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

### 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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 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 Cont ents .............................................................................................. 7 1.1 Description of Activities...........................................................................7 1.2 Location ...................................................................................................7 1.3 Safety and Pollution Pr evention Fe atures ................................................7 1.4 Storage Tanks and Production Ve ssels....................................................7 1.4.1 Storage Tanks We st Sirius...............................................................7 1.4.2 Storage Tanks Support Vesse ls .......................................................8 1.5 Additional Measures ................................................................................8 2 General Info rmation.................................................................................... 9 2.1 Applications and Permits .........................................................................9 2.2 Drilling Fl uids ...........................................................................................9 2.3 New or Unusual Technologies .................................................................9 2.4 Bonding Inform ation ................................................................................9 2.5 Oil Spill Financial Re sponsibility (OSFR)...................................................9 2.6 Deepwater Well Con trol Stat ement.......................................................10 2.7 Blowout Sc enario...................................................................................10 2.7.1 Blowout Sc enario...........................................................................10 2.7.2 The Potential for the We ll to Bri dge 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 Re lief Well ...............10 2.7.5 Measures that would Enhance the Ab ility to Prevent a Blowout...11 2.7.6 Measures that would Reduce th e Likelihood of a Blowout ...........12 2.7.7 Measures that would Enhance the Ability to Conduct Early Intervent ion....................................................................................12 2.7.8 Other Meas ures.............................................................................12 3 Geological and Geophysic al Informa tion................................................ 12 3.1 Geological De scripti on ...........................................................................12 3.2 Structure Cont our Maps ........................................................................13 3.3 Interpreted 2-D and/or 3D Seismic Lines...............................................13 3.4 Geological Structure Cross-Secti on Maps..............................................13 3.5 Shallow Hazard s Repor t.........................................................................13 3.6 Shallow Hazards Assessment (S ite Clearance Letter) ...........................13 3.7 High Resolution Sei smic Li nes ..............................................................13 3.8 Stratigraphi c Colu mn..............................................................................13 3.9 Time vs. Dept h Tabl e.............................................................................13 4 Hydrogen Sulfide (H 2 

### S) Informa tion........................................................ 14 4.1 Concentra tion ........................................................................................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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

### 4.2 Classificat ion..........................................................................................14 4.3 H 2 

### S Contingen cy Plan ............................................................................14 4.4 Modeling R eport ....................................................................................14 5 Biological and Physical Information ........................................................ 14 5.1 Benthic Communiti es Report.................................................................14 5.2 Topographic Featu res Map ....................................................................14 5.3 Topographic Features Stat ement (shunt ing) ..........................................15 5.4 Live Bottoms (Pinn acle Trend) Map.......................................................15 5.5 Live bottoms (Low Relief) Map..............................................................15 5.6 Potentially Sensitive Biol ogical Fe atures................................................15 5.7 Remotely Operated Vehicle (R OV) 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 Informati on........................................................... 18 6.1 Waste Generated, Treated, Downhole Disposed or Discharged into the GoM.......................................................................................................18 6.2 Wastes Transported and/or Disposed On shore .....................................19 7 Air Emissions In formation........................................................................ 20 7.1 Screening Q uestions ..............................................................................20 7.2 Emissions Wo rksheet ............................................................................20 7.3 Emission Reductions Measures ............................................................20 7.4 Verification of Non-Defa ult Emission Factors.........................................20 8 Oil Spill In formation.................................................................................. 21 8.1 Oil Spill Respons e Planni ng ...................................................................21 8.1.1 Regional Oil Spill Response Plan (OSRP) Information....................21 8.1.2 Spill Response Sites ......................................................................21 8.1.3 OSRO Inform ation .........................................................................22 8.1.4 Worst-case Scenario Determinat ion ..............................................22 8.2 Oil Spill Respons e Discussi on................................................................23 9 Environmental Monitoring and Mitigation M easures ........................... 23 9.1 Monitoring S ystems...............................................................................23 9.2 Incidental Takes .....................................................................................23 9.3 Flower Garden Banks Nati onal Marine Sa nctuary..................................23 10 Lease Stipulation Informati on ................................................................. 23 11 Related Facilities and Oper ations Info rmation....................................... 24 11.1 Produced Liquid Hydrocarbons Transportati on Vesse ls.........................24 12 Support Vessels and Airc raft Info rmation .............................................. 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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

### 12.2 Diesel Oil Suppl y Vesse ls ......................................................................24 12.3 Vicinity Map ...........................................................................................24 13 Onshore Support Facilitie s Information.................................................. 25 13.1 General ..................................................................................................25 13.2 Support Base Constructi on or Expa nsion...............................................25 14 Coastal Zone Management Act (CZMA) Information ............................ 25 15 Environmental Impact Analysis (EIA)...................................................... 25 16 Administrative In formation...................................................................... 26 16.1 Exempted Informati on Descrip tion ........................................................26 16.2 Bibliograp hy ...........................................................................................26 Appendix A: Plan Information Forms – Form BO EM-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, Sea floor Amplitude Maps ................. 32 Appendix D: Air Quality Report .................................................................... 33 Appendix E: WCD Assumptions for KC93 and WR282 (Exploration Well Scenario in Revi sed OSRP )...................................................... 34 Appendix F: Environmental Impact Analysis (EIA)..................................... 35 Appendix G: Oil Spill Respons e Discussion................................................. 36 Appendix H: Coastal Zone Management Act (CZMA) Consistency Certificat ion .............................................................................. 37 Appendix I: Fee Recove ry ............................................................................ 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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

## 1 Plan Contents

1.1 Description of Activities

Under this Exploration Plan, BP Exploration & Produc tion Inc. (BP) proposes to drill and temporarily abandon two (2) exploratory wells in Keathley Cany on 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-0 137) 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 fe atures utilized during drilling oper ations 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 Notice s 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 mainta ined as mandated by the U.S. Coast Guard regulations contained in 33 CFR § 144.



## 1.4 Storage Tanks and Pr oduction 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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 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, polluti on 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 activi ties that drive how BP will actually perform work and comply with internal and external standard s 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 Re sponse: 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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

## 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 th is 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 demonstr ated oil spill financial responsib ility for the fac ilities proposed in this Exploration Plan according to 30 CFR § 553, and NTL No. 2008-N05, “G uidelines for Oil Spill Financial Responsibility (OSFR) fo r 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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

## 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 a ttached 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 experienc ed on each well have multiple formations open simultaneously. The modelin g 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 BO P 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 re quirements to safely secure the current operations of the MODU, required material l ogistics, mobilization to location, and regulatory ap provals. 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 respec t to the availability of drilli ng 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
Warning:. Check DW Docs revision to ensure you are using the correct revision.

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, inters ection, 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 co mpliance 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 condition s prior to each trip and a fter well kills or testing; 4. BP representative shall be the only person author ized to initiate opening the well as part or conclusion of well control measures; 5. On rig JSA/contingency plan befor e 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 it s contractors involved in drilling operations to use, subsea blowout preventers (BOPs) equip ped with no fewer than two blind shear rams and a casing shear ram on all drilling rigs under contract to BPXP for deepwater serv ice operating in dynamic position mode. With respect to moored drilli ng rigs under contract to BPXP for deepwater drilling service using su bsea BOPs, the subsea BOP will be equipped with two shear rams, which will include at least one blind shear ram and ei ther an additional blind shear ram or a casing shear ram. 2. Each time a subsea BOP from a moored or dynami cally positioned drilling ri g is brought to the surface and testing and maintena nce 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 testin g of cement slurries for pr imary cementing of casing and exposed hydrocarbon bearing zo nes relating to drilling operati ons of deepwater wells be conducted or witnessed by a BPXP engineer com petent 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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

### 2.7.6 Measures that would Reduce the Likelihood of a Blowout

Measures to reduce the likelihood of a blowout incl ude 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 pr essure / 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 proces s 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 sc reened for general acc eptability. In the event of a blow out or other event necessitating a relief well, data will be collected post -event to ensure that previously-ide ntified relief well locations are still va lid, 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 Managem ent System; access to response capability through various contractors and technical specia lists; 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 B SEE 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 t he 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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

## 3.2 Structure Contour Maps

Current structure contour maps are in cluded 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 clearanc e 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 Geohazar ds Assessment Gila Prospect, Blocks 48-51, 92-95, and 136-139 Keathley Canyon Area, Gulf of Mexico” wa s 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 20 08-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-p rocessed exploration 3D seismic data volume which meets the data quality and frequency requirement s of the current Shallow Hazards NTL 2008-G05.



## 3.8 Stratigraphic Column

A generalized biostratigraphic / litho stratigraphic 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 propos ed 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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 292 #1 (32,499 feet MD). These data address the time vs. depth requi rements of 30 CFR 250.214(i) and NTL No. 2008-G04.



## 4 Hydrogen Sulfide (H 2 

## S) Information

4.1 Concentration

Based on previous wells drilled in this area, the concentration would be 0 PPM H 2 S. It is not expected that H 2 S will be encountered during the operations proposed in this Exploration Plan.



## 4.2 Classification

Based on previous drilling, no H 2 S 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 H 2 S: 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 H 2 S are: Unocal GB 941 #1 (21,207 feet MD), Unocal KC 681 #1 (27,575 feet MD), Co noco KC 511 #1 (30,082 feet MD), BP AC 739 #1 (23,847 feet MD), and Shell AC 557 #1 ST02 (19,618 f eet MD). BP requests that BOEM confirm the “H 2 S absent” classification.



## 4.3 H 2 

## S Contingency Plan

Based on previous drilling, no H 2 S is known to occur in the project area. Based previous BOEM “H 2 S absent” classification, it is not anticipate d that a contingency plan will be required.



## 4.4 Modeling Report

Based on previous drilling, no H 2 S 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 locat ion. The proposed wells will be drilled utilizing a dynamically positioned semi-submersible rig; therefore, physical disturbance of t he seafloor will not occur due to anchor emplacements.



## 5.2 Topographic Features Map

The intent of NTL No. 2009-G39 is to protect biologica lly 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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 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 biologica lly 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 with in a 2,000-foot radius of the prop osed well locations. All proposed bottom-disturbing activities will ther efore 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 biologica lly 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 Blo ck 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 2,00 0-foot radius of the proposed well locations. All proposed bottomdisturbing activities will therefore occur outside 61 mete rs (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 biologica lly sensitive features and areas, in this case, naturally occurring hard or rocky formations with rou gh, broken or smooth topo graphy, 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-dist urbing 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-dist urbing 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 Classification: BP Confidential Page: Page 16 of 38
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

## 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 immediat ely prior to commencement of a nd 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, cent ered 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 continuous ly along the track.

If the ROV survey is required, BP will make biol ogical 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 oper ations, but prior to moving the rig o ff 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 an d 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 Enda ngered 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 tu rtle, 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 Classification: BP Confidential Page: Page 17 of 38
Warning:. Check DW Docs revision to ensure you are using the correct revision. 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 cr itical habitat for any of these species.

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



## 5.9 Archaeological Report

Keathley Canyon Block 93 is not located within the ar ea 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 Su rvey Mitigation”, which require archaeological assessments prior to undertaking any bottom-disturbing activities, such as spudding a well. An archaeological survey “Gila Archaeological and Haza rd 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 co pies 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
Security Classification: BP Confidential Page: Page 18 of 38
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

## 6 Waste and Discharge Information

6.1 Waste Generated, Treated, Down hole Disposed or Discharged into the GoM

Projected generated waste Pro jected 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 C u tti ngs genera t e d w

hil

e us i ng 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
Security Classification: BP Confidential Page: Page 19 of 38
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

## 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 Classification: BP Confidential Page: Page 20 of 38
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

## 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 = 3400D 2/3 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 87.5 o W longitude? X
Do you expect to encounter H 2 S at concentrations greater than 20 parts per million (ppm)? X

Do you propose to flare or vent 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, 200 9 to March 31, 2010 is included in Appendix D.



## 7.4 Verification of Non-De fault Emission Factors

The default emission factors provided in For m 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 Classification: BP Confidential Page: Page 21 of 38
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

## 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 B SEE 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 standa rds as outlined in a letter to Director Bromwich, dated July 15, 2011:
4. BPXP’s Oil Spill Respon se Plan (OSRP) will include inform ation about enhanc ed 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 Lessee s, BPXP’s OSRP will include:

 Provisions to maintain access to a supply of disp ersant and fireproof boom for use in the event of an uncontrolled long-term blowout for the leng th of time required to drill a relief well.

 Contingencies for maintain ing 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 re cover the discharge on the water’s surface. The discussion must include methods to increase encoun ter 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 thicknes s detection systems (suc h 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 consiste nt with applicable area contingency plans (ACP).

 For operations using a s ubsea BOP or a surface BOP on a floa ting facility, a discussion regarding strategies and plans re lated to source abatem ent and control for bl owouts 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
Security Classification: BP Confidential Page: Page 22 of 38
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

### 8.1.3 OSRO Information

BP is a member of the Marine Spill Response Corporation (M SRC), Clean Gulf Associates (CGA) and the National Response Corporation and would utiliz e 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) 250,00 0-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 resp ond to the worst-case spill scenario included in its regional Oil Spill Response Plan approved on July 21, 2009, and resubm itted, in revised form in October 2010, and further revised and submitted on October 20, 2011, and si nce 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 maxi mum 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 Classification: BP Confidential Page: Page 23 of 38
Warning:. Check DW Docs revision to ensure you are using the correct revision. 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 sh ut-off the source and make immediate notifications as per instructions provided in Section 2 a nd 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 Facilit ies” 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 re quired by NTL 2007-G03, BP submits an annual certification letter for its Marine Debris Awarenes s Training Process. The marine debris awareness training is required annually by the BSEE and is i dentified on BP’s Gulf of Mexico (GoM) Environmental Training Matrix and BP’s GoM Health, Safety, a nd 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 in jured/dead protected species. Reporting of dead/injured protected species is addressed in BP’s Incident Notifi cation and Investigation Procedure - Attachment 1.



## 9.3 Flower Garden Banks National Marine Sanctuary

All proposed activities will occur out side of the Protective Zones of t he Flower Garden Banks and Stetson Bank.



## 10 Lease Stipulation Information

Lease Stipulation for Protected Species (Sea Turtl es, 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 Classification: BP Confidential Page: Page 24 of 38
Warning:. Check DW Docs revision to ensure you are using the correct revision. All activities will be conducted in adherence to NTL 2007-G03 “Marine Trash and Debris Awareness Training and Elimination” and NTL 2007-G04 “Vesse l 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 im pact on protected species, and trai ning on reporting of dead/injured protected species addressed in BP’s Incident Noti fication and Investigation Procedure—Attachment 1.



## 11 Related Facilities and Operations Information

11.1 Produced Liquid Hydrocarbo ns Transportation Vessels

There are no well tests proposed in this Exploration Plan.



## 12 Support Vessels and Ai rcraft 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 pr oposed 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 onshor e 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 vehicl e parking lot, office space, radio communication equipment, outside and warehouse storage sp ace, crane, forklift s, 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 or iginate from bases other those described above in order to address changes in weather, market, and operati onal conditions. It is expected that this vessel traffic will originate from bases and lo cations 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 consisten cy 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 enviro nmental 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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

## 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 Informat ion” 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 platfo rm 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 activ ities 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/Ar ea/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
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 renami ng 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 X: 1,425,478.00 X: 1,425,478.00 Lambert X-Y 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 Pl an or Development Operations Coordination Document submitted for BOEM approval. We use the information to facilitate our review and data entry fo r 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 per son is not required to respond to, a collection of infor mation unless it displays a currently valid Office of Management and Budget Control Number. The use of this form is voluntary. The public report ing burden for this form is included in the burden for preparing Exploration Plans and Devel opment Operations Coordination Documents. We estimate that b urden 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 D PP or DOCD, including the time for reviewing instructions, gathering and main taining data, and completing and reviewing the form. Direct co mments regarding the burden estimate or any other aspect of this form to the Inform ation Collection Clearance Officer, Bureau of Ocean Energy Manage ment, 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 renami ng 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 X: 1,416,827.00 X: 1,416,827.00 Lambert X-Y 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 Barg e (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 Pl an or Development Operations Coordination Document submitted for BOEM approval. We use the information to facilitate our review and data entry fo r 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 per son is not required to respond to, a collection of infor mation unless it displays a currently valid Office of Management and Budget Control Number. The use of this form is voluntary. The public report ing burden for this form is included in the burden for preparing Exploration Plans and Devel opment Operations Coordination Documents. We estimate that b urden 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 D PP or DOCD, including the time for reviewing instructions, gathering and main taining data, and completing and reviewing the form. Direct co mments regarding the burden estimate or any other aspect of this form to the Inform ation Collection Clearance Officer, Bureau of Ocean Energy Manage ment, 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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

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

## Appendix C: Geological De scription, 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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

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

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

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

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

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

## Appendix I : Fee RecoveryOG-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
Warning:. Check DW Docs revision to ensure you are using the correct revision. 

