 

order of compensatory mitigation is: 

(A) on-site, in-kind; 

(B) off-site, in-kind; 

(C) on-site, out-of-kind; and 

(D) off-site, out-of-kind. 

(5) Mitigation banking is acceptable compensatory mitigation if use of the 

mitigation bank has been approved by the agency authorizing the 

development and mitigation credits are available for withdrawal. 

Preservation through acquisition for public ownership of unique critical 

areas or other ecologically important areas may be acceptable 

compensatory mitigation in exceptional circumstances. Examples of this 

include areas of high priority for preservation or restoration, areas whose 

functions and values are difficult to replicate, or areas not adequately 

protected by regulatory programs. Acquisition will normally be allowed 

only in conjunction with preferred forms of compensatory mitigation. 

(6) In determining compensatory mitigation requirements, the impaired 

functions and values of the affected critical area shall be replaced on a 

one-to-one ratio. Replacement of functions and values on a one-to-one 

ratio may require restoration or replacement of the physical area affected 

on a ratio higher than one-to-one. While no net loss of critical area 

functions and values is the goal, it is not required in individual cases 

where mitigation is not practicable or would result in only inconsequential 

environmental benefits. It is also important to recognize that there are 

circumstances where the adverse effects of the activity are so significant 
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that, even if alternatives are not available, the activity may not be 

permitted regardless of the compensatory mitigation proposed. 

(7) Development in critical areas shall not be authorized if significant 

degradation of critical areas will occur. Significant degradation occurs if: 

(A) the activity will jeopardize the continued existence of species listed as 

endangered or threatened, or will result in likelihood of the destruction or 

adverse modification of a habitat determined to be a critical habitat under 

the Endangered Species Act, 16 United States Code Annotated, §§1531 - 

1544; 

(B) the activity will cause or contribute, after consideration of dilution and 

dispersion, to violation of any applicable surface water quality standards 

established under §501.21 of this title; 

(C) the activity violates any applicable toxic effluent standard or prohibition 

established under §501.21 of this title; 

(D) the activity violates any requirement imposed to protect a marine 

sanctuary designated under the Marine Protection, Research, and 

Sanctuaries Act of 1972, 33 United States Code Annotated, Chapter 27; or 

(E) taking into account the nature and degree of all identifiable adverse 

effects, including their persistence, permanence, areal extent, and the 

degree to which these effects will have been mitigated pursuant to 

subsections (c) and (d) of this section, the activity will, individually or 

collectively, cause or contribute to significant adverse effects on: 

(i) human health and welfare, including effects on water supplies, 

plankton, benthos, fish, shellfish, wildlife, and consumption of fish 

and wildlife; 

(ii) the life stages of aquatic life and other wildlife dependent on 

aquatic ecosystems, including the transfer, concentration, or spread 

of pollutants or their byproducts beyond the site, or their 

introduction into an ecosystem, through biological, physical, or 

chemical processes; 

(iii) ecosystem diversity, productivity, and stability, including loss of 

fish and wildlife habitat or loss of the capacity of a coastal wetland 

to assimilate nutrients, purify water, or reduce wave energy; or 

(iv) generally accepted recreational, aesthetic or economic values of 

the critical area which are of exceptional character and importance. 
Coastal Zone Management Act Consistency for Keathley Canyon Block 93 

BP Exploration & Production, Inc. 

September 2010 

5929E 14 C-K Associates, LLC 

(b) The TCEQ and the RRC shall comply with the policies in this section when 

issuing certifications and adopting rules under Texas Water Code, Chapter 26, 

and the Texas Natural Resources Code, Chapter 91, governing certification of 

compliance with surface water quality standards for federal actions and 

permits authorizing development affecting critical areas; provided that 

activities exempted from the requirement for a permit for the discharge of 

dredged or fill material, described in Code of Federal Regulations, Title 33, 

§323.4 and/or Code of Federal Regulations, Title 40, §232.3, including but not 

limited to normal farming, silviculture, and ranching activities, such as 

plowing, seeding, cultivating, minor drainage, and harvesting for the 

production of food, fiber, and forest products, or upland soil and water 

conservation practices, shall not be considered activities for which a 

certification is required. The GLO and the SLB shall comply with the policies 

in this section when approving oil, gas, or other mineral lease plans of 

operation or granting surface leases, easements, and permits and adopting 

rules under the Texas Natural Resources Code, Chapters 32, 33 and 51 - 53, 

and Texas Water Code, Chapter 61, governing development affecting critical 

areas on state submerged lands and private submerged lands, and when 

issuing approvals and adopting rules under Texas Natural Resources Code, 

Chapter 221, for mitigation banks operated by subdivisions of the state. 

(c) Agencies required to comply with this section will coordinate with one another 

and with federal agencies when evaluating alternatives, determining 

appropriate and practicable mitigation, and assessing significant degradation. 

Those agencies' rules governing authorizations for development in critical 

areas shall require a demonstration that the requirements of subsection (a)(1) - 

(7) of this section have been satisfied. 

(d) For any dredging or construction of structures in, or discharge of dredged or 

fill material into, critical areas that is subject to the requirements of §501.15 of 

this title (relating to Policy for Major Actions), data and information on the 

cumulative and secondary adverse affects of the project need not be produced 

or evaluated to comply with this section if such data and information is 

produced and evaluated in compliance with §501.15(b) - (c) of this title. 

Addressed in Sections 9.0. and 14.0 of the plan. 

CATEGORY 9 Construction of Waterfront Facilities and Other Structures on 

Submerged lands (Rule §501.24) 

(a) Development on submerged lands shall comply with the policies in this 

section. 

(1) Marinas shall be designed and, to the greatest extent practicable, sited so 

that tides and currents will aid in flushing of the site or renew its water 

regularly. 
Coastal Zone Management Act Consistency for Keathley Canyon Block 93 

BP Exploration & Production, Inc. 

September 2010 

5929E 15 C-K Associates, LLC 

(2) Marinas designed for anchorage of private vessels shall provide facilities 

for the collection of waste, refuse, trash, and debris. 

(3) Marinas with the capacity for long-term anchorage of more than ten 

vessels shall provide pump-out facilities for marine toilets, or other such 

measures or facilities that provide an equal or better level of water quality 

protection. 

(4) Marinas, docks, piers, wharves and other structures shall be designed and, 

to the greatest extent practicable, sited to avoid and otherwise minimize 

adverse effects on critical areas from boat traffic to and from those 

structures. 

(5) Construction of docks, piers, wharves, and other structures shall be 

preferred instead of authorizing dredging of channels or basins or filling of 

submerged lands to provide access to coastal waters if such construction is 

practicable, environmentally preferable, and will not interfere with 

commercial navigation. 

(6) Piers, docks, wharves, bulkheads, jetties, groins, fishing cabins, and 

artificial reefs (including artificial reefs for compensatory mitigation) shall 

be limited to the minimum necessary to serve the project purpose and shall 

be constructed in a manner that: 

(A) does not significantly interfere with public navigation; 

(B) does not significantly interfere with the natural coastal processes 

which supply sediments to shore areas or otherwise exacerbate erosion 

of shore areas; and 

(C) avoids and otherwise minimizes shading of critical areas and other 

adverse effects. 

(7) Facilities shall be located at sites or designed and constructed to the 

greatest extent practicable to avoid and otherwise minimize the potential 

for adverse effects from: 

(A) construction and maintenance of other development associated with 

the facility; 

(B) direct release to coastal waters and critical areas of pollutants from oil 

or hazardous substance spills or stormwater runoff; and 

(C) deposition of airborne pollutants in coastal waters and critical areas. 
Coastal Zone Management Act Consistency for Keathley Canyon Block 93 

BP Exploration & Production, Inc. 

September 2010 

5929E 16 C-K Associates, LLC 

(8) Where practicable, pipelines, transmission lines, cables, roads, causeways, 

and bridges shall be located in existing rights-of-way or previously 

disturbed areas if necessary to avoid or minimize adverse effects and if it 

does not result in unreasonable risks to human health, safety, and welfare. 