## Appendix C: Shallow Hazard s 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 ReportEXPLORATION PLAN (EP)AIR QUALITY SCREENING CHECKLISTOMB Control No. 1010-0151OMB Approval Expires: 12/31/2011COMPANYBP Exploration & Production IncAREAKeathley CanyonBLOCK93LEASEOCS-G26780PLATFORMMODU - West SiriusWELLKC93-A and KC93-BCOMPANY CONTACTJim Pfeiffer (Air Quality); Mandy Phythian (Plans)TELEPHONE NO.281-366-1542 (Jim); 281-504-4352 (Mandy)REMARKSDrill and temporarily abandon two exploratory wells. Complex totalemissions are the same as plan emissions.MMSFORM MMS-138(December 2008 - Supersedes all previous versions of form MMS-138 which may not be used).Page 1 of 5EMISSIONS FACTORSFuel Usage Conversion FactorsNatural Gas Turbines Natural Gas Engines Diesel Recip. Engine REF. DATESCF/hp-hr 9.524 SCF/hp-hr 7.143 GAL/hp-hr 0.0483AP42 3.2-1 4/76 & 8/84Equipment/Emission Factorsunits PM SOx NOx VOC CO REF. DATENG Turbines gms/hp-hr 0.00247 1.3 0.01 0.83AP42 3.2-1& 3.1-1 10/96NG 2-cycle lean gms/hp-hr 0.00185 10.9 0.43 1.5AP42 3.2-1 10/96NG 4-cycle lean gms/hp-hr 0.00185 11.8 0.72 1.6AP42 3.2-1 10/96NG 4-cycle rich gms/hp-hr 0.00185 10 0.14 8.6AP42 3.2-1 10/96Diesel Recip. < 600 hp. gms/hp-hr 1 1.468 14 1.12 3.03AP42 3.3-1 10/96Diesel Recip. > 600 hp. gms/hp-hr 0.32 1.468 11 0.33 2.4AP42 3.4-1 10/96Diesel Boiler lbs/bbl 0.084 2.42 0.84 0.008 0.21AP42 1.3-12,14 9/98NG Heaters/Boilers/Burners lbs/mmscf 7.6 0.593 100 5.5 84P42 1.4-1, 14-2, & 147/98NG Flares lbs/mmscf 0.593 71.4 60.3 388.5AP42 11.5-1 9/91Liquid Flaring lbs/bbl 0.42 6.83 2 0.01 0.21AP42 1.3-1 & 1.3-3 9/98Tank Vapors lbs/bbl 0.03E&P Forum 1/93Fugitives lbs/hr/comp. 0.0005API Study 12/93Glycol Dehydrator Vent lbs/mmscf 6.6La. DEQ 1991Gas Venting lbs/scf 0.0034Sulphur Content Source Value UnitsFuel Gas 3.33 ppmDiesel Fuel 0.4 % weightProduced Gas( Flares) 3.33 ppmProduced Oil (Liquid Flaring) 1 % weightMMSFORM MMS-138(December 2008 - Supersedes all previous versions of form MMS-138 which may not be used).Page 2 of 5EMISSIONS CALCULATIONS 1ST YEARCOMPANY AREA BLOCK LEASE PLATFORM WELL CONTACT PHONE REMARKSBP Exploration & Production Inc Keathley Canyon 93 OCS-G26780ODU - West Siri KC93-A and KC93-B Jim Pfeiffer (Air Quality); Mandy281-366-1542 (JOPERATIONS EQUIPMENT RATING MAX. FUEL ACT. FUEL RUN TIME MAXIMUM POUNDS PER HOUR ESTIMATED TONSDiesel Engines HP GAL/HR GAL/DNat. Gas Engines HP SCF/HR SCF/DBurners MMBTU/HR SCF/HR SCF/D HR/D DAYS PM SOx NOx VOC CO PM SOx NOx VOC CODRILLINGMains- 8 x Cat 3616 PRIME MOVER>600hp diesel 50560 2442.05 58609.15 24 305 35.64 163.48 1225.02 36.75 267.28 130.43 598.35 4483.58 134.51 978.24E-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 1.73 12.93 0.39 2.82Small 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 7.40 70.54 5.64 15.27Fast 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 5.34 50.89 4.07 11.01Offshore 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 17.20 164.06 13.12 35.51Offshore 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 17.20 128.90 3.87 28.12Offshore 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 17.20 128.90 3.87 28.122012 YEAR TOTAL84.24 270.35 2137.47 90.18 465.44 158.70 664.42 5039.80 165.47 1099.09EXEMPTION CALCULATIONDISTANCE FROM LAND INMILES5727.60 5727.60 5727.60 5727.60 105155.31172.0MMSFORM MMS-138(December 2008 - Supersedes all previous versions of form MMS-138 which may not be used).Page 3 of 5EMISSIONS CALCULATIONS 2ND YEARCOMPANY AREA BLOCK LEASE PLATFORM WELL CONTACT PHONE REMARKSBP Exploration & Production Inc Keathley Canyon 93 OCS-G26780ODU - West Siri KC93-A and KC93-B Jim Pfeiffer (Air Quality); Mandy281-366-1542 (JOPERATIONS EQUIPMENT RATING MAX. FUEL ACT. FUEL RUN TIME MAXIMUM POUNDS PER HOUR ESTIMATED TONSDiesel Engines HP GAL/HR GAL/DNat. Gas Engines HP SCF/HR SCF/DBurners MMBTU/HR SCF/HR SCF/D HR/D DAYS PM SOx NOx VOC CO PM SOx NOx VOC CODRILLINGMains- 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 29.51 135.37 1014.32 30.43 221.31E-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 0.39 2.93 0.09 0.64Small 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 1.67 15.96 1.28 3.45Fast 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 1.21 11.51 0.92 2.49Offshore 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 3.89 37.11 2.97 8.03Offshore 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 3.89 29.16 0.87 6.36Offshore 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 3.89 29.16 0.87 6.362013 YEAR TOTAL84.24 270.35 2137.47 90.18 465.44 35.90 150.31 1140.15 37.43 248.65EXEMPTION CALCULATIONDISTANCE FROM LAND INMILES5727.60 5727.60 5727.60 5727.60 105155.31172.0MMSFORM MMS-138(December 2008 - Supersedes all previous versions of form MMS-138 which may not be used).Page 4 of 5SUMMARYCOMPANY AREA BLOCK LEASE PLATFORM WELLBP Exploration&Keathley Canyon 93 OCS-G26780 MODU - West Sirius KC93-A and KC93-BEmitted SubstanceYearPM SOx NOx VOC CO2012 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 0.00Allowable5727.60 5727.60 5727.60 5727.60 105155.31MMSFORM 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 2,730MC85 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 Cons u Boat 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/h r Crew Vessel 4.355 gals/min 261.319 gals/h r ROV Vessel 1.621 gals/min 97.250 gals/h r



### 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 Sc enario 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
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## 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 5929EEnvironmental Impact Analysis, Keathley Canyon Bloc k 93 BP Exploration & Production, Inc.

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### 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 Are as ...........................................38
3.3.5 Other Environmental Resources Identified .. ..................................................3 9
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 ...........................

................................................... ...................48Environmental Impact Analysis, Keathley Canyon Bloc k 93 BP Exploration & Production, Inc.

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### ii of ii C-K Associates, LLC 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 pe rcent 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 RefugeEnvironmental Impact Analysis, Keathley Canyon Bolo ck 93 BP Exploration & Production, Inc.

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### i of ii C-K Associates, LLC List of Acronyms

bbl barrel BOEMRE Bureau of Ocean Energy Management, Regulatio n 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 & Rest oration 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 Sanctuar y FMP Fishery Management Plan FONSI Finding of No Significant Impact FPSO floating production, storage and offloading s ystems 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 CorporationEnvironmental Impact Analysis, Keathley Canyon Bolo ck 93 BP Exploration & Production, Inc.

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### ii of ii C-K Associates, LLC 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 Administratio n NOx nitrogen oxides NPDES National Pollutant Discharge Elimination Syst em 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 AreaEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 1 of 67 C-K Associates, LLC 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 Ke athley 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 a bandon each well. Regulatory Background

Under the Federal Outer Continental Shelf Lands Act (OCSLA) the Bureau of Ocean Energy Management, Regulation and Enforcement (BOEM RE; formerly Minerals Management Service [MMS] prior to June 2010) is cha rged with the responsibility for managing and regulating exploration and development on the Outer Continental Shelf (OCS). The BOEMRE Notice to Lessees and Operators (NTLs) p rovide clarification, description, or interpretation of a regulation; special lease st ipulation or regional requirement strategies; or administrative information. Several of the NTLs are applicable and contain stipulations which direct lease development to avoi d or mitigate impacts.

NTL No. 2005-G07 Archaeological Resource Surveys and Reports Provides regulatory guidance for archaeological dis coveries and clarifies when to report discoveries, responsibility for conducting d iscovery investigations and assessments, penalties for non-compliance and chang es 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 pr ograms to minimize risk of vessel strikes to protected species and to report o bservations 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 O CS plans including guidance on information requirements for compliance with the Endangered Species Act (ESA), Marine Mammal Protection Act (MMPA), and pla cing high resolution survey lines with 3-D survey data.Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 2 of 67 C-K Associates, LLC

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 blo cks that require archaeological surveys.

NTL No. 2009–G39 Biologically-Sensitive Underwater Features and Area s 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 m inor 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) w ith a separation distance of 610 m (2,000 ft) from drilling muds and cutting loc ations.

NTL No. 2010–N06 Information Requirements for Exploration Plans, Dev elopment and Production Plans, and Development Operations Coordination Docu ments 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) sce narios. Under the National Environmental Policy Act (NEPA), the BOEMRE has prepared multi-lease-sale Environmental Impact Statements (E IS) in the Central Planning Area (CPA) and Western Planning Area (WPA) Gulf of Mexic o (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 (US DOI MMS 2008b). The GOM has also been divided into 17 areas or Grids of bio logical similarity ( http://www.gomr.boemre.gov/homepg/regulate/environ/ ea_grid/ea_grid.asp ). A Programmatic Environmental Assessment (PEA) for specif ic activities within Grid 4 in the OCS region was prepared which includes Keathley Can yon Block 93 (USDOI MMS 2001). The PEA updates some of the material covere d in the EIS. The EIS and PEA contain a description of the affected resources; po tential impacts on the physical, biological, socioeconomic, and human resources; and the cumulative effects of a proposed action. BOEMRE recently published an Environmental Assessme nt (EA), Finding of No Significant Impact (FONSI) for Increased Safety Mea sures for Energy Development on the Outer Continental Shelf for 30 CFR Part 250 (US DOI BOEMRE 2010a), Modifications to Suspensions of Deepwater Drilling Operations (USDOI BOEMRE 2010b), a Site Specific EA in deepwater (USDOI BOEM RE 2011a) and a draft Supplemental EIS, Lease Sale 2011, WPA 218 (USDOI B OEMRE 2011b). The Site Specific EA and draft supplemental EIS each contain a catastrophic spill event analysisEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 3 of 67 C-K Associates, LLC (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 onsh ore resources. In preparing the EIA several Impact Producing Factors (IPFs) are conside red 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 e mplacement; (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 facili ties; (8) onshore waste disposal; (9) marine trash and debris; and, (10) accidental events including oil spills, chemical sp ills, blowouts, vessel collisions, hydrogen sulfide releases, or large-vol ume flaring or venting events (for such accidents, describe in terms of vo lume, duration, etc.). Several of the IPFs may be considered to be routine for exploration activities such as waste and discharges from vessel operations and dri lling activities; air emissions from equipment and vessels; noise from vessel and helico pter 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 MM S 2002, 2007a), the supplemental EIS for the CPA and WPA sales (USDOI M MS 2008b), the PEA for Grid 4 (USDOI MMS 2001), and the draft supplemental EIS (U SDOI BOEMRE 2011b). Several IPFs can occur from an accidental event suc h as a vessel collision with marine mammals and sea turtles; oil spills and blowouts; a nd, vessel and helicopter collisions with coastal and marine birds (USDOI MMS 2002, 2003 , 2007a, 2008b, USDOI BOEMRE 2010a, 2011a and 2011b). The IPFs are addre ssed in detail in the impact analysis for each of the affected resources in Sect ion 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 potential ly 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 th e analysis of a high-volume, long duration oil spill (USDOI BOEMRE 2011a, Append ix B). In this EA, a catastrophic event is defined as “large-scale damage involving d estruction of species, ecosystems, infrastructure, or property with long-term effects, and/or major loss of human lifeEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 4 of 67 C-K Associates, LLC (Eccleston 2008).” Several factors were used durin g the analysis of a catastrophic event such as time of year, location of a release relativ e 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 a nd 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 20 11a). Furthermore, a WCD for an offshore facility is the largest foreseeable discha rge in adverse weather conditions (Section 311(a) (24) of the Clean Water Act). A Sp ill of National Significance (SONS) is defined as a spill that because of the severity, si ze, location, actual or potential impact on the public health and welfare or the environment, o r 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 ri sk of spill > 1,000 barrels (bbl) as reported by BOEMRE) (USDOI BOEMRE 2011a). Risk is further r educed by the recent response and containment improvements, BOEMRE’s enhanced ove rsight, 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 BOEM RE 2011a). Additionally, the regulations (30 CFR 254) require the submittal of a n 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 e xtent practicable, to a worst case discharge or a substantial threat of such a dischar ge. New safety measures (USDOI BOERME 2011b) reduce the risk of large volume, long duration oil spills and smaller oil spills occurrin g. The development of new well containment technology, well containment protocols and oil spill response technology, methodologies, and protocols reduce the severity an d duration of catastrophic oil spills (USDOI BOEMRE 2010a). Oil Spill Risk Analysis: The BOEMRE conducted an OSRA that produced oil spil l trajectory simulations used to estimate the risk from a spill (Ji et al. 2004). A ccording 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 r eleased, and winds and ocean currents that transport spills. While the occurrence of a s pill cannot be predicted, an estimate can be calculated of the likelihood of an event contact ing environmental resources. The trajectories simulated represent only hypotheti cal pathways of oil slicks and does not involve any consideration of spill response activit ies (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 simu lates a spill’s movement on the surface of water by using modeled ocean current and wind fi elds. The OSRA model tabulates theEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 5 of 67 C-K Associates, LLC number of times that each trajectory moves across o r touches (contacts) a location representative of various environmental features or shoreline segments. The OSRA model compiles the number of contacts to each featu re that result from the modeled trajectory simulations from all of the launch point s for a specific launch area. Each trajectory was allowed to continue for as long as 3 0 days and contacts within 3, 10 and 30 days were compiled. If the hypothetical spill cont acted 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; LaBell e and Anderson 1985). The location of a launch area(s) where a lease or facility is locat ed 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 perc ent chance) that an oil spill starting at Launch Area W025 (includes Keathley Can yon 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 o r 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 contacte d, 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 -/-/1Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 6 of 67 C-K Associates, LLC 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 pre vious 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 9 0 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 oceanogra phic 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 likelihoo d of such an event but may assist in identifying potential impacts if the event occur s. 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 cur rents. Offshore resources in the vicinity of the drilling rig or platform could be i mpacted. 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 bet ween the oil and complex ocean and wind currents (USDOI BOEMRE 2011b, Appendix C).Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 7 of 67 C-K Associates, LLC TABLE 2 ENVIRONMENTAL IMPACT ANALYSIS WORKSHEET

The IPF ’ s that have the potential to cause impacts to the l isted 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, H 2 S 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 o n page 2 of this form.

Copied from BOEMRE FORM MMS-142 Page 1 of 2Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 8 of 67 C-K Associates, LLC Footnotes for Environmental Impact Analysis Matrix 1. Activities that may affect a marine sanctuary or to pographic feature. Specifically, if the well or pl atform site or any anchors will be on the seafloor within the:

a. 4-mile zone of the Flower Garden Banks, or the 3-mi le zone of Stetson Bank; b. 1000-m, 1-mile or 3-mile zone of any topographic fe ature (submarine bank) protected by the Topographic Features Stipulation attached to an OCS lease;

c. Essential Fish Habitat (EFH) criteria of 500 ft fro m any no-activity zone; or d. Proximity of any submarine bank (500 ft buffer zone ) with relief greater than 2 meters that is not pro tected by the Topographic Features Stipulation attached to an OCS lease.

2. Activities with any bottom disturbance within an OC S lease block protected through the Live Bottom Act ivities (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 be ing in water depths 400 meters or greater.

5. Exploration or production activities where H 2 S concentrations greater than 500 ppm might be enco untered.

6. All activities that could result in an accidental s pill of produced liquid hydrocarbons or diesel fuel that you determine would impact these environmental resources. If the propo sed 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 des ignated by the MMS as

having high-probability for the occurrence of shipw recks or prehistoric sites, including such blocks t hat will be affected that are adjacent to the lease block in which your planned a ctivity 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 o r two.

8. All activities that you determine might have an adv erse effect on endangered or threatened marine mamm als or sea turtles or

their critical habitats.

9. Production activities that involve transportation o f produced fluids to shore using shuttle tankers or barges

Copied from BOEMRE FORM MMS-142 Page 2 of 2Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 9 of 67 C-K Associates, LLC 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 i n which burrowing infauna are the most abundant inver tebrates. Single-celled bacteria to invertebrates as well as fish inhabit s oft-bottom habitat at almost every depth range in the GOM (USDOI MMS 2007a). Major gr oups of animals that live in this habitat include: bacteria and other mi crobenthos; meiofauna (0.063-0.3 millimeter (mm)); macrofauna (>0.3 mm); and (4) meg afauna (larger organisms such as crabs, sea pens, sea cucumbers, crinoids, a nd bottom-dwelling (demersal) fish). All of these groups are represented through out the entire GOM from the continental shelf to the deepest abyssal depths (ab out 3,850 m (12,630 ft)). The seabed in the project area is complex and ranges fr om smooth to slightly hummocky in the basins to rugged in the highly faul ted areas in the shallow salt (Fugro 2010). Impact Analysis – IPFs potentially affecting soft bottom benthic com munities are effluent discharges (drilling mud and cuttings) and accidental releases. The proposed drilling and support activities will be do ne with a dynamically positioned rig, so there are no associated anchors, anchor chain or wire ropes. Discharges of drilling mud and cuttings only move t o limited directions depending on prevailing currents. Impacts will als o be limited by the drilling one well at a time. This would not result in a signifi cant impact on the soft-bottom benthic communities because the duration and areal extent of the proposed activities would be limited and recolonization of b enthic communities is facilitated from nearby surrounding areas (USDOI MM S 2007a). Oil from a surface spill can be driven into the wat er 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 m agnitude 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. 1 985).
An accidental release (blowout) at the seafloor cou ld create a crater and resuspend and disperse large quantities of bottom sediments w ithin a 300-m (984-ft) radius of the blowout site (USDOI BOEMRE 2011a, 2011b), bu rying both infaunal (live in the sediment) and epifaunal (live on the sedimen t) organisms and interfering with sessile invertebrates that rely on filter-feed ing organs. Even in situations where substantial burial of typical benthic infauna l communities occurred, recolonization from populations from neighboring so ft 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 tha n one year for most all macrofauna species (USDOI MMS 2007a; NRC 2003; NRC 2006). Low concentrations of dispersed oil may occur in ar eas near a blowout site in offshore waters following the subsea use of dispers ants (USDOI BOEMREEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 10 of 67 C-K Associates, LLC

2011a; Joint Analysis Group 2010). The behavior an d impacts of subsurface concentrations of dispersed oil are not well known, but such oil could have the potential to contact soft bottom benthic communitie s beyond the 300

‐ m (984

‐ ft) radius estimated by BOEMRE (USDOI BOEMRE 2011a; USD OI 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 wi ll vary depending on, among other factors, the magnitude and duration of such a n 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 im pact is expected to soft bottom benthic communities. Contact from small spills is minimized due to water depth. Implementation of new BOEMRE environmental and safe ty 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 edg e, 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 f eatures also support, either as shelter or food, or both, large numbers of commerci ally and recreationally important fishes; and they provide a relatively pri stine 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 Ac t (MPRSA) of 1972 established the National Marine Sanctuary Program, which is administered by National Oceanic and Atmospheric Administration (NO AA). 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 a nd are located in the WPA (USDOI MMS 2002, 2007a, 2008b; USDOI BOEMRE 201 1b). Impact Analysis – The only IPF potentially affecting topographic feat ures is accidental releases. The nearest topographic featu re 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 Canyo n 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 suc h impact is not expected. Implementation of new BOEMRE environmental and safe ty regulations mayEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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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 northea stern portion of the CPA is known as the “pinnacle trend, ” at the outer edge of the Mississippi-Alabama shelf between the Mississippi R iver 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 an d structural complexity. Impact Analysis

– The only IPF potentially affecting pinnacle trend features i s an accidental release. The pinnacle trend area is abo ut 568 km (353 mi) northeast from the Gila project area, along the shelf edge so uth 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 concentration s 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 expect ed. Implementation of new BOEMRE environmental and safety regulations may fur ther reduce the probability of the occurrence of a large volume/lon g duration spill.

3.1.4 Live Bottom/Low Relief

Affected Resource – Live-bottoms (low relief features) means seagrass communities; areas that contain biological assembla ges 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 accumul ation of turtles, fishes, or other fauna (USDOI MMS NTL 2009-G39). The closest live b ottom feature is beyond the pinnacle trend area which is greater than 568 k m (353 mi). Impact Analysis – The only IPF potentially affecting live bottoms w ould be accidental releases. The Gila project area is not covered by the Live B ottom (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 safe ty 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 o r areas that could support high density chemosynthetic comm unities, deepwater corals, and other associated hard bottom communities (USDOI MMS NTL 2009-G39). Chemosynthetic communities are defined as persisten t, largely sessile assemblages of marine organisms dependent upon chem osynthetic bacteria asEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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their primary food source (MacDonald 1992) (Figure 3). A carbon source independent of photosynthesis is used by chemosynth etic communities. Although the process of chemosynthesis is entirely microbial , chemosynthetic bacteria and their primary production can support thriving assem blages of higher organisms through symbiosis. The occurrence of chemosyntheti c organisms dependent on hydrocarbon seepage has been documented in water de pths as shallow as 290 m (951.4 ft) (Roberts et al. 1990) and as deep as 2,2 00 m (7,217.76 ft) (MacDonald 1992). This depth range places chemosynthetic comm unities in the deepwater region of the GOM. The communities are dominated by vestimentiferan tu beworms, mytilid mussels, vesicomyid clams, and infaunal lucinid or thyasirid clams (USDOI MMS 2002, 2007a and 2008b) (MacDonald 1990). These faunal gr oups tend to display distinctive characteristics in terms of how they ag gregate, the size of aggregations, the geological and chemical propertie s 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 G OM are new to science and remain undescribed. Impact Analysis – The IPF potentially affecting high density deepwat er 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 assess ment (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 dynamical ly positioned rig, so there are no associated anchors, anchor chain or wire ropes. BP has provided BOEMRE with the required maps, anal yses 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 20 10) 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 suppo rt 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 presenc e of chemosynthetic communities are recognized (Fugro 2010). The poten tial for the presence of chemosynthetic communities is considered very low.

As discussed in Section 3.1.1 sub-sea concentration s 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 d eepwater 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/lon g duration spill.Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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3.1.6 Water Quality

Affected Resource – Deepwater areas in the northern GOM are relative ly homogeneous with respect to temperature, salinity, and oxygen (USDOI MMS 2007a). Discharges associated with offshore oil an d gas exploration and production activities located in the Western and Ce ntral GOM must be authorized for discharge under the current “National Pollutant Discharge Elimination system (NPDES) General Permit for Discharges from the Offs hore Subcategory of the Oil and Gas Extraction Category for the Western Por tion of the Outer Continental Shelf of the Gulf of Mexico off the Coa sts of Louisiana and Texas”

, GMG290000 (USEPA 2007). This general permit sets p rohibitions, 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 dril ling fluids and cuttings, uncontaminated ballast water, uncontaminated seawat er, deck drainage, sanitary wastes, domestic wastes, and other miscellaneous di scharges (excess cement slurry, blowout preventer control fluid, uncontamin ated freshwater and saltwater, etc.). Discharges associated with oil and gas prod uction activities include deck drainage, produced water, domestic wastes, sanitary waste water, and miscellaneous discharges (uncontaminated seawater, subsea wellhead preservation fluids, subsea production control flui ds and hydrate control fluids). Discharges associated with support vessels must com ply with United States Coast Guard (USCG) regulations found at 33 CFR 140, 33 CF R 151 and 33 CFR 159. The purpose of these regulations is to promote safe ty 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 regulatio ns incorporate and implement the OCSLA, Shore Protection Act of 1988, and the Ac t 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 Shi ps (MARPOL 73/78). Impact Analysis - IPFs that could result in water quality degradation from the proposed operations at Keathley Canyon Block 93 inc lude operational effluents (discharges) and accidents. Refer to Section 5.0 o f the EP for a list of operational discharges associated with this operation. Operational discharges could impact water quality i n the immediate vicinity of the point of discharge (less than 100 m regulatory mixi ng zone boundary). However, any constituents found in these discharges are expe cted 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 e ffluents discharged are expected to be in compliance with the current NPDES General Permit GMG290000, thereby eliminating significant biologic al or ecological effects. Further, the U. S. Environmental Protection agency (USEPA) has stated that discharges in compliance with the NPDES Permit, GMG 290000 will not cause unreasonable degradation of the water quality and t he marine environment (USEPA 2004). Therefore, operational effluent disc harges are not expected to have a significant impact to water quality.Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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Support vessels may discharge treated sanitary wast es, deck drainage, ballast water, bilge water and domestic wastes. These disch arges could impact water quality in the immediate vicinity of the point of d ischarge. 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 contract ual agreements with vessel owner/operators require support vessel discharges t o comply with all applicable USCG regulations. Therefore, support vessel discha rges are not expected to have significant impacts to water quality. Following the 2010 Macondo incident, there is a lar ge 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 Lab oratory (Berkley Lab) operated by the University of California is studyin g the impacts and fate of deepwater oil plumes. An initial study result sugg ests that the potential exists for rapid intrinsic bioremediation (bacterial degradati on) of sub-sea dispersed oil in the water column by deep-sea indigenous microbial a ctivity without significant oxygen depletion (Hazen et al. 2010). Other studie s lead by David Valentine (University of California, Santa Barbara) and John Kessler (Texas A&M University) are studying the effects of deepwater d issolved hydrocarbon gases (e.g. methane, propane and ethane) and effects to m icrobial 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 popul ations for rapid hydrocarbon degradation of sub-sea oil plumes (Kessler et al. 2 011; Valentine et al. 2010). These and other studies are ongoing and more data w ill be generated, analyzed, and final conclusions made. As more information fr om these studies is made publicly available the impacts to water quality fro m oil spills and potential deepwater plumes will be addressed and analyzed acc ordingly by the scientific community. Results to date suggest that sub-surfac e concentrations of hydrocarbons may be more rapidly degraded by biolog ical means than was previously anticipated. During a spill or well blowout, the water quality o f marine waters could be impacted. The extent of such impacts will vary dep ending on, among other factors, the magnitude and duration of such an inci dent. Implementation of new BOEMRE environmental and safety regulations may fur ther reduce the probability of the occurrence of a large volume/lon g 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 lar vae become part of theEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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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 (Unde rwood and Fairweather 1989; Doherty and Fowler 1994). In general, the distribu tion 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 (Synodonti dae), and sciaenids (drums, seatrout, kingfish and others) (McEachran and Fechh elm 1998). These fish are very dependent on estuaries as nursery grounds (Dar nell 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 (Bothi dae). 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 Fechhe lm 1998). The remaining OCS, ranging to a depth of approximat ely 200 m (656 ft), generally has a muddy or silty soft bottom and domi nated by hakes (Phycidae), scorpionfishes (Scorpaenidae), and ogcocephalids (b atfishes) (McEachran and Fechhelm 1998). Pelagic fishes occurring from the beach to the open ocean, portioned only by temperature, salinity and turbidity (Hoese and Moor e 1977) are divided into coastal pelagic species, oceanic pelagic species, m esopelagic species, and bathypelagic species. Coastal pelagic species trav erse shelf waters of the region throughout the year. The major coastal pelagic fam ilies occurring in the region are Carcarhinidae (requiem sharks), Elopidae (ladyf ish), Engraulidae (anchovies), Clupeidae (herrings), Scombridae (mackerels and tun as), Carangidae (jacks and scads), Mugilidae (mullets), Pomatomidae (bluefish) , and Rachycentridae (cobia) (FishBase 2006). Oceanic pelagic species such as tuna occur througho ut 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 evi dence that these species spawn in the GOM (Richards et al. 1989). Many of t he oceanic fishes associate with drifting Sargassum , which provides forage areas and/or nursery refuge

. Mesopelagic fish assemblages in the GOM include myc tophids (lanternfishes), with gonostomatids (bristlemouths) and sternoptychi ds (hachetfishes). These fishes make extensive vertical migrations during th e night from mesopelagic depths (200-1,000 m or 656-3,281 ft) to feed in hig her, food-rich layers of theEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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water column (Hopkins and Baird 1985). Mesopelagic fishes are important ecologically because they transfer substantial amou nts of energy between mesopelagic and epipelagic zones over each diel cyc le. 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 fr om 4° Celsius (C) to 10°C. Common species include deep-sea angler fishes (Cera tioidei), 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 (B arkuloo 1988). Gulf sturgeons are bottom suction feeders that have vent rally located, highly extrusible mouths. Fishes that forage by taste are opportunist ic feeders because smell is much more discriminating than taste. Another adapta tion of sturgeon to major rivers and offshore waters is mobility (an adaptati on 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 river s and the degradation of water quality (Barkuloo 1988). The Gulf sturgeon critical habitat occurs in the es tuarine 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. Des ignated 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 small tooth sawfish is peninsular Florida and common only to the everglades. The cur rent designated critical habitat for the smalltooth sawfish is two areas alo ng the southwest coast of Florida (http://www.nmfs.noaa.gov/pr/species/fish/s malltoothsawfish.htm). The Center for Biological Diversity (CBD) petitione d the National Marine Fisheries Service (NMFS), on May 24, 2010 requestin g that the Atlantic bluefin tuna ( Thunnus thynnus ), an Atlantic bluefin tuna distinct population seg ment (DPS) consisting of one or more subpoplations in th e 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 t he species. The NMFS appointed an Atlantic bluefin tuna status review team (SRT) t o assess the species status. After an extensive scientific review by the SRT inc luding comments from invited Atlantic bluefin tuna experts and five listening se ssions with Atlantic bluefin tuna fishermen it was announced on May 27, 2011 that Atl antic bluefin tuna currently do not warrant species protection under the Endange red Species Act (ESA) (Atlantic Bluefin Tuna Status Review Team 2011). Th e NMFS has committed to revisit this decision by early 2013, when more info rmation will be availableEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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(http://www.nmfs.noaa.gov/stories/2011/05/bluefin_t una.html and http://www. noaanews.noaa.gov/stories2011/20110527_bluefintuna .html). Impact Analysis – IPFs that could affect fisheries include drillin g rig and support vessel presence (noise and lights), effluent discha rges, cooling water intakes, and accidents. Fish may be attracted to the drilling r ig, as a floating structure in the deepwater environment. Epipelagic fishes such as t unas, dolphin, billfishes, and jacks, are commonly attracted to fixed and drifting surface structures (e.g., Holland et al. 1990; Higashi, 1994; Relini et al. 1 994). The feeding of epipelagic predators could be enhanced by attracting and conce ntrating smaller fish species. The drilling rig is a single, temporary structure; therefore, impacts on fish populations, whether beneficial or adverse, would b e considered insignificant. Discharges associated with the proposed action to m arine 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 f t), 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 offs hore 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 permi t (GMG290000) design requirements for CWIS are not applicable. Regardle ss, no significant entrainment or impingement impact on key species is expected ba sed 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 surf ace or subsurface waters. Behavior science associated with adult fish indicat e that they would likely avoid the area of a spill, but fish eggs and larvae withi n 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 da mage (Baker et al. 1991; Malins et al. 1982). Observations at oil spills around th e world, including the Exxon Valdez spill in Prince William Sound, indicate that free-s wimming fish ordinarily avoid harm from oil spills (NRC 1985). Some work h as 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 lit er ( μ g/l) by a species of minnow. Adult fish must experience continual exposure to re latively high levels of hydrocarbons over several months before secondary t oxicological 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 in gestion of oil or oiled prey and through the uptake of dissolved petroleum products through the gills and epithelium by adults and juveniles (NRC 1985). Upo n exposure to spilled oil, liver enzymes of fish oxidize soluble hydrocarbons into compounds that are easilyEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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excreted in the urine (Spies et al. 1982). Ordinar y changes in salinity, temperature, and food abundance (Evans and Rice 197 4; 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-k ills 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 th e site of the Amoco Cadiz wreck (USDOI MMS 2002). For OCS-related oil spills to have a substantial ef fect on a commercial fishery resource, whether estuary dependent or not, eggs an d larvae would have to be concentrated in the immediate spill area. This are a could be very large considering the maximum blowout discharge volume. Oil components also would have to be present in highly toxic concentrat ions when both eggs and larvae are in the pelagic stage (Longwell 1977). W hen eggs and larvae are exposed to spilled oil in the water column, the suc cess of a spawning event may be reduced (USDOI BOEMRE 2011b). The effect is exp ected to be lethal for eggs and larvae that contact spilled oil (USDOI BOE RME 2011b). However, fish overproduce eggs on an enormous scale and the overw helming majority of them die at an early stage, generally as food for predat ors. 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 th e 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 impa ct 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 prese nted in the Multisale EIS (USDOI MMS 2007a), and concluded that an area nearl y 130 mi (209 km) from the nearest coast, and not located within designate d critical habitat for Gulf sturgeon, that it was unlikely there will be any st urgeon in the area due to water depths that far exceed the recorded depths preferre d by Gulf sturgeon. Additionally, substrate type and potential forage b ase associated with bottom types at these depths are not conducive for sustain ing a Gulf sturgeon forage base. Therefore, because of the floating nature of oil an d the small tidal range of the GOM, oil spills alone would typically have very lit tle impact on benthic feeders such as the Gulf sturgeon. Implementation of new BOEMRE environmental and safe ty regulations may further reduce the probability of the occurrence of a large volume/long duration spill. No significant impact is expected to fisher y resources.
3.1.8 Marine Mammals