(9) To the greatest extent practicable, construction of facilities shall occur at 

sites and times selected to have the least adverse effects on recreational 

uses of CNRAs and on spawning or nesting seasons or seasonal 

migrations of terrestrial and aquatic wildlife. 

(10) Facilities shall be located at sites which avoid the impoundment and 

draining of coastal wetlands. If impoundment or draining cannot be 

avoided, adverse effects to the impounded or drained wetlands shall be 

mitigated in accordance with the sequencing requirements of §501.23 of 

this title. To the greatest extent practicable, facilities shall be located at 

sites at which expansion will not result in development in critical areas. 

(11) Where practicable, piers, docks, wharves, bulkheads, jetties, groins, 

fishing cabins, and artificial reefs shall be constructed with materials that 

will not cause any adverse effects on coastal waters or critical areas. 

(12) Developed sites shall be returned as closely as practicable to pre-project 

conditions upon completion or cessation of operations by the removal of 

facilities and restoration of any significantly degraded areas, unless: 

(A) the facilities can be used for public purposes or contribute to the 

maintenance or enhancement of coastal water quality, critical areas, 

beaches, submerged lands, or shore areas; or 

(B) restoration activities would further degrade CNRAs. 

(13) Water-dependent uses and facilities shall receive preference over those 

uses and facilities that are not water-dependent. 

(14) Nonstructural erosion response methods such as beach nourishment, 

sediment bypassing, nearshore sediment berms, and planting of vegetation 

shall be preferred instead of structural erosion response methods. 

(15) Major residential and recreational waterfront facilities shall to the 

greatest extent practicable accommodate public access to coastal waters 

and preserve the public's ability to enjoy the natural aesthetic values of 

coastal submerged lands. 

(16) Activities on submerged land shall avoid and otherwise minimize any 

significant interference with the public's use of and access to such lands. 
Coastal Zone Management Act Consistency for Keathley Canyon Block 93 

BP Exploration & Production, Inc. 

September 2010 

5929E 17 C-K Associates, LLC 

(17) Erosion of Gulf beaches and coastal shore areas caused by construction 

or modification of jetties, breakwaters, groins, or shore stabilization 

projects shall be mitigated to the extent the costs of mitigation are 

reasonably proportionate to the benefits of mitigation. Factors that shall be 

considered in determining whether the costs of mitigation are reasonably 

proportionate to the cost of the construction or modification and benefits 

include, but are not limited to, environmental benefits, recreational 

benefits, flood or storm protection benefits, erosion prevention benefits, 

and economic development benefits. 

(b) To the extent applicable to the public beach, the policies in this section are 

supplemental to any further restrictions or requirements relating to the beach 

access and use rights of the public. 

(c) The GLO and the SLB, in governing development on state submerged lands, 

shall comply with the policies in this section when approving oil, gas, and 

other mineral lease plans of operation and granting surface leases, easements, 

and permits and adopting rules under the Texas Natural Resources Code, 

Chapters 32, 33 and 51 - 53, and Texas Water Code, Chapter 61. 

Addressed in Sections 11.0 and 12.0 of the plan. 

CATEGORY 10 Dredging and Dredged Material Disposal and Placement (Rule 

§501.25) 

Not applicable. No dredging activities will occur as a result of this project. 

CATEGORY 11 Construction in the Beach / Dune System (Rule §501.26) 

Not Applicable. No development will be conducted within the beach/dune 

system. 

CATEGORY 12 Development in Coastal Hazard Areas (Rule §501.27) 

Not Applicable. No development will be conducted within the coastal hazard 

areas. 

CATEGORY 13 Development within Coastal Barrier Resource (Rule §501.28) 

Not Applicable. No development will be conducted within coastal barrier 

resources. 
Coastal Zone Management Act Consistency for Keathley Canyon Block 93 

BP Exploration & Production, Inc. 

September 2010 

5929E 18 C-K Associates, LLC 

CATEGORY 14 Development in State Parks, Wildlife Management Areas or 

Preserves (Rule §501.29) 

Not Applicable. No development will be conducted in State Parks or Wildlife 

Management areas or Preserves. 

CATEGORY 15 Alteration of Coastal Historic Areas (Rule §501.30) 

(a) Development affecting a coastal historic area shall avoid and otherwise 

minimize alteration or disturbance of the site unless the site's excavation will 

promote historical, archaeological, educational, or scientific understanding. 

(b) The Texas Historical Commission (THC) shall comply with the policies in this 

section when adopting rules and issuing permits under the Texas Natural 

Resources Code, Chapter 191, governing alteration of coastal historic areas. 

The THC shall comply with the policies in this section when issuing reviews 

under the National Historic Preservation Act, §106 (16 United States Code 

Annotated, §470f), and the regulations enacted pursuant thereto, Code of 

Federal Regulations, Title 36, Chapter 1, Part 63. 

Addressed in Sections 4.0, 9.0, and 14.0 of the plan. 

CATEGORY 16 Transportation Projects (Rule §501.31) 

Not applicable. No transportation construction projects and maintenance 

programs will be conducted. 

CATEGORY 17 Emission of Air Pollutants (Rule §501.32) 

TCEQ rules under Texas Health and Safety Code, Chapter 382, governing 

emissions of air pollutants, shall comply with regulations at Code of Federal 

Regulations, Title 40, adopted pursuant to the Clean Air Act, 42 United States 

Code Annotated, §§7401, et seq, to protect and enhance air quality in the coastal 

area so as to protect CNRAs and promote the public health, safety, and welfare. 

Addressed in Section 6.0 in the plan. 

CATEGORY 18 Appropriations of Water (Rule §501.33) 

Not applicable. No impoundment or diversion of State water within 200 

miles of the coast will be conducted. 
Coastal Zone Management Act Consistency for Keathley Canyon Block 93 

BP Exploration & Production, Inc. 

September 2010 

5929E 19 C-K Associates, LLC 

CATEGORY 19 Levee and Control Projects (Rule §501.34) 

Not applicable. No levees will be constructed. 

CATEGORY 22 Policies for Major Actions (Rule §501.15) 

(a) For purposes of this section, "major action" means an individual agency or 

subdivision action listed in §505.11 of this title (relating to Actions and Rules 

Subject to the Coastal Management Program), §506.12 of this title (relating to 

Federal Actions Subject to the Coastal Management Program), or §505.60 of 

this title (relating to Local Government Actions Subject to the Coastal 

Management Program), relating to an activity for which a federal 

environmental impact statement under the National Environmental Policy Act, 

42 United States Code Annotated, §4321, et seq is required. 

(b) Prior to taking a major action, the agencies and subdivisions having 

jurisdiction over the activity shall meet and coordinate their major actions 

relating to the activity. The agencies and subdivisions shall, to the greatest 

extent practicable, consider the cumulative and secondary adverse effects, as 

described in the federal environmental impact assessment process, of each 

major action relating to the activity. 

(c) No agency or subdivision shall take a major action that is inconsistent with the 

goals and policies of this chapter. In addition, an agency or subdivision shall 

avoid and otherwise minimize the cumulative adverse effects to coastal 

natural resource areas of each of its major actions relating to the activity. 

Addressed in Section 14.0 of the plan. 

BP has considered all of Texas’ enforceable policies and certifies the consistency for the 

proposed operations. See attached Table 2. 
TABLES 
TABLE 1 

LOUISIANA GUIDELINES 
TABLE 1

LOUISIANA GUIDELINES

Guideline TOPIC CROSS REFERENCE COMMENT

1.2 Air Quality Section 6.01.2 Water Quality Section 5.01.6 Permitting Authority Sections 4.0 thru 14.01.7 Adverse Effects Section 14.01.9 Multiple Use Section 1.0 and 2.0

3.1 - 3.16 Linear Facilities NA The proposed project is not a line

4.1 - 4.7 Dredged Spoil Deposition NA No dredged spoil will be deposite

proposed project.

6.1 Surface Alterations NA No surface alterations are propo

7.1, 7.3, and 

7.9

Hydrologic and Sediment Transport Modifications NA No hydrologic or sediment transp

proposed for this project.