Affected Resource – Twenty-eight cetacean (whales and dolphins) and one sirenian (manatee) species have confirmed occurrenc es in the GOM. Cetaceans are divided into two major suborders: Mysticeti (i. e., baleen whales) and Odontoceti (i.e., toothed whales, dolphins and thei r allies). Of the seven baleenEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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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 Sireni a found in the GOM is the endangered West Indian manatee ( Trichechus manatus ). All marine mammals are protected species under the MMPA. There are no cri tical habitats designated within the offshore GOM for the threatened and enda ngered species of mammals listed above. The GOM Cetacean Program (GulfCet) I study showed t hat 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 1996-1 997), administered by the U.S. Geological Survey, Biologi cal Resources Division (BRD 1999), continued work on patterns of distribution a nd abundance of GOM cetaceans and identified possible associations betw een 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 affec ted by various hydrological circulation patterns. River discharge, wind, and t he loop current generally drive these patterns. Most of the river discharge into t he northern GOM is transported west and along the coast. Circulation on the conti nental 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 stud ies suggested that seafloor depth was the most important variable in habitat pa rtitioning among cetacean species in the northern GOM (Baumgartner 1995; Davi s 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 a nd 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. latirostri s). 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 mo ves 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 sou rces. Crystal River, in Citrus County, is typically the northern limit of the mana tee’s winter range on the Gulf coast. Manatees are uncommon along the Florida Panh andle and are infrequently found (strandings and sightings) as far west as Lou isiana and Texas (Powell and Rathbun 1984; Rathbun et al. 1990; Schiro et al. 19 98).Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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Impact Analysis – IPFs that could affect marine mammals include drill ing rig and installation/support vessel presence (noise and lights), effluent discharges, accidents and loss of debris. Sound from drilling activities, installation/suppor t vessels and helicopters may elicit a startle reaction from marine mammals. Thi s reaction may lead to disruption of marine mammals’ normal activities. S tress may make them more vulnerable to parasites, disease, environmental con taminants, and/or predation (Majors and Myrick 1990). There is little conclusiv e evidence for long-term displacements and population trends for marine mamm als relative to sound; therefore, no significant impact is expected. Discharges associated with the proposed action to m arine 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 f t), 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 vari ous 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 e ffective barrier to noxious substances found in petroleum. Crude oil or volatile distillates release toxic vap ors that, when inhaled, can lead to irritation of respiratory membranes, lung congestio n, and pneumonia. Subsequent absorption of volatile hydrocarbons into the bloods tream may accumulate into such tissues as the brain and liver, causing neurol ogical disorders and liver damage (Geraci and St. Aubin 1982; Hansen 1985; Ger aci 1990). Toxic vapor concentrations just above the water’s surface (wher e 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 ot her light components (Geraci and St. Aubin 1982). Cetaceans may consume oil con taminated prey (Geraci 1990) or incidentally ingest oil (USDOI MMS 2007a). Studies have been completed with varying results whether marine mamma ls avoid spilled oil (USDOI BOERME 2011b). In some cases, marine mammal s have been shown to detect and avoid oil slicks (Geraci and St. Aubin 1 990), while other reports indicate marine mammals did not attempt to avoid sp illed oil (Smultea and W ürsig 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 dugo ngs (St. Aubin and Lounsbury 1990). Direct contact with discharged oi l probably does not impact adult manatees’ thermoregulatory abilities because they use blubber for insulationEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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(USDOI MMS 2008b). Manatees are nonselective, gene ralized 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 safe ty 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 th at cetaceans (more specifically, sperm whales) possess for detecting and avoiding th e various flowlines, risers, umbilicals, and mooring lines (USDOI MMS 2002 and 2 007a). Sperm whales are known to get entangled in deep-sea cables (Heezen 1 957). 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 inj ury or death (Laist et al. 2001). Collisions between OCS vessels and cetacean s 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 de ath or serious injury to marine mammals (Laist 1997). Compliance with NTL 2 007-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 wate rs 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 endang ered. Sea turtles spend nearly all of their lives in the water. Females must emerge p eriodically from the ocean to nest on beaches. Sea turtles are long-lived, slow-r eproducing animals. It is generally believed that all sea turtle species spen d the first few years of their lives in pelagic waters, occurring in driftlines and conv ergence zones (in sargassum rafts) where they find refuge and food in items tha t accumulate in surface circulation features (Carr 1987). No critical habit at has been designated for these species in the Gulf of Mexico. Adult turtles in the GOM are apparently less abunda nt in the deeper waters of the GOM than they are in waters less than 27-50 m (80-1 60 ft) deep (NRC 1990). More sea turtles are sighted in the northeastern GO M than in the northwestern GOM (Thompson 1999). Sea turtle abundance in the GO M 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 zon es of convergence. GulfCet II studies sighted most loggerhead, Kemp’s ridley and leatherback sea turtles over shelf waters. Historically these spec ies 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; Lo hoefener et al. 1990). Deep waters may be used by all species as a transitory h abitat.Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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The green turtle has a global distribution in tropi cal and subtropical waters. Important feeding areas for green turtles in Florid a include the Indian River, Florida Bay, Homosassa River, Crystal River, and Ce dar Key (USDOC NMFS 1993). Green turtles in the western GOM are primar ily restricted to the lower Texas coast where seagrass meadows and algae-laden jetties provide developmental habitat, especially during warm month s (Landry and Costa 1999). The leatherback is the most pelagic and most wide-r anging of sea turtles, undertaking extensive migrations following depth co ntours for hundreds, even thousands, of kilometers (Morreale et al. 1996; Hug hes et al. 2001). It is commonly found in relatively shallow continental sh elf waters along the U.S. Atlantic coast (Hoffman and Fritts 1982; Knowlton a nd Weigle 1989; Shoop and Kenney 1992) and northern GOM (Leary 1957; Fritts e t al. 1983a; Lohoefener et al. 1988, 1990; Collard 1990; Davis et al. 2000). The hawksbill occurs in tropical and subtropical se as 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 t he GOM States and from along the eastern seaboard as far north as Massachusetts, with the exception of Connecticut; however, sightings north of Florida ar e rare (USDOC NMFS 1993). Texas and Florida are the only states where hawksbi lls 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 abundan t 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 inn er 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 d epths less than 100 m (328 ft) (Shoop et al. 1981; Fritts et al. 1983a; Davis et a l. 2000). Impact Analysis – IPFs that could affect sea turtles include drill ing rig and installation/support vessel presence (noise and lig hts), effluent discharges, accidents, and loss of debris. Disturbance (e.g., noise) and/or exposure to sublet hal levels of biotoxins and anthropogenic contaminants may stress animals, weak en their immune systems, and make them more vulnerable to parasites and dise ases that normally would not be fatal (USDOI MMS 2002, 2007a and 2008b). Sound from drilling activities, installation/support vessels, and helicopters may e licit a startle reaction from sea turtles, but this is a temporary disturbance. No s ignificant impact is expected to sea turtles. Discharges associated with the proposed action to m arine 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 nearEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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background levels at a distance of 1,000 m (3,281 f t), 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 res ult of impacts on prey items or possibly through ingestion in the food chain (API 1 989). No significant impact is expected to sea turtles.
Sea turtle habitat in the GOM includes inshore, coa stal, and oceanic waters, as well as numerous beaches in the region, sea turtles could be impacted by accidental spills (USDOI MMS 2002 and 2007a). Depe nding on the timing of the spill’s occurrence in coastal waters, its impact an d resulting cleanup may interrupt sea turtle migration, feeding, mating, and/or nesti ng activity for extended periods (days, weeks, months) (USDOI MMS 2007a). Exposure to hydrocarbons persisting in the sea following an oil slick may re sult in sublethal and lethal impacts (e.g., decreased health, reproductive fitne ss, and longevity; and increased vulnerability to disease) to sea turtles (USDOI MMS 2002, 2007a). Sea turtle hatchling exposure to, fouling by, or consumption o f tarballs persisting in the sea following the dispersal of an oil slick would likel y be fatal (USDOI MMS 2002, 2007a). The net result of any disturbance would de pend on the size and percentage of the population affected, ecological i mportance of the disturbed area, environmental and biological parameters that influe nce an animal’s sensitivity to disturbance and stress, and the accommodation time in response to prolonged disturbance (St. Aubin 2001). Implementation of ne w BOEMRE environmental and safety regulations may further reduce the proba bility 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 with in 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 cause d the death or serious injury of sea turtles (Balazs 1985). Compliance with NTL 200 7-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 Gul f of Mexico is located to the southwest of this center of circulation, res ulting in a prevailing southeasterly to southerly flow, which is conducive to transporting emissions toward shore. This circulation is affected by tropi cal 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 pre sumed 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 (SO x 

### ), Nitrogen Oxides (NO x 

### ), Volatile Organic Compounds (VOC), and Carbon Monoxide (CO) during operations. Combustion engines (located onEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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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 r esult from the drilling rig operations, helicopters and service ve ssels and an accidental release. Emissions occur mainly from combustion or burning o f diesel fuel. The combustion of fuels occurs primarily on generators, pumps, or motors and from lighter fuel motors. Primary air pollutants typica lly associated with OCS activities are suspended PM, SOx, NOx, VOCs, and CO . The proposed activities are located approximately 172.4 miles from the near est shoreline. Due to the distance from shore

‐ based pollution sources, offshore air quality is ex pected 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 a ir 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 aff ect 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 a s 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 signific ant 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, the se releases are not expected to impact onshore air quality because of the prevailin g atmospheric conditions, emission height, emission rates, and the distance o f Keathley Canyon Block 93 from the coastline. Implementation of new BOEMRE e nvironmental and safety regulations may further reduce the probability of t he 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 incl uding 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 m odel areas in the GOM where historic shipwrecks were most likely to exist. A s tudy 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 be tween 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 ob served frequencies of shipwrecks were within areas of intense marine traf fic, such as the approachesEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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and entrances to seaports and the mouths of navigab le rivers and straits. The most recent study in 2003 used about 15 years of high-re solution 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 histo ric ships, ranging in age from an 18th-century armed sailing ship to a World War I I German U-boat. In addition to the above studies, historic shipwrec ks have, to date, been discovered through oil industry sonar surveys in wa ter depths up to 1,981 m (6,500 ft). Over a dozen shipwrecks have been loca ted in deep water and nine of these ships have been confirmed visually as histori c 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 stu dy then recommended including some deepwater areas, primarily on the ap proach to the Mississippi River, among those lease areas requiring archaeolog ical investigation. Because of this, BOEMRE revised its guidelines for conducting archaeological surveys and added about 1,200 lease blocks to the list of block s requiring an archaeological survey and assessment (NTL 2005-G07 and NTL 2008-G2 0). 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, ha ve not been located on the ocean floor. The BOEMRE Shipwreck Database lists 911 wre cks in the CPA and 494 wrecks in the WPA (USDOI MMS 2007a; USDOI BOERME 20 11b). Impact Analysis – IPFs for shipwrecks will result from accidental re leases. The lease blocks within Keathley Canyon Block 93 are no t stipulated as requiring archaeological resource surveys and reports (NTL 20 05-G07 and 2008-G20). A review of the Shallow Hazards Assessment for Gila P rospect, Keathley Canyon (Fugro 2010) indicates there is no known or potenti al shipwreck sites located within the survey area. Should BP discover man-mad e debris that appears to indicate the presence of a shipwreck within or adja cent to the Gila Project area, BP will immediately halt operations. The proposed activities will be done with dynamic positioned vessels which do not have associ ated 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 cou ld create a crater and resuspend and disperse large quantities of bottom sediments w ithin a 300-m (984-ft) radius of the blowout site (USDOI BOEMRE 2011a, 2011b), bu rying shipwrecks. Subsurface spills could result in the formation and settling of oil-saturated material, and oil-sediment particles could come int o contact with shipwrecks. The extent of such impacts will vary depending on, among other factors, the magnitude and duration of such an incident. No sig nificant impact is expected to shipwrecks. Implementation of new BOEMRE environme ntal and safety regulations may further reduce the probability of t he occurrence of a large volume/long duration spill.Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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3.1.12 Prehistoric Archaeological Sites

Affected Resource – Archaeological resources are any material remain s of human life or activities that are at least 50 years of age and that are of archaeological interest (30 CFR 250.105). The Arch aeological Resources Regulation (30 CFR 250.194) provides specific autho rity to each BOEMRE Regional Director to require archaeological resourc e surveys, analyses, and reports. Surveys are required prior to any explora tion or development activities on leases within areas determined to have a high po tential for archaeological resources (NTL 2005-G07 and NTL 2008-G20). Available evidence suggests that sea level in the n orthern GOM was at least 90 m (295 ft), and possibly as much as 130 m (427 ft), l ower than present sea level during the period 20,000-17,000 years before presen t (Nelson and Bray 1970). Sea level in the northern GOM reached its present s tand around 3,500 years before present (Pearson et al. 1986). The arrival of early man into the GOM region is acc epted to be around 12,000 years before present (Aten 1983). Sea-level for th e northern GOM would have likely been approximately 45-60 m (148-197 ft) belo w the present day sea level (CEI 1977 and 1982). The continental shelf shorewa rd of the 45 to 60 m (148 to 197 ft) bathymetric contours has potential for preh istoric 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, B OEMRE adopted the 60 m (197 ft) water depth as the seaward extent for arch aeological 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 f eatures, which have a high potential for associated prehistoric sites. Invest igations 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 i n the shallow inundated portions of the OCS.
The McFaddin Beach site, east of Galveston in the M cFaddin National Wildlife Refuge, has produced late Pleistocene megafaunal re mains 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 R iver Valley and evaluated for archaeological potential 1986 (CEI 1986). Surveys from other areas of the western part of the CPA have produced evidence of f loodplains, terracing, and point-bar deposits in association with relict late Pleistocene fluvial systems. Prehistoric sites associated with these features wo uld have a high potential for preservation. Salt diapirs with bathymetric expres sion 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 Pale o-Indian site associated with aEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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salt-dome solution feature (CEI 1977). The proximit y of most of these relict landforms to the seafloor facilitates further inves tigation and data recovery. Impact Analysis - IPFs for archaeological resources will result from accidental releases. Keathley Canyon Block 93 is not stipulat ed 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 site s 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 cou ld create a crater and resuspend and disperse large quantities of bottom sediments w ithin a 300-m (984-ft) radius of the blowout site (USDOI BOEMRE 2011a, 2011b), bu rying archaeological resources. Subsurface spills could result in the formation and settling of oilsaturated material, and oil-sediment particles coul d come into contact with archaeological resources. The extent of such impac ts will vary depending on, among other factors, the magnitude and duration of such an incident. No significant impact is expected to archaeological re sources. Implementation of new BOEMRE environmental and safety regulations may further reduce the probability of the occurrence of a large volume/lon g 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, breed ing, feeding, and growth to maturity. Due to the wide variation of habitat req uirements 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 Excl usive Economic Zone (EEZ). The Magnuson-Stevens Fishery Conservation and Manag ement Act of 1976, as amended through 1998, places requirements on any Fe deral agency with respect to EFH, and requires the development of management plans for all managed fish species. The Gulf of Mexico Fisheries Management C ouncil (GMFMC) currently maintains Fishery Management Plans (FMP) for a vari ety of bay and estuarine species that spend a large part of their life cycle s in these nearshore environments. Occurrence of these managed species, along with maj or adult prey species and relationships with estuary and bay systems in the E astern 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 A reas (USDOI MMS 2007a and 2008b). The GMFMC currently describes FMP’s for the followi ng 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 mackerelEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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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 an d bay systems in the GOM. None of the stocks managed by the GMFMC are endange red or threatened. Migratory species that are likely to be encountered include tuna (Scombridae), billfish (Istiophoridae), swordfish (Xiphiidae), an d sharks (Squaliformes). These groups are under the direct management of NOAA Fish eries 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 billf ish 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, adult s) • Atlantic skipjack tuna (spawn, eggs, larvae, adul ts) • 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 Ha bitat 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 shel l 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 NMF S 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 s harks of this temperate zone in the GOM because most species are highly migratory, usin g diverse habitats in apparently nonspecific or poorly understood ways. Temperature is a primary factor affecting the distribution of sharks, and th eir movement in coastal waters isEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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usually correlated with unpredictable seasonal chan ges in water temperature. Some of the highly migratory species occurring offs hore beyond the 200-m isobath, and many, such as billfishes, are associat ed with upwelling areas where canyons cause changes in current flow (upwelling) a nd 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 inc lude 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, billfishe s, 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 fi sh species. The drilling operations are temporary. Impacts on fish populati ons, whether beneficial or adverse, would be considered insignificant. Discharges associated with the proposed action to m arine 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 f t), 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 surf ace or subsurface waters. Behavior science associated with adult fish indicat es that they would likely avoid the area of a spill, but fish eggs and larvae withi n the spill area of the northern GOM could be killed (USDOI MMS 2002, 2007a). Marine sanctuaries and national estuary reserves ar e considered to be HAPC that meet these general HAPC guidelines. Further releva nt 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 sig nificant impact is expected to EFH resources. Implementation of new BOEMRE enviro nmental and safety regulations may further reduce the probability of t he occurrence of a large volume/long duration spill.

3.2.2 Marine and Pelagic Birds

Affected Resource – The offshore waters, coastal beaches, and contig uous wetlands of the northern GOM are populated by both resident and migratory species of coastal and marine birds that can be sep arated into five major groups: diving birds, shorebirds, marsh birds, wading birds and water fowl. Seabirds are a diverse group of birds that spend mu ch 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 (Terr es 1991). Species diversity and overall abundance is highest in the spring and summ er and lowest in the fall andEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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winter. Four ecological categories of seabirds hav e been documented in the deepwater areas of the GOM: summer migrants (e.g., shearwaters, storm petrels and boobies), summer residents that breed in the GO M (e.g., sooty, least, and sandwich tern, and frigate birds), winter residents (e.g., gannets, gulls, and jaegers), and permanent resident species (e.g., lau ghing 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). S eabirds typically aggregate in social groups called colonies; the degree of colony formation varies between species (Parnell et al. 1988). They also tend to a ssociate with various oceanic conditions including specific sea-surface temperatu res, salinities, areas of high planktonic productivity, or current activity. Seabi rds obtain their food from the sea with a variety of behaviors including piracy, s cavenging, 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 u se offshore structures and platforms for resting, feeding, or as temporary she lter from inclement weather (Russell 2005). Effluent discharges are likely to have negligible impacts on the birds due to rapid dispersion, the small area of oc ean affected, the intermittent nature of the discharges, and the mobility of these animals. Helicopter and service-vessel traffic could sporadi cally disturb feeding, resting, or nesting behavior of birds or cause abandonment of p referred habitat. These impact-producing factors could contribute to indire ct population loss through reproductive failure resulting from nest abandonmen t. The Federal Aviation Administration (FAA) (Advisory Circular 91-36C) and corporate helicopter policy specify minimum altitude over populated area s 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 incl ement weather. Due to the short term duration and sporadic frequency, no sign ificant impact is expected.