8.1 Waste Storage, Treatment and Disposal Facilities Sections 5.0 and 12.0

8.2 Hazardous Waste Storage, Treatment and Disposal Sections 5.0 and 12.08.8 Approved Disposal Sites Sections 5.0 and 12.08.9 Radioactive Waste Sections 5.0 and 12.09.2 Alteration of Waters Draining into Coastal Waters NA The proposed project will not affe

draining into coastal waters.

10.3 Siting of Exploration, Production Activities Sections 2.0 and 14.010.5 Access to Site Sections 2.0 and 12.010.6 Best Practical Techniques for Drilling/Production Sites Sections 2.0 and 5.0

10.9 Drilling and Production Equipment Guidelines for Preventing Adverse Environmental Effects Section 1.0

10.10 Design of Facilities to Minimize Adverse Environmental Impacts10.11 Effective Environmental Protection and Emergency or Contingency Plans Sections 1.0, 7.0 and 14.0
TABLE 2 

TEXAS GUIDELINES 
TABLE 2

TEXAS GUIDELINES

Category No. TOPIC CROSS REFERENCE COMMEN

2 Construction, Operation and Maintenance of Oil and Gas Exploration and Production Activities Section 14.0 No wetlands will be impounded or drained 

completion, all facilities will be removed anwill be restored to pre-project conditions.

3

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

Section 5.0

4 Construction and Operation of Solid Waste Treatment, Storage, and Disposal Facilities NA

5 Prevention, Response, and Remediation of Oil Spills Section 7.06 Discharge of Municipal and Industrial Waste Water to Coastal Waters Section 5.07 Non Point Source Pollution NA No Non-point Source Water Pollution will b

project.

8 Development in Critical Areas Sections 9.0, and 14.0

9 Construction of Waterfront Facilities and Other Structures on Submerged lands Sections 11.0 and 12.0

10 Dredging and Dredged Material Disposal and Placement NA

11 Construction in the Beach / Dune System NA No development will be conducted within t12 Development in Coastal Hazard Areas NA No development will be conducted within C13 Development within Coastal Barrier Resource NA No development will be conducted within C14 Development in State Parks, Wildlife Management Areas or Preserves NA No development will be conducted in State 

Areas or Preserves

15 Alteration of Coastal Historic Areas Sections 4.0, 9.0, and 14.0

16 Transportation Projects NA17 Emission of Air Pollutants Section 6.018 Appropriations of Water NA No impoundment or diversion of state wat

coast will be conducted for this project.

19 Levee and Control Projects NA No levees will be constructed for this proje22 Policies for Major Actions Sections 14.0 Section 14.0 contains an Environmental Im
APPENDICES 
APPENDIX A 

COASTAL ZONE MANAGEMENT 

CONSISTENCY CERTIFICATION


________________________________________________________________________

Title of Document: 2700-T2-RG-PN-0001 Initial Exploration 

Plan KC 93 Document Number: 2700-T2-RG-PN-0001 

Authority: James Grant Revision 0 

Custodian/Owner: Mandy Phythian Issue Date: 15-Dec-2011 

Retention Code: ADM3000 Next Review Date 

 (if applicable): N/A 

Security 

Classification: Public Information Page: Page 37 of 37 

Warning:. Check DW Docs revision to ensure you are using the correct revision. 

Appendix I : Fee Recovery 
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Application Name: BOEM Exploration Plan - BF

Pay.gov Tracking ID: 254M0M78

Agency Tracking ID: 74245495017

Transaction Date and Time: 10/13/2011 13:47 EDT

Address Information

Account Holder 

Name: Betsy Cleland 

Billing Address:

200 Westlake 

Park Blvd 

Billing Address 

2:

City: Houston 

State / Province: TX 

Zip / Postal 

Code: 77072 

Country: USA 

Account Information

Card Type: American Express 

Card

Number: ************1008 

Region: Gulf of Mexico 

Contact:

Betsy Cleland 281-

366-7539 

Company 

Name/No:

BP Exploration 

Production Inc., 

02481 

Lease 

Number(s): 25780, , , , 

Area-Block:

Keathley Canyon 

KC, 93: , : , : , : , 

Surface 

Locations: 2 

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Transaction Date 

and Time:

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13:47 EDT

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