Service vessels would use selected nearshore and co astal (inland) navigation waterways, or corridors, and adhere to protocol set forth by the U. S. Coast Guard (USCG) for reduced vessel speeds within these inlan d areas. Routine presence and low speeds of service vessels within these wate rways would diminish the effects of disturbance from service vessels on near shore and inland populations of coastal and marine birds. The effects of service-ve ssel traffic on birds offshore would not be significant. Marine birds can become entangled and snared in dis carded trash and debris. In addition, many species will readily ingest small pl astic debris, either intentionally or incidentally. Interaction with plastic material s is therefore very serious and can lead to permanent injuries and death. Compliance w ith NTL 2007-G03 is expected to result in no significant impact with tr ash and debris. Refer to Section 1.0 for additional information.Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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Physical oiling of individuals or local groups of b irds, depending on the extent and concentration could result in some degree of ac ute and chronic physiological stress (USDOI MMS 2002, 2007a and 2008b). In addit ion, recent spill experience showed that bird mortality is expected t o occur during a large volume/long duration spill (USDOI BOEMRE 2010b).
Stress, trauma, and shock enhance the effects of ex posure and poisoning (USDOI MMS 2002, 2007a and 2008b). Low levels of oil coul d stress birds by interfering with food detection, feeding impulses, predator avo idance, territory definition, homing of migratory species, susceptibility to phys iological disorders, disease resistance, growth rates, reproduction, and respira tion (USDOI MMS 2002, 2007a and 2008b). Implementation of new BOEMRE environmental and safe ty 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 safet y is an accidental release. An accidental hydrogen sulfide (H 2 

### S) 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 H 2 

### S 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 H 2 

### S 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 compound s. The amount of exposure will depend on the magnitude and duration, the phys ical/chemical characteristics of the material, the oceanic conditions and the eff ectiveness of the spill response. During the recent Macondo event extensive air sampl ing conducted by the USEPA found no evidence of onshore levels of contam inants that are of significant concern for the long term health of res idents of coastal communities (www.epa.gov/bpspill/air.html and www.epa.gov/bpspi ll/air-mon.html). Wildlife cleaning and rehabilitation workers have r eported concerns including scrapes and cuts, itchy or red skin or rash, and sy mptoms of headache or feeling faint, dizzy, or fatigued. Hand, shoulder, or back pain was also reported by some wildlife cleaning workers (Centers for Disease Cont rol and Prevention 2010). Spill response workers can be exposed to heat stres s and acute exposure to hydrocarbons. Typical symptoms include: headaches, dizziness, nausea, vomiting, cough, respiratory distress, and chest pa in (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/lon g duration spill.Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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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 phys iographic areas: the Chenier Plains and barrier islands. These coastal barriers are relatively low landmasses that can be divided into several interre lated environments, including the unvegetated foreshore, the dune zone, and the b ackshore. When coastal storms occur, GOM waters may become elevated enough to ove rwash a coastal barrier, leveling the areas of beach and dunes, creating ove rwash fans or terraces. Within a week, overwashed beaches may reestablish their ty pical structure. Over longer periods, terraces will become revegetated by opport unistic species, and the formation of dunes will begin again with the availa bility and nature of windblown sand at each terrace. Landform changes can b e seasonal and cyclical. Coastal barriers are dynamic habitats and provide a variety of niches that support many avian, terrestrial, aquatic, and amphibian spe cies, 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 regre ssive sequences. A transgressive sequence moves the shore landward all owing marine deposits to form on terrestrial sediments. A regressive sequenc e is one in which terrestrial sediments are deposited over marine deposits as lan d builds out, into the sea. Although transgressive landforms are dominant in th e 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 hurricane s. The areas have experienced varying degrees of erosion, land and ve getation loss, loss in elevation or beach profile and, in some cases, movement towar d shore as a result of the previous hurricane seasons. The resulting change i n elevation and island profiles reduces the ability of these features to provide th e pre-storm coastal protection to the mainland beaches and wetlands. While these barr iers can rebuild to some extent naturally over time, it is the intent of bot h Federal and State coastal restoration initiatives like the Coastal Wetlands P rotection, Planning & Restoration Act (CWPPRA), Louisiana Coastal Resourc es 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 vesse l traffic, marine debris, and accidental releases. The distan ce to the shore is about 172.4 mi (277 km) (Figure 4). An increase in the number of vessel trips, could re sult in minor incremental impacts to channels and coastal erosion rates. Sta ndard activities associated with exploration, development and production have been d ocumented and typically have a limited number of vessels required and a rel atively short timeframe forEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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each phase resulting in impacts being short term an d 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, i f 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 durati on could pose problems for beaches and nearshore barrier islands. Oil and gas infrastructure such as pipelines and well heads also pose a higher probability regar ding inshore oil spill threat (USDOI MMS 2007a and 2008b). The extent of such im pacts will vary depending on, among other factors, the magnitude an d duration of such an incident. Meteorological and hydrological conditions at the t ime of the spill coupled with the quantity and location of the spill determines t he fate of accidental oil spills (USDOI MMS 2002, 2007a and 2008b). Spilled oil wou ld need strong southerly winds to persist for an extended time prior to or i mmediately after the spill to elevate water levels to move onto beaches or across dunes. Strong winds would accelerate oil-slick dispersal, spreading, and weat hering, thereby reducing impact severity at a landfall site. A study in Texas show ed 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 e t al. 1981 and 1985). Oil or its components that remain in the sand after cleanup ma y be (1) released periodically when storms and high tides resuspend or flush beach sediments, (2) decomposed by biological activity, or (3) volatilized and disp ersed during hot or sunny days (USDOI MMS 2002, 2007a and 2008b). According to a Site Specific EA for a floating prod uction, storage and offloading (FPSO) facility (USDOI MMS 2008a) located in an adj acent area to the east, oil spills from the operations could produce either adv erse (but not significant) or extended (but not irreversible) impacts on coastal barrier beaches, depending upon spill size, the nature of the oil coming ashor e (e.g., highly vs. lightly weathered), and the location and characteristics of the coastal barrier beach. Impacts may be long term, depending upon spill loca tion and the relative position of sensitive resources. No significant impact is expected to coastal beache s. Contact is minimized due to distance from small spills. Implementation of new BOEMRE environmental and safety regulations may further reduce the probabili ty 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 an d sand flats; and forested wetlands of mangrove swamps, cypress-tupelo swamps, and bottomland hardwoods. These can support mixed communities of plant species or pure standsEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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of single species. Coastal wetlands are characteri zed by high organic productivity, high detritus production, and efficie nt nutrient recycling. Wetlands provide habitat for a great number and wide diversi ty of invertebrates, fish, reptiles, birds, and mammals, and are particularly important nursery grounds for many economically important fish and shellfish (USD OI MMS 2002, 2007a and 2008b).

The Deltaic Plain wetlands are on a series of overl apping 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 acti ve Mississippi River channel tended to build outward, and marsh areas tended to expand. At the same time, areas located near inactive, abandoned channels ten ded to deteriorate and erode as a result of the lack of sediment. Today, the Missi ssippi River is leveed, which greatly reduces the once natural formation of Delta ic 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 Loui siana 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 mudfla ts that are now marshes or open water. The mudflats were built during times w hen the Mississippi River Channel was located on the western side of the Delt aic Plain or when minor changes in localized hydrologic and sedimentation p atterns favored deposition on the Chenier Plain (USDOI MMS 2002, 2007a and 2008b)

. Along the Texas coast in the vicinity of southern P adre Island, marshes are minimal and unstable, compared with the more northe rn GOM. Brackish marshes occur in less saline, inland areas and are divided into frequently and infrequently flooded marshes. Infrequently flooded marshes conta in an assemblage of plants that are much more tolerant of dry conditions.

Freshwater marshes in Texas occur inland above tida lly delivered saline waters, in association with streams, lakes, and catchments. B roken 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 sa nd are mostly found around shallow bay margins and in association with shoals. South of Corpus Christi and into Tamaulipas, flats increasingly replace lagoona l and bay marshes. Laguna Madre of Texas is divided into northern and souther n parts by the wind-tidal flats of the Land-Cut Area, just south of Baffin Bay. Th e 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 t he shores of bays, lagoons, and tidal streams. The structure of these beaches is s imilar to, but much narrower and smaller in scale than, barrier beaches. Compared w ith 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).Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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Several factors contribute to wetland loss in coast al Louisiana. Sediment deprivation is a result of a 50 percent decreases i n the suspended-sediment load of the river since the 1950’s, the channelization of t he river, and the primary cause, the construction of the flood protection levees. S ubsidence and sea level rise have caused submergence of lower wetland areas. Constru ction of ring levees allowed drainage and development of extensive wetlands. De velopment activities in low areas, outside leveed areas, have caused the fillin g of wetlands. Construction of canals converted wetlands to open water and upland spoil banks. Canals and subsidence also contributed to increased tidal infl uence 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 vesse l traffic and accidental releases. Only a slight increase in ves sel traffic is expected to occur, but vessel size may increase due to supply needs an d open-sea conditions. Currently, existing ports, production facilities, a nd navigation channels would be used, eliminating the need for the expansion or con struction of facilities into wetland areas. Vessel support would likely use arm ored coastal channels, as well as existing offshore channels and sea lanes. No si gnificant impact is expected. The primary accidental IPF associated with the pote ntial to impact coastal wetlands is oil spills. Barrier islands can provid e 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 o f the islands. Should a spill occur inshore or in nearshore waters, it presents a much greater potential for adversely impacting wetlands than an offshore deepw ater spill simply due to proximity. The works of several investigators (Webb et al. 198 1 and 1985; Alexander and Webb 1983, 1985, and 1987; Lytle 1975; Delaune et a l. 1979; Fischel et al. 1989) evaluated the effects of potential spills to wetlan ds. The primary reason for vegetation loss and ultimately facilitating land lo ss associated with an oil spill is impact to the vegetation root system. Vegetation d iebacks may only happen for one growing season depending upon the concentration and the season during which contact occurs. The extent of such impacts w ill vary depending on, among other factors, the magnitude and duration of such a n incident. The larger the spill with longer duration may result in more impact. Distant offshore spills have a further diminished p robability of impacting inland wetland shorelines and seagrasses, largely due to t heir 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, th ough the probability is likely also very small. Should a spill occur inshore or in nea rshore waters, it presents a much greater potential for adversely impacting wetlands and seagrasses, due to their proximity to the spill. Oil could accumulate in sh eens and thick layers in the marsh and in protected pools and embayments (USDOI MMS 2002, 2007a and 2008b).Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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No significant impact is expected to wetlands. Con tact is minimized due to distance from small spills. Implementation of new BOEMRE environmental and safety regulations may further reduce the probabili ty 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 contig uous wetlands of the northeastern GOM are populated by b oth resident and migratory species of coastal and marine birds. This analysis assumes five major groups in the area of concern: seabirds, shorebirds, marsh an d wading birds, waterfowl, and raptors. Many species are mostly pelagic and, there fore, are rarely sighted nearshore. Fidelity to nesting sites varies from ye ar to year along the Gulf coast (Martin and Lester 1991). Birds may abandon sites a long the northern Gulf coast because of altered habitat and excessive human dist urbance.

Shorebirds are those members of the order Charadrii formes generally restricted to coastline margins (beaches, mudflats, etc.). GOM sh orebirds comprise five taxonomic families; Jacanidae (jacanas), Haematopod idae (oystercatchers), Recurvirostridae (stilts and avocets), Charadriidae (plovers), and Scolopacidae (sandpipers, snipes, and allies) (Hayman et al. 198 6). An important characteristic of almost all shorebird species is their strongly d eveloped migratory behavior, with some shorebirds migrating from nesting places in the far north to the southern part of South America (Terres 1991). Alon g the Gulf coast, observers have recorded 44 species of shorebirds. Six specie s nest in the area; the remaining species are wintering residents and/or “s taging” transients (Pashley 1991). The term wading birds refers to birds that have ada pted to living in marshes and shallow water. Seventeen species of wading birds i n 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 f amilies have representatives in the northern GOM: Ardeidae (herons, bitterns, and e grets), Ciconiidae (storks), Threskiornithidae (ibises and spoonbills), Gruidae (crane), and Rallidae (rails, moorhens, gallinules, and coots). Waterfowl belong to the taxonomic order Anseriforme s and include swans, geese, and ducks. A total of 27 species are regularly rep orted along the north-central and western Gulf coast (Clapp et al. 1982; National Geo graphic Society 1983; Madge and Burn 1988). Many species usually migrate from wintering grounds along the Gulf coast to summer nesting grounds in the norther n 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, Mi ssissippi, and Alabama) flyway. Waterfowl are social and have a diverse arr ay of feeding adaptations related to their habitat (Johnsgard 1975). There are three main groups of diving birds, respec tively: cormorants and anhingas, loons, and grebes. Of the two pelican sp ecies in North America, only the brown pelican is listed as endangered.Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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Several other birds that inhabit or frequent the no rthern GOM coastal areas are recognized by U. S. Fish and Wildlife Service (FWS) as either endangered or threatened: interior least tern, Mississippi sandhi ll crane, piping plover, whooping crane, and wood stork. Detailed descriptions of th e 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 West ern and Central GOM Multisale Lease Areas (USDOI MMS 2007a) and draft s upplemental 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 F lorida south to Tampa Bay, Alabama, Louisiana, and Texas. Critical habitat ide ntifies specific areas that are essential to the conservation of a listed species a nd 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 roost ing. The least tern is not considered federally endangered or threatened withi n 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 liste d as endangered or threatened; these are included under Shore Birds an d Coastal Nesting Birds. Impact Analysis - IPFs potentially affecting shore birds and coastal nesting birds include helicopter traffic, marine debris, and acci dental release. An accidental oil spill from the proposed activities could cause impa cts 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 th e proposed action could sporadically disturb feeding, resting, or nesting b ehavior of birds or cause abandonment of preferred habitat. These IPFs could contribute to indirect population loss through reproductive failure result ing from nest abandonment. The FAA (Advisory Circular 91-36C) and corporate he licopter policy specify minimum altitude over populated areas and biologica lly sensitive areas such as wildlife refuges and national parks. Although thes e incidents are very short term in duration and sporadic in frequency, they can dis rupt coastal bird behavior and, at worst, possibly result in habitat or nest abando nment. No significant impact is expected.

Service vessels should use selected nearshore and c oastal (inland) navigation waterways, or corridors, and adhere to protocol set forth by the USCG for reduced vessel speeds within these inland areas. Routine p resence and low speeds of service vessels within these waterways would dimini sh the effects of disturbance from service vessels on nearshore and inland popula tions of coastal and marine birds. The effects of service-vessel traffic on bi rds offshore would result in no significant impact. Coastal and marine birds can become entangled and s nared in discarded trash and debris. Additionally, many species will ingest sma ll plastic debris, eitherEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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intentionally or incidentally. Compliance with NTL 2007-G03 is expected to result in no significant impact with trash and debr is. Refer to Section 1.0 for additional information. Oil-spill cleanup methods often require heavy traff icking of beaches and wetland areas, application of oil dispersant and bioremedia tion chemicals, and the distribution and collection of oil containment boom s and absorbent material. The presence of humans, along with boats, aircraft, and other technological creations, could also disturb coastal birds after a spill. In vestigations have shown that oildispersant mixtures are similar to that of oil alon e 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 redu ce chick survival more than exposure to oil alone; however, successful dispersa l of a spill will generally reduce the probability of exposure of coastal and m arine 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 intensifie d research activity after the oil spills (Maccarone and Brzorad 1994). If physical oiling of individuals or local groups o f birds occurs, some degree of both acute and chronic physiological stress associa ted with direct and secondary uptake of oil would be expected (USDOI MMS 2002, 20 07a and 2008b). In addition, recent spill experience showed that bird mortality is expected to occur during a large volume/long duration spill (USDOI BO EMRE 2010b).
Stress, trauma, and shock enhance the effects of ex posure and poisoning (USDOI MMS 2002, 2007a and 2008b). Low levels of oil coul d stress birds by interfering with food detection, feeding, predator avoidance, t erritory 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 ha zing from the path of an approaching oil slick or the use of booms to protec t sensitive colonies in an emergency, have limited applicability (Clark 1984). No significant impact is expected to shore birds an d coastal nesting birds. Contact is minimized due to distance from small spi lls. Implementation of new BOEMRE environmental and safety regulations may fur ther reduce the probability of the occurrence of a large volume/lon g 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 (Lagu na Atacosa, Aransas, Big Boggy, San Bernard, Brazoria, Moody, Anahuac, McFad den, Texas Point, Shell Keys Delta, Breton and St. Bernard) that are locate d along the Northern GOM along the coast. In addition to the NWR system, the National Estuari ne Research Reserve (NERR) System is a network of protected areas established for longterm research,Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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education, and stewardship. This partnership progr am between NOAA and coastal states has established five reserves (Grand Bay NERR, Weeks Bay NERR, Rookery Bay NERR, Apalachicola NERR, and Mission-Ar ansas NERR) in the GOM. Impact Analysis – An accidental oil spill from the proposed activit ies could cause impacts to coastal wildlife refuges. However , due to the distance to shore (about 172.4 mi) (Figure 4) and the response capabi lities that would be implemented, no significant adverse impacts are exp ected. Contact is minimized due to distance from small spills. Implementation of new BOEMRE environmental and safety regulations may further re duce the probability of the occurrence of a large volume/long duration spill.

3.3.5 Other Environmental Resources Identified

Other environmental resources identified were socio economic and groundwater and onshore surrounding environments.

3.3.5.1 Socioeconomics

Affected Resource – The GOM provides more than 34 percent of the commer cial fish landings in the continental United States (USD OC NMFS 2006). Commercially important species include the estuary- dependent species such as Atlantic menhaden, shrimps, oyster, crabs, and scia enids (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 m illion pounds and valued at about $367 million, was the most important GOM spec ies in value landed during 2004. The 2004 GOM oyster fishery accounted for ne arly 93 percent of the national total with landings of 25 million pounds o f 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 ha rvested 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 billi on in value added impacts, and over 100,000 jobs (USDOC NMFS 2010a). Unlike comme rcial fishing, recreational fishing is concentrated during the sum mer months. Tourism and recreation are integral components of t he economy of the GOM. Visitors to Texas, Louisiana, Mississippi, Alabama, and Florida spent approximately $145 billion in 2008 (USDOI BOEMRE 20 11a). This spending helped to support approximately 2.4 million jobs in recreation-based industries statewide. Approximately, 600,000 of these jobs ar e 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 reas onably cyclical, with the peak months during the past few years occurring between March and June (USDOI BOEMRE 2011a).Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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The importance of the oil and gas industry to the c oastal communities of the GOM is significant, especially in Louisiana, easter n Texas and coastal Alabama (USDOI MMS 2007a and 2008b). Oil service related e mployment is concentrated in coastal Louisiana Parishes (St. Mar y, Terrebone, Lafourche, Iberia, and Plaquemines) and drilling related emplo yment is most concentrated in Harris County, Texas and Lafayette Parish Louisiana (USDOI BOEMRE 2011a). Changes in OCS oil and gas activities have signific ant employment implications to the communities, especially those directly or in directly related to oil and gas development (USDOI MMS 2007a and 2008b). Sufficient land is designated in commercial and ind ustrial 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 accompa nied by development of onshore service and support facilities. This onsho re infrastructure includes gas processing plants, navigation channels, oil refiner ies, pipelines, storage yards, fabrication yards, separation facilities, service b ases, and terminals as well as landfills and disposal sites for drilling and produ ction wastes (USDOI MMS 2007a and 2008b). Archaeological sites provide recreational opportuni ties (e.g. tourism and diving) both offshore and onshore. Damage by an accidental release on corals and other organisms on archaeological resources (i.e. shipwre ck sites) could change the surrounding site and increase degradation. Additio nally, onshore habitat could degrade and erode, which would increase exposure to and subsidence of prehistoric and historic sites. Archaeological res ources 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 ha s the potential to impact on recreation and tourism; recr eational and commercial fishing and employment. Tourism impact would depend on the extent to which any structural/ecological damage can be repaired, as we ll as on the extent to which public confidence in the tourism industry can be re stored (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 act ivity in a region to the extent that the fish population has decreased. An accidental r elease may or may not result in fishery closures, depending on the magnitude and du ration 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 b ase facilities in Louisiana. BP will use the existing shorebase (C-Port Fourchon Sh orebase, Fourchon Heavy Lift and Serimax Yard) located in Fourchon, Terrebonne P arish, Louisiana to support general vessel operations. No expansion of these p hysical facilities is expected to result from the proposed supplemental activities. The C-Port Fourchon facility is located approximately 257 mi (Figure 4) from the ge neral project area, provides a vehicle parking lot, office space, radio communicat ion equipment, outside andEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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warehouse storage space, crane, forklifts, water an d fueling facilities, and boat dock space. The base is in operation 24 hours eac h day. No new or expanded facilities will be constructed, and no new employees are expected to move permanently into the area. The pro ject will have a negligible impact on socioeconomic conditions such as local em ployment, 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 i ncluding scarce coastal resources, will represent a small fraction of the l evel of activity occurring at the shore base. The response to a release would be sta ged primarily out of existing facilities; however, there could be limited tempora ry 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 dem obilized. 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/lon g duration spill.

3.3.5.2 Groundwater and Onshore Environments

Affected Resource – Offshore drilling operations generate several type s of wastes such as municipal trash (paper, plastic, woo d, 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 S ection 6.0 of the EP for additional information regarding wastes types and a mounts. Operational waste is collected and stored until it is shipped to shore f or disposal or recycling at BP approved landfills or disposal companies. An accidental release of oil could generate large q uantities of additional waste materials and debris. This could include: tar balls , oiled vegetation and sand, used personal protective equipment (PPE), oil and oily w ater, and oiled sorbent materials (e.g. rags, boom and absorbent pads) (USE PA 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 gen erated 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 Ga s Scenario Examination: Onshore Waste Disposal (Dismukes et al. 2007), curr ent landfills located in Texas, Louisiana, Mississippi, and Alabama have an estimated permitted capacity of 386,545,904 tons and an average useful life of 3 2 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 f or the GOM region. Activities covered in this EP will utilize a limited number of BP approved disposal sitesEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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located in Louisiana. Refer to Section 6.0 of the E P for additional information regarding approved waste disposal venders and sites

. Impact Analysis: IPFs that could affect ground water and onshore en vironments are onshore waste disposal. Landfills are state pe rmitted waste management facilities and must comply with the Resource Conser vation and Recovery Act (RCRA) regulations at the federal, state and local levels. The regulations include design criteria for the protection of groundwater a nd the surrounding environments such as: Location restrictions, compos ite liner requirements, leachate collection and removal systems, operating practices, groundwater monitoring requirements, closure and post-closure c are requirements, corrective action provisions, and financial assurance. BP cond ucts routine independent audits of commercial waste disposal facilities to r eview 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 managemen t plans, manifesting trash sent to shore, and using special precautions such a s covering outside trash bins to prevent accidental loss of solid waste in accordanc e with NTL 2007-G03. Refer to Section 1.0 for additional information. Special ca ution will be exercised when handling and disposing of small items and packaging materials, particularly those made of non-biodegradable, environmentally persiste nt materials such as plastic or glass. BP has developed waste management plans for the col lection, handling, management and disposal of such wastes. These plans are written to ensure wastes are handled safely and in accordance with ex isting 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 drink ing 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 landfi ll capacities do not appear to be a constraint in any fashion to the ongoing or futur e development of offshore oil and gas activities. Environmental regulators in the region indicated that existing facilities have ample capacity and see no future co nstraints. The USEPA recently stated that landfills receiving wastes have abundan t capacity to handle the expected wastes from large response efforts and; th erefore, the addition of the waste generated from large response efforts would n ot significantly shorten the expected life-span of the landfills (USEPA 2010). Therefore, there are no significant impacts expecte d from onshore waste disposal to groundwater and the onshore environments.

4.0 CUMULATIVE IMPACT ANALYSIS

The BOEMRE fully addressed the cumulative effects o f OCS (i.e., oil and gas leasing, exploration, development, and production) and non-OCS related activitiesEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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for the CPA and WPA as well as the Gulf Coast regio n as part of the NEPA documentation completed for proposed multi-sale lea se activities. OCS related activities include routine operations (e.g., drill rig presence (noise and lights), bottom disturbing activities, vessel traffic, opera tional discharges, noise generated by platforms, drillships, helicopters and vessels, seismic surveys, explosive structure removals) and accidental events (e.g., oi l spills, oil-spill-response activities, vessel collisions loss of debris from s ervice vessels and OCS structures). Non-OCS related activities were consi dered, but not limited to crude oil import tankering, State oil and gas activity, r ecreational and commercial fishing, coastal development, natural processes (hy poxia), and recreational, commercial and military vessel traffic. These OCS and non-OCS activities are considered in this section so far as they could con tribute to the cumulative environmental and socioeconomic impacts pertinent t o the proposed activities. Cumulative impacts from OCS and non-OCS related act ivities are discussed in Chapter 4.5 of the multi-sale EIS (USDOI MMS 2002 a nd 2007a) and Chapter 4.1 of the supplemental EIS (USDOI MMS 2008b). Add itional impacts from accidental releases are discussed in Chapter 4 of t he multi-sale EIS’s (USDOI MMS 2002 and 2007a) and the Supplemental EIS (USDOI MMS 2008b). The proposed activities described in the EP are sim ilar 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, includin g cumulative impacts, against new information related to the Macondo inci dent. The cumulative impacts discussed in these BOEMRE NEPA documents in clude both the project specific work proposed in these documents and other reasonably foreseeable activities expected to take place in the GOM. Incr emental 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, an d the limited geographic scope and duration. Although regulatory uncertainties continue to affec t the approval of new exploration and development plans, and the issuance of new permits to drill, additional projects are expected to proceed. The c losest existing production facility is in Garden Banks Block 668, about 30 mil es 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 t he immediate vicinity of the proposed EP activity. Discussions below address ho w the impacts, if any, from the proposed EP activities are expected to contribu te to the cumulative impacts of this and other similar projects. The Gulf Coast has survived major natural and manma de disasters (i.e., hurricanes and oil spills), through which the peopl e and environmental resources of the GOM and the Gulf Coast have repeatedly demon strated their resiliency. While environmental and socioeconomic resources may recover from a natural or manmade disaster if given enough time between disas ters, disasters happening in unison or within short periods of each other would make recovery more difficult (USDOI BOEMRE 2011a).Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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The magnitude of OCS and non-OCS activity in the GO M 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 l arge blowout and spill could contribute to cumulative impacts on a variety of GO M resources (USDOI BOEMRE 2011a).
Benthic Communities (Soft Bottom Benthic Communitie s, High Density Deepwater Benthic Communities, Designated Topograph ic 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 d ynamically positioned rig. Slight increases in turbidity from drilling mud and cuttings are expected to be localized and temporary (USDOI BOEMRE 2011a). Subs urface spills, including a catastrophic event, could result in sediment or o ily 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). Recolonizatio n 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 sh ort term impacts. No significant incremental cumulative impacts to these benthic features and communities are expected as a result of the propose d activities as well as other reasonably foreseeable future activities in the are a. 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 ma y occur from vessels transporting crude oil and petroleum products; from vessels invo lved in commercial fishing, freight or passenger transport; and from OCS operat ions (USDOI BOEMRE 2011a).” During a well blowout the water quality o f marine waters could be impacted by increase turbidity and the release of o il (USDOI BOEMRE 2011a). Short-term, localized changes in water quality woul d be expected from an oil spill ≥ 1,000 bbl and cumulative impacts would be negligibl e (USDOI BOEMRE 2011a). The extent of such impacts will vary depen ding 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 impac ts. 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, cr ude oil imports by tanker,Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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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 2 011a). The drilling rig is a single, temporary structure; therefore, impact s on fish populations, whether beneficial or adverse, would be considered insignif icant. Slight increases in turbidity from drilling mud and cuttings are expect ed to be localized and temporary. A well blowout scenario could introduce oil to surface or subsurface waters. Behavior science associated with adult fis h 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 20 07a). Mitigation measures such as those required by laws, regulations, lease stipulations and NTLs are expected to minimize impacts. No sign ificant incremental cumulative impacts to fisheries and EFH are expecte d 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 traff ic, noise generated by platforms, drillships, helicopters and vessels, seismic survey s, 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 OC S-related activities could stress and/or weaken individuals of a local g roup or population and make them more vulnerable to infection from natural or a nthropogenic sources (USDOI BOEMRE 2011a). Few deaths are expected from chance vessel collisions, ingestion of plastic material by compliance with NT L 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 sign ificant incremental cumulative impacts to marine mammals and sea turtle s 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 1 72.4 miles offshore. Cumulative impacts on air quality within the offshore area would come primarily from non-OCS oil/gas activities in the GO M as well as onshore sources such as emissions from industrial plants, power gen eration, and urban transportation (USDOI BOEMRE 2011a). The projected air emissions are not expected to aff ect the air quality of the OCS primarily due the distance to the shore or to any P revention of Significant Deterioration Class I air quality area such as the Breton Wilderness Area. Keathley Canyon Block 93 is beyond the 200 kilomete r (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).Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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Mitigation measures such as those required by laws, regulations, lease stipulations and NTLs are expected to minimize impacts. No sign ificant 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 Prehistori c Archaeological Sites - Several impact-producing factors may threaten histo ric archaeological resources. An impact could result from a contact between a his toric shipwreck and an OCS activity (pipeline and platform installations, dril ling rig emplacement and operation, dredging, and anchoring activities) (USD OI BOEMRE 2011a). Keathley Canyon Block 93 are not stipulated as requ iring archaeological resource surveys and reports (NTL 2005-G07 and 2008-G20). A review of the Shallow Geohazards Assessment (Fugro 2010) was conducted an d indicates there is no known or potential shipwreck sites located within t he survey area. The proposed drilling will be done with a dynamic positioned rig which does not have associated anchors, anchor chains or wire ropes; th erefore, no impacts on such sites are expected as a result of the proposed oper ations. During oil and gas exploration and development as w ell as during fishing or other maritime activities, the loss or discard of ferroma gnetic 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 sensin g 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 sign ificant incremental cumulative impacts to shipwrecks and prehistoric ar chaeological 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, pela gic, coastal nesting and shore birds are expected to be sublethal: behavioral effe cts, sublethal exposure to or intake of OCS-related contaminants or discarded deb ris, temporary disturbances, and displacement of localized groups from impacted habitats (USDOI MMS 2007a). Chronic sublethal stress, however, is ofte n undetectable in birds. As a result of stress, individuals may weaken, facilitat ing 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 natu re 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 deb ris. Oil-spill cleanup methods often require heavy traff icking of beaches and wetland areas, application of oil dispersant and bioremedia tion chemicals, and the distribution and collection of oil containment boom s and absorbent material. TheEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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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 sign ificant incremental cumulative impacts to marine, pelagic, coastal nest ing 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 H 2 

### S release from the proposed activities is not expected. Some members of the pu blic could be exposed to oil on the water and along the shoreline, including skin c ontact or breathing volatile organic compounds. The amount of exposure will dep end on the magnitude and duration, the physical/chemical characteristics of the material, the oceanic conditions and the effectiveness of the spill respo nse. Mitigation measures such as those required by laws, regulations, lease stipulations and NTLs are expected to minimize impacts. No sign ificant incremental cumulative impacts to public health and safety are expected as a result of the proposed activities as well as other reasonably for eseeable future activities in the

area. Beaches, Wetlands, Coastal Wildlife Refuges and Wil derness Areas - The distance to the nearest shore is 172.4 miles (Figu re 4). An increase in the number of vessel trips, could result in minor incremental impacts to channels and coastal erosion rates. Currently, existing ports, producti on facilities, and navigation channels would be used, eliminating the need for th e expansion or construction of facilities into wetland areas. Offshore oil spills of large volume and long durati on could produce impacts on beaches and nearshore barrier islands. Implementat ion of new BOEMRE environmental and safety regulations may further re duce 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 sign ificant incremental cumulative impacts to beaches, wetlands, coastal wi ldlife refuges and wilderness areas are expected as a result of the proposed acti vities 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 we ll as on the extent to which public confidence in the tourism industry can be re stored (USDOI BOEMRE 2011a). Recreational resources and tourism in coas tal 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 Gu lf of Mexico is so immense that routine activities associated with a s ingle 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 l arge blowout and spill could contribute to cumulative impacts (USDOI BOEMRE 2011 a). The project willEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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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 ha ve 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 sign ificant incremental cumulative impacts to socioeconomics are expected a s 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 Contingenc y Plan identifies the thresholds (e. g. wind speed, current speed) at which such impacts ma y 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 th e EP. The BOEMRE’s lease stipulations, OCS Operating Regulations, NTLs, and other regulations and laws were identified throughout this environmental impact ana lysis as existing mitigation to minimize potential environmental effects associated with the proposed action. Considering the mitigative measures, this alternati ve was selected for evaluation in this EIA.

7.0 MITIGATION MEASURES The EP contains numerous mitigation measures requir ed by laws and regulations, lease stipulations and NTL’s. Additional mitigation meas ures include:

• Low sulfur fuel to be used.

• NPDES permit compliance will minimize potential env ironmental impact.

• Water treatment equipment will be effectively opera ted and maintained to reduce pollutant discharge.

• A waste minimization plan will be followed for ongo ing operations to recycle and source reduce waste. BP is covered by a Regional OSRP approved by the BO EMRE. BP has contracts in-place with three (3) Oil Spill Removal Organizations (OSR O's): The National Response Corporation (NRC), the Marine Spill Response Organi zation (MSRC), and Clean Gulf Associates (CGA). NRC, MSRC and CGA will provide b oth equipment and trained personnel in the event an oil spill response is mou nted as a result of BP's proposedEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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8.0 CONSULTATION No agencies or persons were consulted regarding pot ential 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

10.0 REFERENCES
Albers, P.H. 1979. Effects of Corexit 9527 on the h atchability of mallard eggs. Bull. Environ. Contam. and Toxicol. 23:661-668. Albers, P.H. and M.L. Gay. 1982. Effects of a chemi cal dispersant and crude oil on breeding ducks. Bull. Environ. Contam. and Toxicol. 9:138-139.
Alexander, S.K. and J.W. Webb. 1983. Effects of oil on growth and decomposition of Spartina alterniflora . In: Proceedings, 1983 Oil Spill Conference. Febru ary 28- March 3, 1983, San Antonio, TX. Washington, DC: Ame rican Petroleum Institute. Pp. 529-532. Alexander, S.K. and J.W. Webb. 1985. Seasonal respo nse of Spartina alterniflora to oil. In: Proceedings, 1985 Oil Spill Conference . . . Fe bruary 25-28, 1985, Los Angeles, CA. Washington, DC: American Petroleum Ins titute. Pp. 355-357. Alexander, S.K. and J.W. Webb. 1987. Relationship o f Spartina alterniflora growth to sediment oil content following an oil spill. In: Pr oceedings, 1987 Oil Spill Conference. April 6-9, 1988, Baltimore, MD. Washing ton, DC: American Petroleum Institute. Pp. 445-450. Aten, L.E. 1983. Indians of the upper Texas coast. New York, NY: Academic Press.
American Petroleum Institute (API). 1989. Effects o f offshore petroleum operations on cold water marine mammals: a literature review. Was hington, DC: American Petroleum Institute. 385 pp. Balazs, G.H. 1985. Impact of ocean debris on marine turtles: entanglement and ingestion. In: Shomura, R.S. and H.O. Yoshida, eds. Proceeding s, Workshop on the Fate and Impact of Marine Debris, 26-29 November 1984, Honol ulu, HI. U.S. Dept. of Commerce. NOAA Tech. Memo. NOAA-TM-NMFS-SWFC-54. Pp 387-429.Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 50 of 67 C-K Associates, LLC Baker, J.M., R.B. Clark, and P.F. Kingston. 1991. T wo years after the spill: environmental recovery in Prince William Sound and the Gulf of Alaska. Institute of Offshore Engineering, Heriot-Watt University, Ed inburgh, EH14 4AS, Scotland. 31 pp. Barkuloo, J.M. 1988. Report on the conservation sta tus of the Gulf of Mexico sturgeon, Acipenser oxyrhunchus desotoi . U.S. Dept. of the Interior, Fish and Wildlife Service, Panama City, FL. Baumgartner, M.F. 1995. The distribution of select species of cetaceans in the northern Gulf of Mexico in relation to observed environmenta l variables. M.Sc. Thesis, University of Southern Mississippi. Benson, N. G., ed. 1982. Life History Requirements of Selected Finfish and Shellfish in Mississippi Sound and Adjacent Areas. U. S. Fish an d Wildlife Service, Office of Biological Services, Washington, D.C.: FWS/OBS-81/5 1. 97 pp. Biological Resources Division (BRD), USGS/BRD/CR-19 99-0006 and the Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2000-003.
Brown, Jr, L.F., J.H. McGowen, T.J. Evans, C.S. Gro at, and W.L. Fisher. 1977. Environmental geological atlas of the Texas coastal zone: Kingsville area. The University of Texas at Austin, Bureau of Economic G eology, Austin, TX. Butler, R.G., A. Harfenist, F.A. Leighton, and D.B. Peakall. 1988. Impact of sublethal oil and emulsion exposure on the reproductive success o f Leach’s storm-petrels: short- and long-term effects. Journal of Applied Ec ology 25:125-143. Carr, A. 1987. Impact of nondegradable marine debri s on the ecology and survival outlook of sea turtles. Mar. Poll. Bull. 18:352-356

. Centers for Disease Control and Prevention (CDC). 2 010. NIOSH Report of BP illness and injury data (April 23 – June 6, 2010). Internet website: http://www.cdc.gov/niosh/topics/oilspillresponse/pd fs/NIOSHReptBPInjuryandIllnessDataApril23-June6.pdf

. Clapp, R.B., R.C. Banks, D. Morgan-Jacobs, and W.A. Hoffman. 1982. Marine birds of the southeastern United States and Gulf of Mexico. U.S. Dept. of the Interior, Fish and Wildlife Service, Office of Biological Services , Washington, DC. FWS/OBS82/01. 3 vols. Clark, R.B. 1984. Impact of oil pollution on seabir ds. Environ. Pollut. Ser. A. 33:1-22
Coastal Environments, Inc. (CEI). 1977. Cultural re sources evaluation of the northern Gulf of Mexico continental shelf. Prepared for U.S. Dept. of the Interior, National Park Service, Office of Archaeology and Historic Pr eservation, Interagency Archaeological Services, Baton Rouge, LA. 4 vols. Coastal Environments, Inc. (CEI). 1982. Sedimentary studies of prehistoric archaeological sites. Prepared for the U.S. Dept. o f the Interior, National Park Service, Division of State Plans and Grants, Baton Rouge, LA.Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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‐ Spill .pdf Spies, R.B., J.S. Felton, and L. Dillard. 1982. Hep atic mixed-function oxidases in California flatfishes are increased in contaminated environments and by oil and PCB ingestion. Mar. Biol. 70:117-127. St. Aubin, D.J. and V. Lounsbury. 1990. Oil effects on manatees: Evaluating the risks. In: Geraci, J.R. and D.J. St. Aubin, eds. Sea mammals a nd oil: confronting the risk. San Diego, CA: Academic Press. Pp. 241-251. St. Aubin, D.J. 2001. Endocrinology. Pages 165-192 in L. A. Dierauf and F.M.D. Gulland eds. Handbook of Marine Mammal Medicine: He alth, Disease and Rehabilitation. Vol. 2. CRC Press, Boca Raton, FL. Stright, M.J., E.M. Lear, and J.F. Bennett. 1999. S patial data analysis of artifacts redeposited by coastal erosion: A case study of McF addin Beach, Texas. U.S. Dept. of the Interior, Minerals Management Service, Herndon, VA. OCS Study MMS 99-0068. 2 vols. Terres, J.K 1991. The Audubon Society encyclopedia of North American birds. New York, NY: Wing Books. 1,109 pp. Thompson, M.J., W.W. Schroeder, and N.W. Phillips. 1999. Ecology of live bottom habitats of the northeastern Gulf of Mexico: A comm unity profile. U.S. Dept. of the Interior, Geological Survey, Biological Resourc es Division, USGS/BRD/CR1999-0001 and Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA, OCS Study MMS 99-0004. x + 74 pp.Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 60 of 67 C-K Associates, LLC Underwood, A.J. and P.G. Fairweather. 1989. Supply side ecology and benthic marine assemblages. Trends Ecol. Evol. 4(1):16-20. U.S. Dept. of Commerce, National Marine Fisheries S ervice and U.S. Dept. of the Interior, Fish and Wildlife Service. 1993. Recovery plan for hawksbill turtles in the U.S. Caribbean Sea, Atlantic Ocean, and Gulf of Mexico. U.S. Dept. of Commerce, National Marine Fisheries Service, St. Pe tersburg, FL. 52 pp. U.S. Dept. of Commerce. National Marine Fisheries S ervice. 1999. Amendment 1 to the Atlantic billfish fishery management plan. U.S. Dep t. of Commerce, National Marine Fisheries Service, Highly Migratory Species Division. U.S. Dept. of Commerce. National Marine Fisheries S ervice. 2005e. Draft consolidated Atlantic highly migratory species fishery managemen t plan. Highly Migratory Species Management Division. Internet website: http://www.nmfs.noaa.gov/sfa/hms/Amendment2/DEIS%20 Exec%20Sum.pdf

. Accessed September 15, 2006. U.S. Dept. of Commerce. National Marine Fisheries S ervice. 2006. Marine recreational fisheries statistics survey, Gulf of Mexico. Intern et website: http://www.st.nmfs.gov/st1/recreational/index.html

. U. S Dept. of Commerce. National Marine Fisheries S ervice. 2009. Final Amendment 1 to the Consolidated Atlantic Highly Migratory Speci es Fishery Management Plan Essential Fish Habitat. Highly Migratory Species Ma nagement Division, Office of Sustainable Fisheries, Silver Spring, MD. June 2009

. http://www.nmfs.noaa.gov/sfa/hms/EFH/Final/FEIS_Ame ndment_Total.pdf U.S. Dept. of the Interior. Fish and Wildlife Servi ce. 2001. Technical agency draft, Florida manatee recovery plan ( Trichechus manatus latirostris ), third revision. U.S. Dept. of the Interior, Fish and Wildlife Servi ce, Atlanta, GA. 138 pp. U.S. Dept. of the Interior. Fish and Wildlife Servi ce. 2007. International Recovery Plan: Whooping Crane ( Grus americana ), Third Revision. Albuquerque, New Mexico. March 2007. U.S. Dept. of the Interior. Bureau of Ocean Energy Management, Regulation and Enforcement. 2010a. Gulf of Mexico – Increased Safe ty Measures for Energy Development on the Outer Continental Shelf for 30 C FR Part 50 – Environmental Assessment (EA) and Finding of No Significant Impac t (FONSI). OCS EIS/EA BOEMRE. U.S. Dept. of the Interior. Bureau of Ocean Energy Management, Regulation and Enforcement. 2010b. Modifications to Suspensions of Deepwater Drilling Operations – Environmental Assessment (EA) and Find ing of No Significant impact (FONSI). OCS EIS/EA BOEMRE. U.S. Dept. of the Interior. Bureau of Ocean Energy Management, Regulation and Enforcement. 2010c. Notice to Lessee (NTL) No. 2010 -N06 “ Information Requirements for Exploration Plans and Development Operations Coordination Documents in the Gulf of Mexico ”Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 61 of 67 C-K Associates, LLC U.S. Dept. of the Interior. Bureau of Ocean Energy Management, Regulation and Enforcement. 2011a. Gulf of Mexico – Site Specific Environmental Assessment (SEA). SEA No. S-7445. U.S. Dept. of the Interior. Bureau of Ocean Energy Management, Regulation and Enforcement. 2011b. Gulf of Mexico OCS oil and gas lease sale 218, Western Planning Area Lease Sale – draft supplemental envir onmental impact statement. OCAS EIS/EA BOEMRE 2011-218. U.S. Dept. of the Interior. Minerals Management Ser vice. 1997. Gulf of Mexico OCS oil and gas lease Sales 169, 172, 175, 178, and 182, Ce ntral Planning Area

— final environmental impact statement. U.S. Dept. of the I nterior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, U.S. Dept. of the Interior. Minerals Management Ser vice. 2000. Gulf of Mexico – Deepwater Operations and Activities Environmental A ssessment (EA). OCS EIS/EA MMS 2000-001. U.S. Dept. of the Interior. Minerals Management Ser vice. 2002. Gulf of Mexico OCS oil and gas lease sales 2003 - 2007: Central Planning A rea Sales 185, 190, 194, 198, and 201; Western Planning Area Sales 187, 192, 196, and 200, final environmental impact statement. U.S. Dept. of the I nterior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA . OCS EIS/EA MMS 2002-052. U.S. Dept. of the Interior. Minerals Management Ser vice. 2001. Evaluation of KerrMcGee Oil and Gas Corporation’s Development Operati ons Coordination Document, N-7045. Nansen Project, east Breaks, Bloc ks 602 and 646. Programmatic Environmental Assessment for Grid 4. U .S. Dept. of the Interior, Minerals Management Service, Gulf of Mexico OCS Reg ion, New Orleans, LA. OCS EIS/EA MMS 2001-075. U.S. Dept. of the Interior. Minerals Management Ser vice. 2005. Notice to Lessee (NTL) 2005-G07 “Archaeological Resource Surveys and Reports” U.S. Dept. of the Interior. Minerals Management Ser vice. 2007a. Gulf of Mexico OCS oil and gas lease sales 2007 - 2012: Western Planning A rea Sales 204, 207, 210, 215, and 218; Central Planning Area Sales 205, 206, 208, 213, 216, and 222, final environmental impact statement. U.S. Dept. of the I nterior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA . OCS EIS/EA MMS 2007-018. U.S. Dept. of the Interior. Minerals Management Ser vice. 2007b. Notice to Lessee (NTL) 2007-G03 “Marine Trash & Debris Awareness and Elimination” U.S. Dept. of the Interior. Minerals Management Ser vice. 2007c. Notice to Lessee (NTL) 2007-G04 “Vessel Strike Avoidance and Injured/Dead Protectiv e Species” U.S. Dept. of the Interior. Minerals Management Ser vice. 2008a. Site-specific evaluation of Petrobras America Inc.’s initial development ope rations coordination document, N-9015: Cascade-Chinook Project Walker Ri dge Blocks 205, 206, 249, 250, 425, 426, 469, and 470, site-specific env ironmental assessment for anEnvironmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 62 of 67 C-K Associates, LLC

FPSO facility. U.S. Dept. of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS EIS/EA MMS 2008-008. U.S. Dept. of the Interior. Minerals Management Ser vice. 2008b. Gulf of Mexico OCS oil and gas lease sales 2009 - 2012: Central Planni ng Area Sales 208, 213, 216, and 222; Western Planning Area Sales 210, 215, and 218, final supplemental environmental impact statement. U.S. Dept. of the I nterior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA . OCS EIS/EA MMS 2008-041. U.S. Dept. of the Interior. Minerals Management Ser vice. 2008c. Notice to Lessee (NTL) No. 2008-G04 “ Information Requirements for Exploration Plans and Development Operations Coordination Documents in th e Gulf of Mexico ” U.S. Dept. of the Interior. Minerals Management Ser vice. 2008d. Notice to Lessee (NTL) 2008-G20 “Revisions to the List of OCS Lease Blocks Requirin g Archaeological Resource Surveys and Reports” U.S. Dept. of the Interior. Minerals Management Ser vice. 2009. Notice to Lessee (NTL) 2009-G39 “Biologically-Sensitive Underwater Features and Are as” U.S. Dept. of the Interior. Minerals Management Ser vice. 2010. Notice to Lessee (NTL) 2009-G40 “Deepwater Benthic Communities” U.S. Environmental Protection Agency. 1993. Develop ment Document for Effluent Limitations, Guidelines, and Standards for the Offs hore Subcategory of the Oil and Gas Extraction Point Source Category. Office of Water. EPA 821-R-93-003. U.S. Environmental Protection Agency. Office of Com pliance. 2000. EPA Office of Compliance Sector Notebook Project. Profile of the Oil and Gas Extraction Industry. EPA/310-R-99-006. U.S. Environmental Protection Agency. 2004. Record of Decision (ROD) further to the Supplemental Environmental Assessment (SEA) regardi ng the reissuance of the Region 6 General Permit (GMG290000). U.S. Environmental Protection Agency. 2007. Region 6 General Permit (GMG290000). Final NPDES General Permit for New and Existing Sou rces and New Discharges in the Offshore Subcategory of the Oil and Gas Extr action Category of the Western Portion of the Outer Continental Shelf of t he Gulf of Mexico , 72 Fed. Reg. No. 109, p. 31575, effective October 1, 2007, expires midnight September 30, 2012. U.S. Environmental Protection Agency (USEPA). 2010. Questions and answers about the BP oil spill in the Gulf Coast. Internet website: http://www.epa.gov/BPSpill/qanda.html#waste19
Valentine, David L., J.D. Kessler, M.C. Redmond, S. D. Mendes, MB. Heintz, C. Farwell, L. Hu, F.S. Kinnaman, S.A. Yvon-Lewis, M. Du, E.W. Chan, F.G. Tigreros, and C.J. Villanueva. Propane Respiration Jump-Starts Microbial Response to a Deep Oil Spill. Science Magazine. Volume 330, pp208-211.Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### 63 of 67 C-K Associates, LLC Webb, J.W., G.T. Tanner, and B.H. Koerth. 1981. Oil spill effects on smooth cordgrass in Galveston Bay, Texas. Contributions in Marine Scien ce 24:107-114.
Webb, J.W., S.K. Alexander, and J.K. Winters. 1985. Effects of autumn application of oil

on Spartina alterniflora in a Texas salt marsh. Environ. Poll., Series A. 8( 4):321- 337.
White, W.A., T.R. Calnan, R.A. Morton, R.S. Kimble, T.G. Littleton, J.H. McGowen, H.S. Nance, and K.E. Schmedes. 1986. Submerged land s of Texas, BrownsvilleHarlingen aea. University of Texas at Austin, Burea u of Economic Geology, Austin, TX.Environmental Impact Analysis, Keatley Canyon Block 93 BP Exploration & Production, Inc.

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### ________________________________________________________________________

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 pot ential KC 93 oil spill using the BSEE Oil Spill Risk Analysis Model (OSRAM ) trajectory results. The OSRAM estimates the probability that oil sp ills 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 Pack age (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-trackingtechnologies (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 cont rol 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 containedprocessing 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 typica lly 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” confi guration. 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 mob ilized 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 (lik e 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 disper sant 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 thereare 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 limit ed 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 c onsist 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 moni toring 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 duri ng 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 ETALoadoutTimeETA to SiteDeploymentTimeTotal 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 r ounded 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 P ackageQuantityStaging AreaDistance toSite fromStaging (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

1Staging ETALoadout TimeETA to SiteDeploymentTimeTotal 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

2.93 0.5 1.06 Aerial Dispersant

System Supplier & PhoneDistance toSite fromStaging (Miles) Response Times (Hours)QuantityStaging 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 3.55 0.2

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
0.3 1.06 351 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

0.5Staging ETALoadoutTimeETA to SiteDeploymentTimeTotal 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)QuantityStaging AreaDistance toSite fromStaging (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 1Staging ETALoadout TimeETA to SiteDeploymentTimeTotal 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 Bladde r 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 CGA888-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 PackageQuantityEffective DailyRecovery Capacity(EDRC in Bbls/Day)Storage (Barrels)Staging AreaDistance toSite from Staging(Miles) Response Times (Hours)

CGA-53 MARCO Shallow Water

Skimmer CGA888-CGA2007 Houma, LA 3,588 Port Fourchon, LA 34

CGA-52 MARCO Shallow Water

Skimmer CGA888-CGA2007 Venice, LA 3,588 Port Fourchon, LA 34 CGA888-CGA2007 Galveston, TX 5,000 65

M/V Bastian Bay CGA888-CGA2007 Lake Charles, LA 5,000 65 Lake Charles, LA

CGA-54 Egmopol Shallow Water

Skimmer CGA888-CGA2007 Houma, 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 CGA888-CGA2007 Venice, LA 5,000 65 M/V RW Armstrong CGA888-CGA2007 Houma, 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

27 Venice, LA 324 2 1 23 1

1 29 1 35 263 4

1 19 1 30

35 29 263 4

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 5929ECoastal Zone Management Act Consis tency 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 MANAGEM ENT ACT INFORMATION ........................................1
2.0 CONSISTENCY CERTIFICATION.................................................................................1
3.0 LOUISIANA COASTAL ZO NE MANAGEMENT PROGRAM...................................1
A. GUIDELINES APPL ICABLE 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 a nd 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 a nd Industrial Waste Water to Coastal Waters Rule §501.21................................................................................10
CATEGORY 7 Non Point So urce 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 Mate rial Disposal and Placement (Rule §501.25).....................................................................................................17
CATEGORY 11 Construction in the Beach / Dune System (Rule §501.26)..................17 CATEGORY 12 Development in C oastal Hazard Areas (Rule §501.27) ......................17 CATEGORY 13 Development within Coastal Barrier Resource (Rule §501.28).........17 CATEGORY 14 Development in State Park s, 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)...........................................18Coastal Zone Management Act Consis tency 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 Appropriatio ns 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 CertificationCoastal Zone Management Act Consis tency 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, Mississi ppi and Texas developed Coastal Zone Management Programs (CZMP) to allow for th e supervision of signi ficant 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 consiste ncy certification a ccording to 15 CFR 930.76(c) and (d) for Louisiana and Te xas is included as Appendix A.

3.0 LOUISIANA COASTAL ZO NE 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 alterati ons, hydrologic and sediment transport modifications; waste disposal; uses that result in the al teration of waters draining into coastal waters; oil, gas or other mi neral activities; and ai r 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.louisian a.gov/CRM/coastmgt/ interagencyaff/consistency/pdf/Guideline s.pdf) are applicable to the proposed operations to Outer Continental Shelf (OCS) plan filings (http://www.gomr.boemre.gov/homepg/regu late/regs/ntls/enforpols.pdf):

A. GUIDELINES APPLICABLE TO ALL USES

Guideline 1.2: Applicable air and water qua lity laws and regulations compliance guidelines

Conformance with applicable water and air quality laws, standards and regulations, and with those other laws, st andards 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 Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

5929E 

### 2 C-K Associates, LLC Guideline 1.6: General factors that will be utilized by the permitting authority

Information regarding the following gene ral 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 a nd flood and storm hazard characteristics of site. c) techniques and materials used in c onstruction, operation and maintenance of

use. d) existing drainage patterns and wate r 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 pub lic and private benefits. i) extent of coastal water dependency of the use. j) existence of necessary infrastructu re to support the use and public costs resulting from use. k) extent of impacts on existing and trad itional 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, wild life 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, particul ar areas, or other areas of particular concern of th e state program or local programs. o) likelihood of, and extent of impact s 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, fi shing, public access, and recreational opportunities. r) extent of compatibility w ith 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 Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 3 C-K Associates, LLC Guideline 1.7: Adverse effects from la nd 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 ac tivities shall be plan ned, sited, designed, constructed, operated and maintained to avoid to th e 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 concen tration 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 temp erature 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 circulati on patterns within or into an estuarine system or a wetland forest. m) discharges of pathogens or toxi c substances into coastal waters. n) adverse alteration or dest ruction of archaeological, hi storical or other cultural

resources. o) fostering of detrimental secondary impacts in undisturbed or biologically highly productive wetland areas. p) adverse alteration or destruction of uni que or valuable habitats, critical habitat for endangered species, important wild life 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 area s, scenic rivers, or other areas of public use and concern. r) adverse disruptions of coastal w ildlife 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 biologica l productivity of the coastal ecosystem.

Addressed in Section 14.0 of the plan.Coastal Zone Management Act Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 4 C-K Associates, LLC Guideline 1.9: Permitting multiple uses to avoid conflict

Uses shall to the maximum extent practi cable 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 a pplicable. 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 w ill 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 operati on 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 maximu m extent practicable, and best practical techniques shall be used to minimize a dverse impacts which may result from such

use.

Addressed in Sections 5.0 and 12.0 of the plan.Coastal Zone Management Act Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 5 C-K Associates, LLC Guideline 8.2: Generati on, transportation, treatme nt, 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 onl y 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 temporar ily 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 AN D OTHER MINERAL ACTIVITIES

Guideline 10.3: Siting of exploratio n, production and refining activities

Exploration, production and refining activities shall, to the maximum extent practicable, be located away from critic al wildlife areas a nd vegetation areas. Mineral operations in wildlife preser ves and management areas shall be conducted in strict accordance with the re quirements of the w ildlife management body.

Addressed in Sections 2.0 and 14.0 of the plan.Coastal Zone Management Act Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 6 C-K Associates, LLC Guideline 10.5: Access to sites

Access routes to mineral exploration, production and refini ng 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 techni ques for drilling and production sites

Drilling and production sites shall be prep ared, constructed, and operated using the best practical techniques to preven t 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: Guide lines for drilling and production equipment for preventing adverse en vironmental effects

Mineral exploration, production and refini ng facilities shall be designed and constructed using best pr actical techniques to minimize adverse environmental impacts.

Addressed in Section 1.0 of the plan.

Guideline 10.11: Effectiv e environmental protecti on and emergency or contingency plans

Effective environmental protection and em ergency 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 opera tions. 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 (pipe lines); 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 Texa s Coastal Management Program (TCMP)Coastal Zone Management Act Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 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 propos ed operations to Outer Continental Shelf (OCS) plan filings (http://www.gomr.boe mre.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, facili ties shall be loca ted and operated and geophysical and other operations shal l be located and conducted in such a manner as to avoid and otherwise minimize adverse effects, including those from the disposal of solid wast e 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 em ployed. 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 perm ittees 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 mainte nance or enhancement of Coastal Natural resource Areas (CNRAs) or unl ess restoration activities would further degrade CNRAs.Coastal Zone Management Act Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 8 C-K Associates, LLC CNRA – any area defined in Texa s 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 sec tion when approving oil, gas, and other mineral lease plans of operation and granting surface leases, easements, and permits and adopting rules under the Texa s 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 Producti on 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 di sposal pit shall be located in any CNRA.

(2) Oil and gas waste disposal pits sh all be designed to prevent releases of pollutants that adversely affect coas tal waters or critical areas.

(b) Discharge of oil and ga s 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.Coastal Zone Management Act Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 9 C-K Associates, LLC (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 aff ect 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 discha rge produced waters to waters under tidal influence. In determining complianc e with the policies in this section, the RRC shall consider the effects of salinity from the discharge.

(c) The RRC shall comply with the policie s in this section when issuing permits and adopting rules under the Texas Natu ral Resources Code, Chapter 91, for oil and gas waste, and under Texas Water Code, Chapter 26, and the Texas Natural Resources Code, Chapter 91, fo r oil and gas wastewater discharges.

Addressed in Section 5.0 of the pl an (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 hazard ous waste facilities located within the coastal zone.

CATEGORY 5 Prevention, Response, a nd Remediation of Oil Spills Rule §501.20

(a) The GLO regulations governing preventi on of, response to and remediation of coastal oil spills shall provide for measures to prevent coastal oil spills and to ensure adequate response and rem oval actions. The GLO regulations for certification of vessels and facilities that handle oil shall be designed to ensure that vessels and facilities are capabl e 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 Assessm ent (NRDA). GLO rules under OSPRA governing the assessment of damages to na tural resources injured as the result of an unauthorized discharge of oil in to coastal waters shall provide for reasonable and rational procedures for a ssessing damages and shall take into account the unique circumstances of the sp ill incident. The costs of assessingCoastal Zone Management Act Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 10 C-K Associates, LLC the damages shall not be disp roportionate 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 th e 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 a nd 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 impl ementing regulations at Code of Federal Regulations, Title 40, which include establishing surface water quality standards in orde r to protect designated us es of coastal waters, including the protection of uses fo r water supply, recreational purposes, and propagation and protection of te rrestrial and aquatic life, and establishing water-quality-based effluent limits, including toxicity monitoring and specific toxicity or chem ical limits as necessary to protect designated uses of coastal waters;

(2) provide for the assessme nt of water quality on a coastal watershed basis as required by the Texas Water Code, §26.0135(d); (3) to the greatest extent practicable, pr ovide that all permits for the discharge of wastewater within a given waters hed or region of a single watershed contain the same expiration date in or der to evaluate the combined effects of permitted discharges on water quality within that watershed or region;

(4) identify and rank waters that ar e not attaining designated uses and establish total maximum daily pollutant loads in accordance with those rankings using scientifica lly 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.Coastal Zone Management Act Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 11 C-K Associates, LLC (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 polic ies in this section when adopting rules and authorizing wastewater discharges under Texas Water Code, Chapter 26.

(d) The TCEQ shall consult with the Texa s Department of Health when reviewing permit applications for wastewater disc harges 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 a nd secondary adverse effects of these activities will be considered.

(1) The policies in this s ection 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 crit ical 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 sh all be avoided to the greatest extent practicable.Coastal Zone Management Act Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 12 C-K Associates, LLC (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 compen satory mitigation shall be required to the greatest extent practicable fo r all adverse effects that cannot be avoided or minimized.

(4) Compensatory mitigation includes restoring adversely affected critical areas or replacing adversely affected cr itical 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 clos e physical proximity to the affected critical areas if practicable and in the same watershed if possible (off-site). Compensatory mitigation should also a ttempt to replace affected critical areas with critical areas with char acteristics identical to or closely approximating those of the affected cr itical areas (in-ki nd). 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 publ ic ownership of unique critical areas or other ecologically impor tant areas may be acceptable compensatory mitigation in exceptional circumstances. Examples of this include areas of high priority for pres ervation 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 fo rms of compensatory mitigation.

(6) In determining compensatory mitigation requirements, the impaired functions and values of the affected critical area shal l be replaced on a one-to-one ratio. Replacement of fu nctions and values on a one-to-one ratio may require restoration or repl acement of the physical area affected on a ratio higher than one -to-one. While no net lo ss 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 effect s of the activity are so significantCoastal Zone Management Act Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 13 C-K Associates, LLC that, even if alternatives are not available, the activity may not be permitted regardless of the comp ensatory mitigation proposed.

(7) Development in critical areas sh all not be authorized if significant degradation of critical areas will occur. Significant degradation occurs if:

(A) the activity will jeopardize the con tinued existence of species listed as endangered or threatened, or will resu lt in likelihood of the destruction or adverse modification of a habitat determ ined to be a crit ical habitat under the Endangered Species Act, 16 Unit ed States Code Annotated, §§1531 - 1544;

(B) the activity will cause or contribute, after consideration of dilution and dispersion, to violation of any appli cable surface water quality standards established under §501.21 of this title;

(C) the activity violates any applicable toxic effluent sta ndard or prohibition established under §501.21 of this title;

(D) the activity violates any requir ement imposed to protect a marine sanctuary designated under the Ma rine 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 secti on, the activity will, individually or collectively, cause or contribute to significan t adverse effects on:

(i) human health and welfare, including effects on water supplies, plankton, benthos, fish, shellfish, w ildlife, 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 byproduc ts beyond the site, or their introduction into an ecosystem, through biological, physical, or chemical processes;

(iii) ecosystem diversity, productivit y, and stability, in cluding loss of fish and wildlife habitat or loss of the capacity of a coastal wetland to assimilate nutrients, purify wa ter, 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 Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 14 C-K Associates, LLC (b) The TCEQ and the RRC shall comply w ith the policies in this section when issuing certifications an d adopting rules under Texa s Water Code, Chapter 26, and the Texas Natural Resources Code , Chapter 91, governin g certification of compliance with surface water quality standards for federal actions and permits authorizing development aff ecting critical areas; provided that activities exempted from the requireme nt 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 Regula tions, 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. Th e GLO and the SLB shall comply with the policies in this section when approving oil, ga s, 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 ev aluating alternatives, determining appropriate and practicable mitigation, and assessing significant degradation. Those agencies' rules governing authori zations for development in critical areas shall require a demons tration that the requirements of subsection (a)(1) - (7) of this section have been satisfied.

(d) For any dredging or construction of stru ctures in, or discharge of dredged or fill material into, cr itical 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 designe d and, to the greatest extent practicable, sited so that tides and currents will aid in fl ushing of the site or renew its water regularly.Coastal Zone Management Act Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 15 C-K Associates, LLC (2) Marinas designed for anchorage of pr ivate 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 leve l of water quality protection.

(4) Marinas, docks, piers, wharves and ot her structures shall be designed and, to the greatest extent practicable, s ited to avoid and otherwise minimize adverse effects on critical areas from boat traffic to and from those
structures.

(5) Construction of docks, piers, whar ves, and other structures shall be preferred instead of authorizing dredging of channels or basins or filling of submerged lands to provide access to co astal waters if su ch 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 re efs 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 interf ere with public navigation;

(B) does not significantly interfere with the natural coastal processes which supply sediments to shore area s or otherwise exacerbate erosion of shore areas; and

(C) avoids and otherwise minimizes sh ading of critical areas and other adverse effects.

(7) Facilities shall be locat ed 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 a nd 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 Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 16 C-K Associates, LLC (8) Where practicable, pipelines, transmission lines, cables, roads, causeways, and bridges shall be located in ex isting 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, c onstruction 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 im poundment or draining cannot be avoided, adverse effects to the impounde d or drained wetlands shall be mitigated in accordance with the sequencing requirements of §501.23 of this title. To the greatest extent pract icable, facilities sh all 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 sha ll 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 pub lic purposes or contribute to the maintenance or enhancement of coastal water quality, critical areas, beaches, submerged lands, or shore areas; or

(B) restoration activities woul d further degrade CNRAs.

(13) Water-dependent uses and facilitie s shall receive pref erence 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 stru ctural erosion response methods.

(15) Major residential and recreational waterfront facilities shall to the greatest extent practicable accommoda te 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 sha ll avoid and otherwise minimize any significant interference with the public's use of and access to such lands.Coastal Zone Management Act Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 17 C-K Associates, LLC (17) Erosion of Gulf beaches and co astal shore areas caused by construction or modification of jetties, breakwa ters, 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 cons truction or modifica tion and benefits include, but are not limited to, e nvironmental benefits, recreational benefits, flood or storm protection be nefits, 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 Mate rial 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 Coas tal Barrier Resource (Rule §501.28)

Not Applicable. No development will be conducted within coastal barrier

resources.Coastal Zone Management Act Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 18 C-K Associates, LLC CATEGORY 14 Development in State Park s, 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, educa tional, or scientific understanding.

(b) The Texas Historical Commission (THC) shall comply with the policies in this section when adopting rules and issu ing permits under the Texas Natural Resources Code, Chapter 191, governing alte ration of coastal historic areas. The THC shall comply with the policies in this section when issuing reviews under the National Historic Preservati on 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 quali ty in the coastal area so as to protect CNRAs and promote the public hea lth, safety, and welfare.

Addressed in Section 6.0 in the plan.

CATEGORY 18 Appropriations of Water (Rule §501.33)

Not applicable. No impoundment or di version of State water within 200 miles of the coast will be conducted.Coastal Zone Management Act Consis tency for Keathley Canyon Block 93 BP Exploration & Production, Inc. September 2010

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### 19 C-K Associates, LLC CATEGORY 19 Levee and Cont rol 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 se ction, "major action" mean s an individual agency or subdivision action listed in §505.11 of this title (relating to Actions and Rules Subject to the Coastal Management Pr ogram), §506.12 of this title (relating to Federal Actions Subject to the Coasta l 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 th e National Environm ental Policy Act, 42 United States Code Annotate d, §4321, et seq is required.

(b) Prior to taking a major action, th e agencies and subdivisions having jurisdiction over the activity shall meet and coordinate their major actions relating to the activity. The agencies a nd subdivisions shall, to the greatest extent practicable, consider the cumulati ve and secondary adverse effects, as described in the federal environmenta l impact assessment process, of each major action relating to the activity.

(c) No agency or subdivision shall take a ma jor action that is inconsistent with the goals and policies of this chapter. In addition, an ag ency or subdivision shall avoid and otherwise minimize the cumulative adverse effects to coastal natural resource areas of each of its ma jor 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 GUIDELINESTABLE 1LOUISIANA GUIDELINESGuideline TOPIC CROSS REFERENCE COMMENT1.2 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 2.03.1 - 3.16 Linear Facilities NA The proposed project is not a linear facility.4.1 - 4.7 Dredged Spoil Deposition NANo dredged spoil will be deposited as a result of theproposed project.6.1 Surface Alterations NA No surface alterations are proposed for this project.7.1, 7.3, and7.9Hydrologic and Sediment TransportModificationsNANo hydrologic or sediment transport modifications areproposed for this project.8.1Waste Storage, Treatment and DisposalFacilitiesSections 5.0 and 12.08.2Hazardous Waste Storage, Treatment andDisposalSections 5.0 and 12.08.8 Approved Disposal Sites Sections 5.0 and 12.08.9 Radioactive Waste Sections 5.0 and 12.09.2Alteration of Waters Draining into CoastalWatersNAThe proposed project will not affect any watersdraining into coastal waters.10.3 Siting of Exploration, Production Activities Sections 2.0 and 14.010.5 Access to Site Sections 2.0 and 12.010.6Best Practical Techniques forDrilling/Production SitesSections 2.0 and 5.010.9Drilling and Production Equipment Guidelinesfor Preventing Adverse Environmental EffectsSection 1.010.10Design of Facilities to Minimize AdverseEnvironmental Impacts10.11Effective Environmental Protection andEmergency or Contingency PlansSections 1.0, 7.0 and14.0

# TABLE 2

TEXAS GUIDELINESTABLE 2TEXAS GUIDELINESCategory No. TOPICCROSSREFERENCECOMMENT2Construction, Operation and Maintenance of Oiland Gas Exploration and Production ActivitiesSection 14.0No wetlands will be impounded or drained as part of this project. Uponcompletion, all facilities will be removed and any significantly degraded areaswill be restored to pre-project conditions.3Discharges of Wastewater and Disposal of Wastefrom Oil and Gas Exploration and ProductionActivitiesSection 5.04Construction and Operation of Solid WasteTreatment, Storage, and Disposal FacilitiesNA5Prevention, Response, and Remediation of OilSpillsSection 7.06Discharge of Municipal and Industrial WasteWater to Coastal WatersSection 5.07 Non Point Source Pollution NANo Non-point Source Water Pollution will be discharged as part of thisproject.8 Development in Critical AreasSections 9.0, and14.09Construction of Waterfront Facilities and OtherStructures on Submerged landsSections 11.0 and12.010Dredging and Dredged Material Disposal andPlacementNA11 Construction in the Beach / Dune System NA No development will be conducted within the Beach/Dune System12 Development in Coastal Hazard Areas NA No development will be conducted within Coastal Hazard Areas13 Development within Coastal Barrier Resource NA No development will be conducted within Coastal Barrier Resources14Development in State Parks, Wildlife ManagementAreas or PreservesNANo development will be conducted in State Parks, Wildlife ManagementAreas or Preserves15 Alteration of Coastal Historic AreasSections 4.0, 9.0,and 14.016 Transportation Projects NA17 Emission of Air Pollutants Section 6.018 Appropriations of Water NANo impoundment or diversion of state water within 200 stream miles of thecoast will be conducted for this project.19 Levee and Control Projects NA No levees will be constructed for this project.22 Policies for Major Actions Sections 14.0 Section 14.0 contains an Environmental Impact Analysis

# 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

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Account Holder Name: Betsy Cleland

Billing Address: 200 Westlake Park Blvd Billing Address 2: City: Houston State / Province: TX Zip / Postal Code: 77072
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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 Payment In formation Payment Amount: $6,884.00
Transaction Date and Time: 10/13/2011 13:47 EDT 

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